DEALING WITH WHITE COLLAR CRIME

THE CRIME RESPONSE PLAN

Any prudent organization will plan its response to white collar crime so that when it strikes, it can be dealt with in an organised and efficient manner. Key decision makers should have no doubts about what needs to be done, and what the likely effect of their decisions will be. As white collar crime frequently involves the swift movement of money, the need for quick decisions and action is a vital ingredient of the plan.

Clearly any contingency plan must be consistent with the organization's policy. Although this document concentrates on the response to white collar crime, the plan could be written to encompass all serious crime.

Business Against Crime believes that the purpose of a crime response plan is to enable the organization to take prompt and effective action to:

1. put into place immediate and appropriate damage control measures;
2. investigate and secure the evidence so that any subsequent internal disciplinary or civil or criminal action in the courts will succeed;
3. minimise the risk of subsequent losses;
4. improve the chance and scale of recoveries;
5. reduce any adverse commercial effects;
6. make a clear statement that the organization is not a soft target for crime;
7. minimise negative or adverse publicity;
8. identify any lessons for the future in respect of improving the organisations' defence against white collar crime;
9. make recoveries from otherwise unattainable sources such as pension monies due to the perpetrator;
10. consider the insolvency alternative in order to take advantage of the insolvency investigation, interrogation and, other extra-ordinary powers granted to liquidators.

The plan will assist in demonstrating to staff, customers and the public that the organization remains in control of its affairs in a crisis situation.

We have already discussed various policy issues related to crime contingency planning in the section which deals with establishing policy for dealing with commercial crime. In this section we proceed on the assumption that the policy recommended by Business Against Crime has been agreed upon.

Any contingency plan will need to include details of:

• the immediate action on a crime being discovered or suspected;
• how and by whom the crime will be investigated within the organization;
• how and by whom the immediate subsequent action (in line with the organization's policy) will be handled;
• whether, and under what circumstances, contact should be made with the media;
• which sources of external assistance should be used.

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