Fraud Prevention and Transparency

Because the revenues that can be generated from oil and gas extraction are very significant, this sector has been a frequent target of fraud and corruption in many jurisdictions, especially in developing countries. Rigged lease auctions, diversion of the resource before production measurement points, false production declaration, and misappropriation of revenues are some of the most common frauds observed in the sector.

It has been shown that transparency is the primary means of reducing fraud and corruption in the resource sector. For this reason, international initiatives have been undertaken to increase transparency (for example, the Extractive Industries Transparency Initiative). In many countries, new laws and regulations require leaseholders to disclose all their payments (above a defined threshold) to government. Where such provisions exist, auditors can look at compliance with the applicable requirements and assess whether transparency is sufficient. Auditors can also look at other systems and practices intended to reduce the incidence of fraud and corruption, including codes of ethics and policies on conflicts of interest.

Table 8 includes examples of knowledge of business questions about fraud prevention and transparency that auditors can ask during the planning phase. Examples of related audit objectives and criteria are provided in later sections of the Practice Guide.

Table 8 – Fraud Prevention and Transparency: Examples of Knowledge Business Questions

Once auditors have obtained answers to their knowledge of business questions, they can better assess the risks related to fraud and transparency.

Auditors should consider including fraud prevention and/or transparency in their audit plan if their preliminary audit work indicates the following:

• Responsible organizations have not assessed the risk of fraud in relation to the collection of oil and gas revenues.
• Responsible organizations have failed to adopt basic policies on ethics and independence.
• Responsibilities for assessing royalties and collecting payments have not been segregated, creating a risk of fraud with regard to the collection of royalties.
• A government has committed to publish the payments it receives from oil and gas companies but has taken no concrete steps to make this happen.
• Legislation requiring a government to publish the payments it receives from oil and gas companies is not being complied with.
• Potential conflicts of interest or inappropriate relationships amongst key decision makers.

This list of potential audit issues is indicative, not exhaustive. It is the responsibility of audit teams to review and analyze the information they collect in the planning phase in order to identify and assess significant risk areas. Only after conducting this work will auditors be able to decide whether to include fraud prevention and transparency in their audit plan.

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