Governance · Risk · Compliance

The GCC Fraud Risk Checklist

15 critical vulnerabilities every company operating in the GCC should assess. Most are discovered after a loss — not before. Use this to find yours first.

of revenue lost
to fraud annually

$145K

median loss
per case

12 mo

median time before
fraud is detected

2×

longer detection
without controls

How to use this: Tick only what is genuinely in place — not what you plan to implement. Every unticked box is a live vulnerability. Count your ticks and use the scoring guide on page 2.

Internal Controls & Segregation of Duties

Financial approvals require more than one person — no single employee can both approve and process a payment. High Risk

New vendor additions are reviewed and approved by someone independent of the person requesting the vendor.

Employee system access is restricted to what their role requires — nobody has access beyond their job function.

Access permissions are reviewed and updated when an employee changes role or leaves. High Risk

Bank reconciliations are performed by someone independent of the person who processes transactions.

Procurement & Vendor Management

Vendor legitimacy is verified before the first payment — registration, ownership, and contact details independently confirmed. High Risk

Vendor invoices are matched against purchase orders and delivery receipts before payment is released.

Controls are in place to detect and prevent duplicate invoice payments.

There is a process to identify phantom or shell vendors billing without delivering goods or services.

Third-Party Relationships & Business Partners

Background checks are conducted on new business partners before any agreement is signed or funds committed. High Risk

Beneficial ownership of partner companies is verified — you know who ultimately owns and controls the entities you work with.

A fraud risk assessment is completed before major investments, joint ventures, or significant new business relationships.

Monitoring, Detection & Reporting

Transaction monitoring flags unusual patterns — large payments, round-number transactions, payments to new accounts. High Risk

A confidential reporting mechanism exists for employees to raise concerns about suspected fraud or misconduct.

There is a documented process for investigating fraud allegations — including evidence handling and escalation protocols.

Score Your Results

12–15

Strong Controls

Fundamentals are in place. Review unticked items — even one gap in a High Risk category creates real exposure.

8–11

Moderate Risk

Some controls in place but significant gaps exist. Prioritise High Risk items first — these are the entry points.

0–7

High Exposure

Your business lacks the controls that prevent fraud. Losses may already be occurring. Immediate action is warranted.

Red Flags That Demand Immediate Attention

One person controls both approval and payment processing with no oversight

A vendor relationship managed entirely by a single employee with no checks

No independent verification of business partners before agreements are signed

Employees retain system access after changing roles or leaving the company

An investment opportunity came through personal introduction with no due diligence

No documented process for raising or investigating fraud concerns internally

Bank reconciliations performed by the same person who processes transactions

Invoices paid without matching against purchase orders or delivery receipts

Gaps Found? Here Is What to Do Next.

Most vulnerabilities on this checklist are not complicated to fix — but they need to be addressed systematically, not one at a time. A single open gap is enough. Goodwork helps companies operating in the GCC build the fraud prevention frameworks, internal controls, and due diligence processes that close these gaps before they become losses. All initial consultations are confidential.

goodwork.ae UAE: +971 56 611 6767 KSA: +966 56 093 6826

About this checklist: Developed by Goodwork LLC based on 16+ years of fraud risk advisory across GCC markets, aligned with ACFE (Association of Certified Fraud Examiners) global standards and regional legal intelligence from UAE, KSA, and Qatar. This is a diagnostic tool — not a formal fraud risk assessment. A comprehensive assessment requires detailed review of your specific operations, controls, and risk environment. © Goodwork LLC 2025.