Full Access ACFE CFE-Investigation Tutorials

The Fraud Examiners Manual explains:

“A Certified Fraud Examiner should not promise confidentiality or leniency to an informant to obtain testimony… the confidentiality relationship runs first to the client or employer”.

Thus, Lisa cannot guarantee full confidentiality but may state she will do her best.

The Financial Action Task Force (FATF) Recommendations, as cited in the Fraud Examiners Manual, require enhanced due diligence in correspondent banking relationships. Specifically, banks must “avoid correspondent banking with shell banks” and ensure the foreign institution is properly licensed and regulated.

This means financial institutions must confirm that the foreign correspondent bank holds the necessary licenses or certifications to operate legitimately.

Other options (branch addresses, tax statements, or client loan profiles) are not mandated under FATF’s correspondent banking due diligence requirements. The most critical factor is verifying the correspondent institution’s legal authorization (licenses/certifications) to prevent money laundering and terrorist financing.

“The interviewer generally should indicate his name and company, but he should avoid stating his title. In general, the more informal the interview, the more relaxed the respondent”.

Introducing oneself only by name and company (not title like CFE or auditor) avoids intimidation and builds cooperation.

The Fraud Examiners Manual notes that EU privacy laws (e.g., EU Data Protection Directive, precursor to GDPR) restrict or prohibit the transfer of personal data to non-EU countries without compliance:

“Many foreign countries—and those in the European Union (EU) in particular—restrict or prohibit processing and transferring personal data… The EU’s directive… places limits on transmitting personal data to non-EU countries”.

Thus, since the fraud examiner is handling data about an EU-based employee, GDPR compliance is required, even if the examiner is outside the EU.