Fraud/White Collar Crime

 

 

https://sm.asisonline.org/Pages/Wells-Fargo-To-Pay-$110-Million-To-Settle-Class-Action-Lawsuits.aspxWells Fargo To Pay $110 Million To Settle Class Action LawsuitsGP0|#28ae3eb9-d865-484b-ac9f-3dfacb4ce997;L0|#028ae3eb9-d865-484b-ac9f-3dfacb4ce997|Strategic Security;GTSet|#8accba12-4830-47cd-9299-2b34a43444652017-03-29T04:00:00Zhttps://adminsm.asisonline.org/pages/megan-gates.aspx, Megan Gates<p>​Wells Fargo & Co. will pay $110 million to settle several class action lawsuits brought in the wake of its mass unauthorized account scam, it announced in a <a href="https://www.wellsfargo.com/about/press/2017/class-action_0328.content" target="_blank">statement. </a></p><p>“This agreement is another step in our journey to make things right with customers and rebuild trust,” said Wells Fargo CEO Tim Sloan in a statement. “We want to ensure that each customer impacted by our sales practices issue has every opportunity for remediation, and this agreement presents an additional option.”<br></p><p>A dozen class action lawsuits were filed against Wells Fargo after it was disclosed in 2016 that employees at the financial institution created almost 2 million unauthorized customer accounts to generate millions in fees that profited the company. <br></p><p>The $110 million will be set aside for customer remediation, and will be used to pay customers for out-of-pocket losses, such as fees incurred due to unauthorized account openings, as well as for attorneys’ fees and administrative costs. <br></p><p>“The settlement class will consist of all persons who claim that Wells Fargo opened an account in their name without consent, enrolled them in a product or service without consent, or submitted an application for a product or service in their name without consent during the period from January 1, 2009, through the date the Settlement Agreement is executed,” according to the Wells Fargo statement.<br></p><p>A court must still approve the settlement agreement before funds can be distributed. <br></p><p>This settlement is the second major settlement Wells Fargo has agreed to related to the scandal. In September 2016, the financial institution agreed to pay $190 million to settle claims brought by government agencies, including the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, and the city and county of Los Angeles, <a href="http://www.nationallawjournal.com/id=1202782282906?kw=Wells%20Fargo%20Strikes%20$110M%20Settlement%20Deal%20in%20Fake%20Accounts%20Cases&et=editorial&bu=National%20Law%20Journal&cn=20170329&src=EMC-Email&pt=Daily%20Headlines&slreturn=20170229140429" target="_blank">The National Law Journal reports. </a></p><p>“Only $5 million of the payment went to customers, who are the class members in the lawsuits against Wells Fargo,” according to the journal.</p><p>For more on the Wells Fargo scam and fraud trends at financial institutions, read <em>Security Management’s</em> March cover story <a href="/Pages/Teller-Trouble.aspx" target="_blank">"Teller Trouble."</a><a href="/Pages/Teller-Trouble.aspx">​</a></p>

Fraud/White Collar Crime

 

 

https://sm.asisonline.org/Pages/Wells-Fargo-To-Pay-$110-Million-To-Settle-Class-Action-Lawsuits.aspx2017-03-29T04:00:00ZWells Fargo To Pay $110 Million To Settle Class Action Lawsuits
https://sm.asisonline.org/Pages/Teller-Trouble.aspx2017-03-01T05:00:00ZTeller Trouble
https://sm.asisonline.org/Pages/Crime-of-Opportunity.aspx2016-12-01T05:00:00ZCrime of Opportunity
https://sm.asisonline.org/Pages/Playing-Clean.aspx2016-12-01T05:00:00ZPlaying Clean
https://sm.asisonline.org/Pages/Book-Review---Anti-Fraud-Program-Design.aspx2016-06-01T04:00:00ZBook Review: Anti-Fraud Program Design
https://sm.asisonline.org/Pages/Book-Review---Fraud-Identification-and-Prevention.aspx2016-06-01T04:00:00ZBook Review: Fraud Identification and Prevention
https://sm.asisonline.org/Pages/Upping-the-Ante-on-Corruption.aspx2016-03-01T05:00:00ZUpping the Ante on Corruption
https://sm.asisonline.org/Pages/Shrink-Expands.aspx2016-02-12T05:00:00ZShrink Expands
https://sm.asisonline.org/Pages/Defense-Corruption.aspx2016-02-03T05:00:00ZDefense Corruption
https://sm.asisonline.org/Pages/DOJ-to-Focus-on-Executives-in-Corporate-Investigations.aspx2015-09-10T04:00:00ZDOJ to Focus on Executives in Corporate Investigations
https://sm.asisonline.org/Pages/Book-Review---White-Collar-Crime.aspx2015-09-01T04:00:00ZBook Review: White Collar Crime
https://sm.asisonline.org/Pages/Fuga-de-Información-Médica.aspx2015-06-10T04:00:00ZFuga de Información Médica
https://sm.asisonline.org/Pages/Swiping-Medical-Data.aspx2015-06-01T04:00:00ZSwiping Medical Data
https://sm.asisonline.org/Pages/China-Tries-to-Cage-Corruption.aspx2015-04-01T04:00:00ZChina Tries to Cage Corruption
https://sm.asisonline.org/Pages/Passing-the-Biometrics-Test.aspx2015-03-01T05:00:00ZPassing the Biometrics Test
https://sm.asisonline.org/Pages/Fraud-Analytics-Strategies-.aspx2014-10-01T04:00:00ZFraud Analytics: Strategies and Methods for Detection and Prevention
https://sm.asisonline.org/Pages/Retail-Theft-Inc.aspx2014-10-01T04:00:00ZRetail Theft, Inc.
https://sm.asisonline.org/Pages/Financial-Fraud-In-.aspx2014-09-24T04:00:00ZFinancial Fraud in Lithuania
https://sm.asisonline.org/Pages/Crime-Blocking.aspx2014-09-01T04:00:00ZCrime Blocking
https://sm.asisonline.org/Pages/fincen-releases-culture-compliance-guidance-financial-institution-leaders-0013620.aspx2014-08-14T04:00:00ZFinCEN Releases 'Culture of Compliance' Guidance for Financial Institution Leaders

 You May Also Like...

 

 

https://sm.asisonline.org/Pages/Message-to-the-Masses.aspxMessage to the Masses<p>Sanofi is a global pharmaceuticals business that manufactures and distributes vaccines and medications worldwide. The organization provides diabetes solutions, consumer healthcare services, animal health products, and other therapies. Sanofi Pasteur, the vaccines division of Sanofi, provides more than 1 billion doses of vaccines each year, which immunize more than 500 million people across the globe.<img src="/ASIS%20SM%20Callout%20Images/0317%20Case%20Study%20Stats%20Sidebar.jpg" class="ms-rtePosition-2" alt="" style="margin:5px;width:296px;" /></p><p>With more than 100 locations in the United States, Sanofi has approximately 25,000 employees domestically, and a global workforce of more than 125,000. Keeping track of those workers and ensuring their safety is of utmost concern to the company, says Joe Blakeslee, security systems manager at Sanofi. </p><p>For its North American sector, the organization incorporates several solutions as part of its overall security profile, including access control, CCTV, and emergency notification. For many years, Sanofi had several mass notification platforms that were disparate, without a centralized way to manage alerts for all employees. </p><p>In late 2014, Sanofi put out a request for proposal to find a product that could unify its many mass notification platforms into one seamless solution. Near the beginning of 2015, it chose Everbridge Mass Notification, a Web-based application that allows for distribution of messages to a large audience. </p><p>“The biggest part about Everbridge that stood out was the user interface,” Blakeslee says. “It provided everything we needed, and we were also impressed with how easy the system was to use.” The Sanofi North America security team started rolling out the application at the beginning of 2015 for internal security purposes, and in June of that year began registering all North American employees into the system.</p><p>He adds that the variety of options for reaching employees was paramount, given Sanofi’s mobile workforce. “Everbridge has multiple modalities in which you can actually send the message,” he says. “We use all the modalities whether it’s cell phone, SMS, home phone, or email. We give all of our employees the ability to elect whatever modality they would like.” Employees rank their preferred communication modalities in order when registering for the system; that way, if one method fails to contact the worker, notifications will automatically be sent via other methods until the party is reached.  </p><p>Everbridge is used on a daily basis at Sanofi, he adds. “Every day we use the application to alert various groups within the company, whether it’s related to fire alarms, evacuations, hazmat response, or other incidents.” </p><p>Sanofi has a central security services center (SSC). There, analysts monitor the business locations across the country for alarms and alerts using various security management software. Only designated individuals within the SSC can access the Everbridge platform and administrate messages through the platform. When there is an incident, such as a fire alarm, analysts send out alerts to the affected employees to give them situational awareness through the Everbridge Web portal. In the fire example, employees would be alerted to evacuate the building and await further instruction. The messages being sent can be selected from a set of prewritten options, or modified based on the particular event; normally in an emergency, the messages are written at the time by the security team. </p><p>“Say you have a building with 3,000 people in it. We want to reach them wherever they may be,” he says, “and reach as many people as we can in as little amount of time as possible.” </p><p>The Everbridge application is used to notify workers that it is safe to return to their desks. It also displays in real-time the status of employees involved in the incident. Employee status can either be confirmed or unconfirmed. If someone is unconfirmed, the Everbridge system allows the SCC to resend the message or try a new contact path based on the order of the employee’s preferred contact methods to try to get a response. For example, if sending an SMS to a cell phone doesn’t work, the system will make a telephone call, then send an email, and so forth. The confirmation lets the security team determine which employees are safe. </p><p>The system helps get employees back to work more quickly, because people aren’t wondering whether it’s safe to return to their desks. </p><p>Everbridge can also be used for incident management. For example, in the case of a trespasser, security would get an alarm or a phone call. “From there, SSC would send out a notification from Everbridge to the local emergency response personnel, asking for them to respond to the occurrence,” Blakeslee says. “After the message is sent to all the recipients’ devices, the SSC would, in real time, monitor the responses from the recipients’ confirmations and determine how many people are responding to the event.” </p><p>Everbridge isn’t just used for reactionary purposes. It provides proactive security measures as well. Sanofi has security officers at each of its locations, and the organization conducts daily check-ins with those personnel who are patrolling alone to ensure they are safe and accounted for. Sanofi expects a message back, and “if they don’t respond, we escalate that to the SSC and they handle it from there,” Blakeslee says.  </p><p>He adds that the mobile nature of the modern workforce means that employees won’t always be working from their primary location. “Our workforce is dynamic. One day I may be working in Pennsylvania, the next day I might be in New Jersey,” he says, noting that several employees and contractors travel frequently. To help keep track of its mobile workforce, Sanofi rolled out a newer feature from Everbridge called Safety Connection in the second quarter of 2016. The solution aggregates geo-location data from multiple systems so Sanofi knows where its employees are at any given time.  </p><p>Blakeslee says that given the sensitivity of materials they manufacture and distribute, as well as the importance of their services to customers, the culture at Sanofi is safety oriented. “Anything dealing with safety we’re really reactive to, so Everbridge provides us another means of communicating to keep our employees safe.”</p><p>--<br></p><p>For more information: Jeff Benanto, jeff.benanto@everbridge.com, www.everbridge.com, 781.373.9879 ​</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://sm.asisonline.org/Pages/Tracking-Performance-Trends.aspxTracking Performance Trends<p>​</p><div>On December 24, 2003, a woman broke into an exhibit case in Kentucky’s Owensboro Medical Health System and stole a case of 50 antique glass eyes. The theft was an unwelcome Christmas present that could’ve been a black eye for the hospital, but fortunately, the security team had the right detection measures in place. The woman, who had the unlikely but appropriate name of Wink, was recorded stealing the goods by the hospital’s CCTV cameras and was quickly caught.</div><div><br> </div><div>Apprehensions are one mark of the security department’s effectiveness. But the security department at the Owensboro Medical Center—which has some 447 beds and which handled more than 60,000 emergency-room visits last year—wanted a more comprehensive way to measure its performance on a day-to-day basis. It chose as its metric average hours per incident.</div><div><br> </div><div>Selecting an indictor. In developing a system for looking at how well security resources are deployed and how effective they are, the first challenge was identifying what exactly should be monitored. While security incidents are easy to count, we wanted to go beyond whether incidents were trending up or down. We also wanted to go beyond simply looking at whether costs per square feet were up or down.</div><div><br> </div><div>The goal was to select and define an indicator that could be used to measure the level of security and the effectiveness of preventive activities. The indicator chosen was time per incident.</div><div><br> </div><div>The first step was to quantify the time devoted to each reported incident as a way to establish a baseline for security coverage. As the security supervisor, I planned to correlate each new measurement against this baseline as a workable measure of security performance.</div><div><br> </div><div>Measurement components. There are two components of the performance measurement. First is the hours devoted to security. This factor only includes regular and overtime hours that the security staff is actually working—it doesn’t include any other hours, such as vacation or sick time.</div><div><br> </div><div>Second are the incidents and activities themselves. In a healthcare setting, incidents might include disturbances caused by visitors or patients, medical detentions, or safety-related occurrences such as fire drills. A comprehensive risk assessment will help define the types of incidents a facility will need to track.</div><div><br> </div><div>Activities may encompass routine duties that security staff carry out, such as patrolling the grounds, escorting visitors, or bringing articles to or from the safe. All of these specific incident responses and routine activities are collectively called incidents for simplicity sake throughout this article.</div><div><br> </div><div>To determine a measure of performance, the total number of security hours was correlated to the number of incidents to provide a ratio of hours to the total number of tasks completed. This is not a measure of the amount of time devoted to each security assignment—which can range from a few minutes for a safe run to a full shift for an officer sitting with a detained patient—rather, it is a global statistical ratio of total hours worked to total security actions handled.</div><div><br> </div><div>Graphing results. By graphing this relationship of total hours to total incidents each month, we developed a curve that represented a level of performance for the facility. While I can't go into the specifics from my own organization for confidentiality reasons, the point is illustrated with two years of hypothetical numbers. </div><div><br> </div><div>Year 1 (see chart) shows typical statistics for a facility with a security staff of about 10 full-time officers with a representative number of incidents recorded each month during the year. You can see that towards the end of the year there is an alarming downward trend in the curve; that is, there were fewer hours spent on each incident. </div><div><br> </div><div>There were several possible explanations for this. For example, the fictional organization might have been expanding, such as by adding a new medical office building. As a result, officers would have had more areas to patrol.</div><div><br> </div><div>Perhaps the hours of outpatient services were extended as well, meaning that there were more people in the building than in earlier months. Since the number of security officers remained the same despite the larger facility and the extended hours, there would have been more incidents to respond to within the same time frame, thus causing the downward trend.</div><div><br> </div><div>Benchmark. At Owensboro, we chose a baseline of 12 hours per incident. Because the system was still under development, this number was chosen provisionally after reviewing the existing data. It served as a benchmark against which future data could be analyzed.</div><div><br> </div><div>If this number proved to be off the mark as a reasonable baseline, we could adjust it later. But as long as it was the baseline, the goal would be to track trends against this number, and where the results rose or fell, to find out why and to take steps to reallocate resources so that the average hours per incident would stay in the range of 12.</div><div><br> </div><div>If the number of hours per incident rose, that might indicate that we had a reduction in the number of incidents. Alternatively, it might simply be because more hours were available thanks to overtime or fewer sick days. We analyzed the data each month to determine the underlying cause of the shift and to put the findings into proper context for our own use and for management.</div><div><br> </div><div>When hours per incident are up, the security department can reallocate resources to improve overall performance. For example, security officers could be directed to devote more time to making rounds, thus providing a more visible presence to deter crime. Additionally, they could be more available to defuse potentially volatile situations before they could escalate, and to work closely with the public, patients, families, and visitors to increase customer satisfaction by attending to their needs, such as escorting visitors or staff to parking areas.</div><div><br> </div><div>Conversely, if security hours decrease or incidents increase, the number of hours per incident will decline, as happens in the example chart. By examining the underlying data about incidents and staff time, the security department can assess the cause and take corrective action or use the numbers to justify a request for more staff.</div><div><br> </div><div>In our case, we were expanding the facility, and our analysis showed that the addition of one-half full-time employee (FTE) to patrol the added space would bring our hours per incident back into compliance. This calculation showed a whole FTE was not necessary, particularly when an adjustment in fixed factors was made, such as a revision of lockdown procedures and the installation of new cameras and signage in the new medical office building. Not having to hire a full FTE would save the department money, but because the metrics showed that we were maintaining our benchmark goal, we knew that we were not sacrificing the level of security in the process.</div><div><br> </div><div>It’s interesting to note that if we had used the more traditional indicators such as hours per square foot, we could have argued that the facility needed a whole FTE as opposed to one-half FTE. By using the performance measurement formula, and making improvements in fixed security factors, our goal was obtainable while still keeping within budget constraints.</div><div><br> </div><div>The increase in security coverage raised the curve back to the desired security level even though there were actually more incidents reported in some months. The Year 2 graph shows how implementing this type of improvement plan could affect the numbers.</div><div><br> </div><div>Working with this model over the past couple of years has helped us to establish the appropriate staffing levels for the area we presently cover. As we expand our medical office areas and build a new cancer treatment center, we will continually reevaluate our staffing requirements.</div><div><br> </div><div>PDCA. Creating a system to benchmark security performance was an important element, but it was only part of our overall solution. Our facility uses the Plan-Do-Check-Act (PDCA) cycle for performance improvement to comply with Joint Commission on Accreditation of Healthcare Organizations’ performance standards. Our PDCA performance improvement model was developed as follows.</div><div><br> </div><div>Plan. Our plan was to monitor the level of our security by trending the number of hours as a function of total security responses to determine a level of security performance, with a goal of maintaining an average of 12 hours per incident.</div><div><br> </div><div>Do. Officers fill out a security incident report for each security incident. This report describes the security incident, the actions taken by officers, and the results of that action. This security log is put in a box in the security office, and subsequent security shifts review it to see what’s going on in the facility.</div><div><br> </div><div>We expanded our camera system and redirected several cameras. We enhanced security by securing access to the building after hours, and we are reviewing our lockdown procedures as they apply to both staff and visitors. We are currently upgrading our badge-access entry points to the building to limit access to the building during off hours.</div><div><br> </div><div>We created a dedicated security office near the ER from which to centralize security operations. And a security officer now makes a proactive effort to reduce security incidents by making a presentation at new employee orientation about parking and personal security habits.</div><div><br> </div><div>Check. We checked our progress by using the security incident reports as source documents for reporting all incident statistics to the Environment of Care committee each month and at year-end. This information is graphed along with hourly payroll statistics to allow us to see our progress.</div><div><br> </div><div>Act. We acted on the results by changing coverage and modifying protocols as required to meet these issues. We adjusted our staffing levels to accommodate our new service offerings and expanded facilities.</div><div><br> </div><div>The final piece consisted of reporting our performance to the Environment of Care Committee and including the performance results in the annual security evaluation submitted to the hospital’s governing body each year.</div><div><br> </div><div>What’s ahead. Despite the benchmarking tool’s effectiveness so far, it’s still in its formative stages. One thing that has become clear is that not all incidents are the same, so there needs to be a way to weigh each one and to add those weighted values to the mix. This is an effort I am working on presently.</div><div><br> </div><div>For now the tool allows us to benchmark our security performance, and it gives us a way of communicating to management what level of security is being provided. It also provides a basis for funding requests in an era of increased competition for available resources.</div><div><br> </div><div>The net outcome is that we now have a much better confidence level in our security coverage because we have a simple method of visually presenting our level of security that management and security staff can identify with, and one that helps justify requests for security enhancements when new security challenges arise. </div><div><br> </div><div>Stephen Wall supervises security and communications at Owensboro Medical Health System in Owensboro, Kentucky, which services western Kentucky and southern Indiana. He has nine years of experience in coordinating environment-of-care issues for their facility.</div><div> </div>GP0|#28ae3eb9-d865-484b-ac9f-3dfacb4ce997;L0|#028ae3eb9-d865-484b-ac9f-3dfacb4ce997|Strategic Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://sm.asisonline.org/Pages/Book-Review---Security-Culture.aspxBook Review: Security Culture<p>​Routledge; Routledge.com; 232 pages; $119.95.</p><p>Building and maintaining a strong security culture is integral to any organization’s security and resiliency. <em>In Security Culture: A How-to Guide for Improving Security Culture and Dealing with People Risk in Your Organisation</em>, author Hilary Walton demonstrates how to establish a “culture within a culture” where security is everyone’s priority and part of their day-to-day professional life. </p><p> This is a book about assessing, implementing, and improving upon a security and risk management culture within an organization. The author successfully outlines the fundamentals of a comprehensive, pragmatic security culture campaign, citing her experience as an organizational psychologist and business consultant in the United Kingdom and Australasia. Six case studies of her suggestions in action add credibility, and three appendixes offer useful examples of proposal letters and a year-long security communications plan.</p><p> Though many of her suggestions focus on large enterprises, her recommendations are scalable for smaller ones. While most of the book focuses on cybersecurity issues, an experienced security manager will see applications for integrating the entire security operation, as well. </p><p> This book is appropriate for a wide range of practitioners, instructors, and consultants who want to establish and build upon a strong security culture within their organizations. </p><p>--<br></p><p><em><strong>Reviewer: Erik Antons CPP, PSP</strong>, is manager of international security and executive services for Sempra Energy and is a former special agent with the Diplomatic Security Service, U.S. Department of State. He is a member of the ASIS International Global Terrorism, Political Instability and International Crime Council and a board member for the ASIS San Diego Chapter.       </em></p>GP0|#28ae3eb9-d865-484b-ac9f-3dfacb4ce997;L0|#028ae3eb9-d865-484b-ac9f-3dfacb4ce997|Strategic Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465