Our thinking
What we think, and why.
Positions, not summaries. What our casework teaches us about governance, fraud and investigations, written for the boards, CFOs, general counsel and audit committees who have to act on it.
The governance lifecycle
From the boardroom to recovery
Our view on the questions Indian boards, CFOs, general counsel and audit committees put to us, arranged in the order a company meets them: setting expectations, preventing and detecting fraud, handling an allegation, and coming out of it stronger.
Stage 01
Tone at the top and board oversight
Why fraud happens in good companies too, and how what boards and audit committees set, tolerate and ask for shapes everything below them.
"Why Us?" The Psychology Behind Fraud, and Why It Is Not Just You
After a fraud, leaders ask why it happened to them. The candid answer: every company carries this risk, and the human psychology behind it can be managed.
5 min read
Tone at the Top Is What the Board Tolerates, Not What It Says
Codes of conduct do not set the tone. What the board pays for, approves as an exception and forgives does. How to test the culture you actually have.
6 min read
The Audit Committee's Fraud Agenda: Stop Receiving Reports and Start Testing Them
Most audit committees hear about fraud risk once a year in a slide. What an effective committee asks for, how often, and how it tests the answers.
5 min read
Stage 02
Prevention
Fraud risk assessment, process gaps and tight systems, third-party and related-party exposure, and ethics training that changes behaviour.
A Fraud Risk Assessment That Changes Nothing Has Not Been Done
Most fraud risk assessments are heat maps that change no budget, control or audit plan. How to run one that names schemes, owners and decisions.
5 min read
Fraud Lives in the Gaps Between Processes. Technology Can Close Many of Them
Most frauds exploit hand-offs, manual workarounds and data nobody connects. Where process gaps open, and how technology can close them without new blind spots.
5 min read
What "Tight Systems" Actually Means: Controls Built for the People Who Can Override Them
Every company says its systems are tight. What tight looks like in practice, process by process, and why it must be built for the people who can override it.
6 min read
Distributors, Agents and Vendors: You Have Outsourced the Work, Not the Risk
Much revenue and spend flows through third parties companies barely know. Why onboarding checks are not enough, and what ongoing oversight needs.
5 min read
Related-Party Risk Is a Conduct Problem, Not a Disclosure Problem
Approvals cover the related parties you know about. The damage comes from those you do not. How boards can find hidden connections and test pricing.
5 min read
Ethics Training Is the Most Underrated Control, Because Most Companies Run It Once
One induction module does not change behaviour. How to run ethics training as a programme: by role, refreshed, tested and built on real scenarios.
5 min read
Stage 03
Detection
An independent speak-up channel, awareness that keeps faith in it, analytics that test a hypothesis, and internal audit that looks for fraud on purpose.
Nobody Calls a Helpline Run by the People They Would Report
Helplines run by HR or the chairman's office earn little trust. Why speak-up channels must be independent, with real safety and confidentiality.
6 min read
A Helpline Without an Awareness Campaign Is Half a System
Companies set up helplines and never tell people what to report, how, or what happened last time. How to run awareness campaigns that keep faith in speaking up.
5 min read
Fraud Analytics Should Start With a Hypothesis, Not a Dashboard
Dashboards of red flags generate noise that nobody follows up. How to build analytics around specific schemes, and turn exceptions into findings.
5 min read
Internal Audit Should Look for Fraud, and Say So
Many internal audit functions test compliance and avoid the word fraud. Why audit committees should give internal audit an explicit fraud mandate.
5 min read
Stage 04
Response
The first days after an allegation, a credible investigation, auditors and regulators, and the people involved.
The First 72 Hours After an Allegation Decide Most of What Follows
Evidence lost, a suspect tipped off, a disclosure missed: most damage in a fraud matter is done in the first three days. What to decide, and when.
6 min read
A Credible Internal Investigation Is Built for the Forum It May End Up In
An investigation report is read by the board, then perhaps by auditors, regulators, a court or an arbitral tribunal. How to make one that survives all of them.
5 min read
When the Auditor Asks: Handling Section 143(12) and Regulators Without Losing Control of the Facts
A suspected fraud puts the auditor on a 45-day clock under s. 143(12). How boards should engage auditors and regulators: early, factually, in control.
5 min read
When the Suspect Resigns: Handling Employee Exits During an Investigation
Resignations, suspensions and quiet settlements during an investigation can cost evidence and recovery. What to decide before signing anything.
5 min read
Stage 05
Recovery and remediation
Choosing the legal route, getting money back, and changing the control environment so it does not happen again.
Getting the Money Back: Legal Routes to Recovery After Fraud, in India and Abroad
Promoters want their money back, fast. The legal routes in India and abroad, how to sequence them, the time limits, and why anger should not set the strategy.
7 min read
"The Employee Was Dishonest" Is Not a Root Cause
Most fraud matters close with a dismissal and a new control on the step that failed. How to find the real root cause and change the environment.
5 min read
From the articles
Practical guidance, organised by situation
Where our thinking takes a position, the articles show how to act on it. Start from where you are, follow a short reading path, or pick up the latest.
Start from your situation
- Suspect fraud nowA complaint, a tip-off or numbers that do not add up. What to do first.9 articles
- Board & audit committeeOversight duties, fraud risk frameworks and what regulators expect.7 articles
- Deals & due diligencePromoters, partners and targets: what the records will not volunteer.6 articles
- Disputes & insolvencyEvidence for courts and tribunals, avoidance transactions and recovery.7 articles
- Cyber & digitalOnline scams, account takeovers and the digital evidence behind them.6 articles
Reading paths · short series, read in order
- 01The first days of a suspected fraudFrom the first complaint to evidence that will stand up, without breaching privacy law on the way.
- 02An audit committee’s fraud toolkitThe framework, the vigil mechanism, when to call for a forensic audit and how data finds what sampling misses.
- 03Before you sign: deals and third partiesIntegrity checks on targets and partners, and the bribery laws that follow you into the deal.
- 04From red flag to recoveryFor lenders and resolution professionals: classification, avoidance transactions, wrongful trading and tracing assets.
Latest articles
Governance & controls7 min read · 11 Oct 2026
How to Build a Fraud Risk Management Framework: A Board-Level Guide
A fraud risk management framework is the governance structure that ties fraud risk assessment, prevention, detection, investigation and monitoring into one accountable programme.
Regulation6 min read · 8 Oct 2026
The DPDP Act 2023 and DPDP Rules 2025: What Changes for Workplace Investigations
The DPDP Act allows employers to process employee personal data without consent for employment purposes and to protect the business from loss or liability, under s. 7(i).
Anti-bribery & corruption6 min read · 5 Oct 2026
FCPA and UK Bribery Act: When Foreign Anti-Bribery Laws Reach Indian Companies
The FCPA can reach Indian companies that are US issuers, that act within US territory, or that act as agents or partners of US companies.
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