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// Fraud scheme

Conflict of interest — purchasing

An employee with an undisclosed financial or personal interest in a vendor uses their position to benefit that vendor: steering awards, approving inflated or unneeded purchases, or avoiding competitive procurement.

Partly covered. The remaining analysis is planned.

Starter pack: Disbursement review, Procurement integrity

Red flags

In the data

  • Vendor shares an address, phone, email, bank account, or TIN with an employee
  • One buyer or approver accounts for most activity with a vendor
  • Sole-source awards and awards just under bid thresholds
  • Requester is also the approver, or approver acts above their limit

Behavioral

  • Employee resists rotation of vendor responsibility
  • Employee has social ties to the vendor's owners
  • Conflict-of-interest disclosure not filed or incomplete

Internal controls

  • No annual conflict-of-interest disclosure or no review of disclosures
  • Vendor ownership not collected at setup
  • Sole-source justifications not reviewed independently
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