Fin Maverick
Foundations VocabularyAccounting & ReportingEconomics & MacroQuant Methods & ProgrammingBusiness & Company AnalysisCorporate Finance & ValuationBehavioural Finance
Banking & Market InfrastructureFixed Income & RatesDerivatives & Structured ProductsPublic EquitiesTransactions & DealsPortfolio ConstructionFunds & AMCs
Private Markets & AlternativesRisk, Treasury & ControlAI & Digital FinanceStochastic Calculus & PricingWealth & Personal FinanceIndian Markets & RegulationProfessional Practice
CalculatorComparison
Frameworks
Explore Bootcamps
Equity ResearchPortfolio ManagementMutual Fund MasteryFinancial LiteracyInvestment Banking Analyst
Private Equity AnalystHedge Funds AnalystBreaking Into VCBreaking Into QuantsAI For Finance
Financial Analyst ProgramRisk Management ProgramPrivate Wealth ManagementDebt Capital MarketsDerivatives Foundation
Explore Internships
Equity Research InternMutual Fund Intern
Portfolio Management InternFinancial Literacy Intern
Explore Micro Courses

Equity Research6

Writing an Investment ThesisBuilding a Discounted Cash FlowReading an Annual Report FastReading a Sector Before a CompanySpotting Quality of Earnings Red FlagsBuilding a Revenue Forecast From Drivers

Portfolio Management3

Rebalancing: When, Why and What It CostsStrategic and Tactical Asset AllocationMeasuring Risk in a Portfolio

Mutual Fund Mastery3

Comparing Funds Without Being FooledHow a NAV Is Struck and Which Day You GetReading a Fund Factsheet Properly

Derivatives Unlocked4

Hedging a Real ExposureThe Greeks, PracticallyFutures, the Basis and What Moves ItReading an Option Payoff

AI For Finance2

Retrieval and Grounding for FinanceDocument Extraction in Finance

Breaking Into Quants4

Backtesting a StrategyHypothesis TestingCleaning Financial DataRegression for Finance

Breaking Into VC3

Sizing a MarketReading a Term Sheet as a FounderHow a Venture Round Actually Works

Financial Analyst Program4

Common Size and Trend AnalysisReading a Cash Flow StatementRatio Analysis That Says SomethingBuilding a Working Capital Schedule

Risk Management Program2

Credit Exposure and How It Is ReducedValue at Risk and What It Hides

Investment Banking Analyst3

Precedent Transactions and Why They DifferReading a Term Sheet StructurallyBuilding a Comparable Companies Table

Private Wealth Management3

Tax Aware Portfolio DecisionsBuilding a Client Risk ProfileGoal Based Planning Arithmetic

Debt Capital Markets3

Analysing an Issuer's CreditDuration and What It Does Not Tell YouBond Pricing and Yield Mechanics

Private Equity Analyst2

Fund Waterfalls and CarryThe LBO in Structure

Hedge Funds Analyst2

Short Selling MechanicsLong Short Mechanics
Courses
Explore Career Roadmaps
Investment Banking AnalystEquity Research AnalystVC AnalystPrivate Equity AnalystHedge Funds Analyst
Quant AnalystAI For FinanceFinancial Analyst ProgramPrivate Wealth ManagementDebt Capital Markets
Risk Management ProgramDerivatives FoundationPortfolio ManagementMutual Fund Mastery
PartnershipsShowdown
Log inSign up
Risk, Treasury & Financial Control
1Risk Foundations
Risk Appetite, Tolerance, Capacity…The Risk Taxonomy and UniverseRisk Register vs Risk MatrixStress TestingScenario Analysis vs Stress TestingImpact and LikelihoodLikelihoodThe Risk EventRisk Assessment
2Enterprise Risk Management
Enterprise Risk ManagementThe Four Risk TreatmentsRisk CultureRisk MaturityRisk Monitoring
3Risk Governance
Risk GovernanceHow to set a…The Risk PolicyThe Risk OwnerThe Risk Committee and Its CharterThe Risk Limit FrameworkRisk EscalationHow to set a…
4Credit and Counterparty Risk
Collateral AgreementsCollateral vs NettingProbability of DefaultExposureCounterparty ExposureConcentration Risk vs Wrong Way RiskCounterparty Risk vs Credit RiskHow to assess Counterparty ExposureHow to assess Concentration Risk
5Market Risk
Market RiskSensitivity MeasuresThe Hedging PolicyInterest Rate Risk in the Banking BookIRRBB vs Market RiskExpected ShortfallEconomic Value of EquityVaR BacktestingOpen PositionValue at RiskValue at Risk and Expected ShortfallEconomic Value SensitivityFX ExposureValue at Risk vs Expected ShortfallEarnings at Risk vs…FX Transaction Risk vs…How to measure Interest…How to measure Foreign…
6Liquidity Risk
Liquidity Stress TestingLiquidity Gap vs Liquidity BufferMaturity MismatchThe Debt Maturity ProfileFunding ConcentrationSurvival HorizonThe Contingency Funding PlanNet Stable Funding RatioLiquidity Risk vs Funding RiskLiquidity Coverage RatioLiquidity Gap and BufferHow to run a Liquidity Gap Analysis
7Operational Risk
Operational LossThe Loss EventRisk and Control Self AssessmentException ManagementInformation Security as a…Segregation of DutiesIssue ManagementThe Near MissRoot Cause Analysis in RiskThe Fraud TriangleCyber Risk vs Third Party RiskHow to run a…How to assess Third…
8Risk Reporting, Data and Model Risk
Model RiskModel Validation vs BacktestingHow to run Model ValidationData Governance in RiskModel Risk vs Data RiskKey Risk IndicatorsManagement InformationRisk ReportingRisk ScoreEarnings at RiskRisk Adjusted ReturnEarly Warning IndicatorsHow to build a KRI Dashboard
9Treasury
Corporate TreasuryAsset Liability ManagementIntragroup FundingThe Treasury PolicyThe Treasury Management SystemThe Cash ForecastCash Pooling and ConcentrationHow to build a Cash Forecast
10Financial Controls and Assurance
Control AssuranceThe Control LifecycleThe Assurance MapThe Audit FindingIssue RemediationInternal Financial ControlsControl Design vs Control EffectivenessHow to map Internal Financial ControlsHow to test Control…Control DeficiencyMaterial Weakness
11Operational Resilience
Operational ResilienceBusiness Continuity and Disaster RecoveryBusiness Continuity vs Operational…Crisis ManagementDisaster RecoveryIncident Management

The Fraud Triangle: Pressure, Opportunity and Rationalisation

Donald Cressey set out the fraud triangle in Other People's Money in 1953: pressure, opportunity and rationalisation, all three of which he found present where a trusted person took what was not theirs. The teaching point here is the split. Two of the three are facts about a person and one is a fact about a control, and an institution can only build against the one.

Most explanatory frames in risk work are comfortable to use because they ask nothing of the person using them. Cressey's frame is different, and the discomfort is where its value sits. The fraud triangleDonald Cressey's 1953 account of what he found present where a trusted person took what was not theirs: pressure, opportunity and rationalisation. is a three part account of what was present when somebody trusted did something they should not have done, and understanding it properly means understanding that two of its three parts are none of an institution's business. Leaving those two parts alone is not a defect in the frame. The frame is doing its job, and the job is to show where effort should be spent and, just as importantly, where it should not.

Vindhya Commercial Bank Limited, an invented bank, carries a twelve month record of operational incidents, and one event inside that record carries the whole argument. Investigation, discipline, employment consequences, reporting to any authority and recovery action against any individual are covered separately. The question is a design question, not a question about a person.

Where does the fraud triangle come from, and what was it built to explain?

The frame is not general knowledge and it has an author. Donald Cressey set it out in Other People's Money in 1953. Cressey was answering a narrow question, and forgetting exactly what the question was is where a great deal of loose use of the triangle begins. He was not asking what makes people dishonest. He was looking at people who had held a position of trust in good faith, who had then violated that trust, and he was asking what circumstances were present in the cases where that happened. The answer he arrived at has three parts that appear together: a problem the person felt unable to share, a belief that the position could be used to solve it without being seen, and an account the person could give themselves that made the act something other than what it was.

Notice the shape of that. Cressey's answer is an account of circumstances that were present, arrived at after the events, from people the events had already happened to. The account is not a forward-looking test, and Cressey did not offer it as one. The triangle is an explanation and never a prediction, and almost every misuse of it in practice comes from treating a description of what was present as a list of things to go looking for in people.

The same shape appears outside banking. A housing society collects maintenance money, and one person holds the book, writes the receipts, banks the cash and reconciles the account. There are forty flats and nobody wants the job. If money goes missing there, the three parts are easy to see afterwards: whatever private difficulty the person was in, the fact that one pair of hands did every step so nothing ever had to agree with anything else, and whatever the person told themselves about paying it back next month. Asked what it should do about that, a society's useful answer is never about the person. The answer is that one pair of hands should not do every step. A bank is the same arrangement at a larger scale, with the duties written down instead of assumed.

One term matters before going further. A trusted positionA role whose duties give access that the control environment assumes will not be misused, which is what makes the arrangement of duties decisive. is a role whose duties give access that the control environment simply assumes will not be misused. Every institution has many of them and it could not function otherwise. Trust is always being extended, so the interesting question is never whether it is. The question is which extra assumption sits on top of the trust in the way the duties are arranged, and whether anybody ever wrote that assumption down and looked at it.

Try it out

Who set out the fraud triangle, in what work, and in what year?

Derivatives Foundation Bootcamp — Fin Maverick

What are the three legs, and what does each one actually mean?

The three legs are usually recited as three words, and the recitation is where the meaning gets lost. Each one has a qualifier inside it that does the actual work, and dropping the qualifier turns a precise idea into a vague one.

Pressure, and why the sharing part is the operative half

PressureA problem the person feels unable to share, which is what makes it operative rather than merely a difficulty. is not difficulty. Almost everybody carries difficulty, continuously, and almost nobody does anything wrong about it. Cressey described something narrower, and the qualifier is the whole point: a problem the person feels unable to share. The sharing is the operative half. A person with a large debt who can talk to somebody about it has a problem. A person with a large debt who believes that telling anybody would end their standing, their job or their marriage has something structurally different. Every ordinary route out of the problem has been closed off in their own mind before anybody else has even heard of it.

The qualifier is also exactly what makes the leg invisible. A non-shareable problem is, by construction, one nobody has been told about. An institution cannot observe pressure without inspecting the private circumstances of the people who work for it, and the moment it starts doing that it has taken on a cost and an intrusion in exchange for a signal that will not work. The practice of inspecting private circumstances is refused outright.

Opportunity, and why it is a fact about arrangements

OpportunityThe belief that the act can be done and not be seen, which is a fact about how the work is arranged rather than about the person. is the belief that the act can be done without being seen. Read that carefully too. The sentence describes how work has been arranged and not a person's character. If one role can both check something and release it, then the person holding that role has that opportunity, and so does every person who has ever held it and every person who ever will. Move the role to somebody else and the opportunity moves with the role, unchanged.

The portability of the opportunity is why this leg behaves completely differently from the other two. Opportunity is written down, usually in a procedure or a system entitlement. Opportunity can be listed. Opportunity can be tested. Opportunity can be changed this week by somebody with the authority to change a procedure. Opportunity is the only one of the three legs that exists as a property of the institution rather than a property of a person, and that single fact is what makes the frame useful instead of merely interesting.

Rationalisation, and why it usually has some truth in it

RationalisationThe account the person gives themselves for why it is not really what it is, which is usually partly true at the start. is the account the person gives themselves for why the act is not really what it is. The common picture of this is a flimsy excuse, and that picture is wrong in a way that matters. The accounts that actually sustain a long-running act are usually partly true when they start. Borrowing rather than taking, with repayment intended. Being owed it, after something that genuinely happened. Nobody being harmed, with the money coming back anyway.

An account that is partly true is durable in a way an invented one is not, and it has a second property that is worse. The account can stop being true without anything announcing the change. Nobody sends a notice on the day the repayment stops being realistic or the day the goods stop existing. The account carries on being used long after the fact that supported it has gone, and the person using it has no particular moment at which they were asked to notice. The dangerous rationalisation is not the absurd one, it is the one that was accurate at the start and quietly stopped being accurate while it was still in use.

CRESSEY'S THREE LEGS, AND THE TWO TO ONE SPLIT INSIDE THEM Donald Cressey, Other People's Money, 1953. Drawn as an explanation of what was present, never as a test applied to anybody. A FACT ABOUT A PERSON A FACT ABOUT A CONTROL ALL THREE PRESENT TOGETHER Cressey's account, arrived at after the event and never a test applied to a person 1 2 3 PRESSURE a problem the person cannot share OPPORTUNITY a fact about how the work is arranged RATIONALISATION the account the person gives themselves TWO LEGS ARE FACTS ABOUT A PERSON AND ONE IS A FACT ABOUT A CONTROL an institution can build against leg 2 alone, which is where all of its effort belongs
Cressey's three legs divide two to one, and that division is the entire practical content of the frame.
Debt Capital Markets Bootcamp — Fin Maverick

Which of the three can an institution do anything about?

Put the three legs side by side and ask two questions of each, in this order. Can the institution see it? And if it can see it, can it change it? The answers do not come out three ways. The answers come out one way once and the other way twice, and that asymmetry is the finding.

Pressure fails the first question. A non-shareable problem is invisible by construction, and the only route to seeing it runs through the private circumstances of a member of staff. Rationalisation fails the first question too, and fails it harder. A rationalisation has no existence in the world at all until somebody has already begun using it. Neither leg reaches the second question at all. There is nothing an institution could act on even if it somehow saw it, and against what, exactly, would the action be taken?

Opportunity answers both. Opportunity can be seen. A procedure and a set of system entitlements are documents, and the opportunity is written into both. Opportunity can be changed. A procedure is a decision somebody made, and it can be made again differently. The two to one split converts a three part explanation into a one part instruction, and that conversion is the reason for using the frame at all.

There is a second reason to like the instruction, and it has nothing to do with efficiency. Acting on opportunity changes the role, so it treats everybody in that role identically. Acting on pressure treats people differently on the basis of guesses about their private lives. One of those is a control and the other is a judgement about individuals dressed up as a control, and an institution that cannot tell them apart will eventually do the second while believing it is doing the first.

TWO QUESTIONS ASKED OF EACH LEG, AND THE ANSWERS COME OUT ONE TO TWO Can the institution see it, and if it can, can the institution change it? LEG WHAT IT IS, IN ONE LINE OBSERVABLE? CHANGEABLE BY DESIGN? PRESSURE about a person a problem the person feels unable to share NO and it should not be tried NO nothing to act on OPPORTUNITY about a control the belief that the act can be done and not be seen YES it is written down YES this week, by procedure RATIONALISATION about a person the account the person gives themselves for the act NO not until afterwards NO nothing to act on One row of three answers yes twice, and it is the row that is a property of the institution rather than of a person.
Only the opportunity leg answers both tests, so a three part frame produces exactly one instruction.
Try it out

Which of the three legs can an institution actually build against, and why only that one?

What does the triangle look like on a real internal fraud?

The bank's twelve month record carries thirteen operational incidents numbered I1 to I13, and two of them sit in the first of the seven event categories, internal fraudOne of the seven event categories, covering acts intended to defraud involving at least one internal party., covering acts intended to defraud involving at least one internal party. The larger of the two is incident I13, and it is the largest net loss in the whole year.

The facts of it, as the record holds them, are these. A trade finance officer and an external party issued 9 letters of credit against forged shipping documents, over fourteen months ending in month 8. The scheme was discovered when a beneficiary bank claimed. Letters of credit, and how they pay, belong to another subject area entirely. Here they are simply the instruments that were issued.

Incident I13, category 1, internal fraudFigure
Gross loss, what left the bankRs 22.4 crore
Recovery, what came backRs 7.0 crore
Net loss, what the event costRs 15.4 crore
Recovery rate on this incident, 7.0 over 22.431.3 per cent
Share of the year's Rs 43.8 crore of net loss35.2 per cent
Share of the year by count, 1 of 13 incidents7.7 per cent
Instruments issued9 letters of credit
Running time before it was foundfourteen months

Every figure belongs to one invented bank. Rs 15.4 crore here is the net loss of incident I13 and is a different object from the Rs 15.6 crore value at risk figure that appears elsewhere in this same invented case, so the meaning is attached to the figure every time it is used.

Now Cressey's three legs, in the order he set them out in Other People's Money in 1953. Each leg lands on this event as a specific, checkable finding, and exactly one of the three findings produces an action.

THE THREE LEGS ON INCIDENT I13 AT VINDHYA COMMERCIAL BANK LIMITED, INVENTED Net loss Rs 15.4 crore over fourteen months. Three findings, and only the middle one is something the bank could have designed. PRESSURE a fact about a person The officer carried a personal borrowing the bank knew nothing about, and there was nothing it could properly have done to know. NOT A DESIGN QUESTION nothing to build against OPPORTUNITY a fact about a control The same person could both check the shipping documents and release the instrument. That is a segregation of duties failure. THE ONE DESIGN QUESTION the only leg to build against RATIONALISATION a fact about a person The bank was going to be paid anyway because the goods existed, which the record states was true for eleven of the fourteen months. NOT A DESIGN QUESTION nothing to build against
The three legs land on a real event as three specific findings, only one of which is a design question.

The pressure leg on incident I13

The record states that the officer carried a personal borrowing the bank knew nothing about. The borrowing is the classic form of the leg: a private financial obligation that has not been shared. The second half of that sentence is doing more work than it looks. The bank knew nothing about it, and there was nothing it could properly have done to know. A borrowing taken privately is a private matter, and a bank that set out to enumerate the private borrowings of its trade finance staff would be doing something it has no business doing and would still miss most of them.

So the honest finding on the pressure leg is that it explains and produces nothing to act on, and any account pretending otherwise would be inventing a control that cannot exist. None of that is a failure of the analysis. The analysis is instead showing that there is nothing further to look for here.

The opportunity leg on incident I13

Here the record is precise, and the precision is what makes the leg useful. The same person could both check the shipping documents and release the instrument. Read that as a sentence about a job description rather than about a person. A job description is exactly what it is. One role held two duties that should not sit together, and the consequence is that a document set never had to satisfy anybody except the person presenting it.

The consequences of that arrangement matter. The finding would have been exactly as true if somebody else had held that job. The two duties sat together before this officer joined the role, and they stayed together until the arrangement changed. The pairing is also written down, in a procedure and in a system entitlement, and could have been read off that record by anybody who went looking. Segregation of duties as a control, meaning which pairs of duties are incompatible, what separating them costs and where separation is impossible, is set out under segregation of duties. The opportunity leg turned out to be a design finding, and the design finding is the only one of the three that came with an action attached.

Try it out

In this event the opportunity was that one officer could both check the documents and release the instrument. What kind of finding is that?

The rationalisation leg on incident I13

The goods existed, so the account the officer could give themselves was that the bank was going to be paid anyway. And here the record does something unusually useful: it states how long that was true. The account was true for eleven of the fourteen months, or 78.6 per cent of the run.

The eleven months are the most instructive number in the case, and the number is not a money figure. For most of the time this went on, the account the person was giving themselves was not a lie. The account was a description of the situation. The account only became false somewhere in the last stretch, and nothing about that stretch looked different from the inside. A rationalisation that is true when it starts does not have to be believed against the evidence, it only has to be left unrevisited, and the record shows this one holding for more than three quarters of the run.

One caution about how the figure below is drawn, and it matters. The record states the count and not the position: it says eleven of the fourteen months and it does not say which eleven. So the bar below is drawn as a share of the run and never as a place inside it. Nothing in the record marks the day the account stopped being accurate, and that absence is itself the point.

HOW LONG THE ACCOUNT WAS ACTUALLY TRUE, ACROSS A FOURTEEN MONTH RUN Incident I13 at the invented bank. The goods existed and the bank would have been paid, for eleven of the fourteen months. ELEVEN OF THE FOURTEEN MONTHS the account the officer gave themselves was true THREE MONTHS it was not 78.6 per cent of the fourteen month run THE RECORD STATES A COUNT AND NOT WHICH ELEVEN MONTHS so this is drawn as a share of the run and never as a position inside it, and nothing in the record marks the moment the account stopped being accurate.
A rationalisation that is partly true is durable, and this one held for eleven of fourteen months.
Try it out

For how much of this fraud's run was the rationalisation actually true, and why does that matter?

Why is it not a tool for identifying people?

Sooner or later somebody in a meeting proposes the obvious-sounding thing: if the three conditions are known, why not go looking for them? An indicator for pressure, a watch for the signs, a way to get ahead of it. The proposal sounds like prevention, and it is worth being blunt about why it is not.

Start with what screeningUsing an explanatory frame to try to identify individuals in advance, which this material refuses on both practical and ethical grounds. would actually require. Detecting pressure means knowing the private financial circumstances of the people who work for the institution. Knowing them means collecting them, holding them, and acting on them. The collection is an intrusion, and it is an intrusion imposed on everybody in order to find, at best, a handful. An institution that sets out to detect pressure has decided to inspect the private lives of its staff, and no framing of that decision makes it something else.

Then look at whether it would even work. The practical answer is as bad as the ethical one. The number of people carrying serious financial pressure at any moment is very large. The number of them who do anything wrong about it is very small. A test fired at a very large population to find a very small one produces overwhelmingly wrong answers, and every wrong answer here is a person treated as suspect on the basis of a difficulty in their life. The signal is not weak in some fixable way. The signal is weak because pressure is common and the act is rare, and no amount of care about the indicator changes that ratio.

Rationalisation is worse still, and it cannot be observed at all before the fact. A rationalisation is an account somebody gives themselves, in private, about something they have not yet done. There is nothing to measure. Anybody claiming to detect it is claiming to read intent, and intent cannot be read.

So a screening use of the frame does two things and buys nothing. Screening intrudes, and it points the effort at the two legs an institution cannot change. The one leg it can change is left exactly where it was. The correct reading of Cressey is the opposite of a watch list. Opportunity is the only leg that will move, so opportunity is where everything available should be spent. Pressure is private. Rationalisation is invisible until afterwards. How the work is arranged is written down, visible and changeable this week, and it is the same for every person who will ever hold the job.

Try it out

A colleague proposes using the triangle to identify staff at risk of committing fraud. Which pair of reasons refuses it best?

Why do internal frauds run so much longer than anything else in a loss record?

Set the frame aside for a moment and just read the record. The invented bank states a running timeHow long an event continued before it was found, which for a fraud is the measure that matters most and appears in no loss column. for six of its thirteen incidents, and the six do not sit anywhere near each other. Incident I3, a core banking outage, ran 4 hours and 20 minutes. Incident I9, a vendor-hosted payment gateway failure, ran 9 hours. Incident I6, a deposit rate applied above the approved card, ran eleven days. Incident I10, a stale collateral valuation feed, ran 11 working days. And then the two category 1 internal frauds: incident I13 ran fourteen months and incident I5, in which a branch officer created 14 fictitious accounts and moved Rs 3.6 crore through them at a net loss of Rs 2.7 crore, ran twenty two months ending in month 5. The two frauds carry thirty six months of running time between them.

The population deserves care before any conclusion is drawn from it. The other seven incidents in this record carry no stated running time at all, so the record cannot say which event in the year as a whole ran longest. Of the six incidents whose running time the record states, the two internal frauds are the longest by an enormous margin, and the gap is not close enough for the missing seven to change the shape. A silence in a record is a silence and stays one.

The reason for the gap is a mechanism and not a moral, and it is worth stating carefully. Every other event in this record announced itself. A system that stops has stopped, and somebody notices within minutes. A payment that goes twice produces a second debit that a reconciliation will not balance. A feed that goes stale produces a value that is the same today as yesterday, and a data quality check can see that. Each of those events is a failure of the process to do what it was built to do, so each generates a signal inside the very process it happens in.

A fraud is not a failure of the process, so it generates no such signal. The process did exactly what it was designed to do: it received a document set, it checked it, it released an instrument. The check itself was compromised, so the process ran to completion and reported success every time. Nothing inside a process is going to surface an act that the process itself was made to complete, and running time for a fraud is therefore bounded by how long it takes something outside the process to notice.

The detection routeHow something was found, which the record states for incident I13, a beneficiary bank claiming, and does not state at all for incident I5. for incident I13 bears that out exactly: it was found when a beneficiary bank claimed, and somebody outside the bank altogether was asking about something. The record states no detection route at all for incident I5, and two events with one stated route between them cannot carry a claim about how both were found.

RUNNING TIME, WHERE THE RECORD STATES ONE, AT THE INVENTED BANK Six of the thirteen incidents carry a stated running time. The other seven are shown as what they are, which is unmeasured. HOURS 2 incidents INCIDENT I3 4 hours 20 minutes INCIDENT I9 9 hours DAYS 2 incidents INCIDENT I6 eleven days INCIDENT I10 11 working days MONTHS 2, both category 1 INCIDENT I13 fourteen months INCIDENT I5 twenty two months LONGEST OF THE SIX MEASURED and by a very wide margin NOT STATED 7 incidents incidents I1, I2, I4, I7, I8, I11 and I12 carry no stated running time, so the ranking covers the six that do and assumes nothing about the seven that do not. Incident I6's eleven days are calendar days and incident I10's eleven are working days, and the two are not converted into one another.
Of the six incidents with a stated running time, the two internal frauds are the longest by a wide margin.

Long running time is not just an unpleasant fact about a category. Long running time also converts a category into most of a loss record. Category 1 at this invented bank carries 2 of the 13 incidents, or 15.4 per cent of the count, and Rs 18.1 crore of the year's Rs 43.8 crore of net loss, or 41.3 per cent of the value. Two events, out of thirteen, account for more than two fifths of everything the year cost, and the thing they had in common was time.

CATEGORY 1, INTERNAL FRAUD: WHAT IT IS BY COUNT AND WHAT IT IS BY NET VALUE The invented bank's thirteen incidents and its Rs 43.8 crore of net loss for the year. Both bars run on a nil to one hundred per cent track. SHARE BY COUNT 2 of 13 incidents 15.4 per cent SHARE BY NET VALUE Rs 18.1 crore of Rs 43.8 crore 41.3 per cent 0 25 50 75 100 TWO EVENTS IN THIRTEEN CARRY MORE THAN TWO FIFTHS OF WHAT THE YEAR COST a record read by counting events and a record read by weighing them describe two different years.
Category 1 is 15.4 per cent of this record by count and 41.3 per cent of it by net value.
Try it out

Why are the two internal frauds the longest-running of the six incidents whose running time this record states?

Rebalancing: When, Why and What It Costs — free micro-course from Fin Maverick

What would earlier detection have been worth, and what would it not have been worth?

Running time has a money consequence, and it is worth working out carefully. The working also shows what the arithmetic cannot say. Incident I13 booked Rs 15.4 crore of net loss over fourteen months. Spread that on a straight line and it is Rs 1.10 crore a month exactly. Dividing 15.4 by 14 gives 1.1 with nothing left over.

Two warnings attach to that number, and both stay on screen throughout. The straight line is the reader's own assumption and not the case's: the record says what the event cost and says nothing at all about how the cost accrued across the fourteen months. A second, equally reasonable basis sits right beside it. 9 letters of credit were issued, and Rs 15.4 crore over 9 instruments is Rs 1.71 crore each. The question being asked is about time, so the monthly straight line is the one used, and it remains a device.

Now run it. At Rs 1.10 crore a month, detection in run month 4 gives Rs 4.4 crore, exactly the whole of category 7's net loss for the year at this invented bank, three incidents put together. Be careful with that figure: Rs 4.4 crore here is category 7's year, and the same Rs 4.4 crore appears elsewhere in this case as incident I9's gross loss, so the object is named every time. Detection in run month 5 gives Rs 5.5 crore, passing incident I4 at Rs 5.2 crore. Incident I4 is the largest net loss among the other twelve incidents, so at Rs 5.5 crore this event would already have stood at the top of the year's net list, in run month 5 of a run that went to fourteen.

The exact crossing is run month 4.73, being 5.2 divided by 1.1. No whole month puts this event second on net. Second place occupies the narrow band between incident I1 at Rs 4.8 crore and incident I4 at Rs 5.2 crore, or run month 4.36 to run month 4.73, and no integer sits inside it. Every rank here names its basis: everything in this paragraph is on net loss, and on gross loss the year is led by incident I2 at Rs 42.0 crore instead.

NET LOSS ON INCIDENT I13 AGAINST THE RUN MONTH IT IS DETECTED IN Rs 1.10 crore a month on a straight line. The invented bank's record does not say how the loss accrued, so the line is a device. ACTUAL DETECTION: RUN MONTH 14 Rs 15.4 crore of net loss on this event, which is what happened TWO LANDMARKS THE LINE PASSES EARLY run month 4, Rs 4.4 crore of net loss, level with category 7 for the whole year run month 4.73, Rs 5.2 crore, level with incident I4, the biggest of the other twelve 0 2 4 6 8 10 12 14 RUN MONTH WITHIN THE FOURTEEN MONTH RUN AT WHICH THE SCHEME IS DETECTED 0 4 8 12 16 NET LOSS ON THIS EVENT, Rs CRORE The straight line is the reader's own assumption and the invented case does not say how the loss accrued. The alternative basis is Rs 15.4 crore over 9 letters of credit, being Rs 1.71 crore each; the monthly basis is the one used.
Detection month and loss run in a straight line, and the line passes two named landmarks very early.

There is one more date in this record that belongs here, and it is uncomfortable. Near miss N4, in month 7, was a trade finance document set carrying the same forgery pattern, refused by a checker. The refusal was recorded as routine and linked to nothing. Incident I13 ran fourteen months ending in month 8, so it began in month minus 5, and case month 7 is run month 13 of the fourteen. At Rs 1.10 crore a month that is Rs 14.3 crore already accrued, being 92.9 per cent of the final figure. The near miss that carried the pattern arrived when the scheme was 92.9 per cent complete, and no sharper statement exists of why a linked near miss is loss the learning would have been looking at and never loss avoided. The near miss as a record, and the two links inside this year, are set out under near miss recording.

Try it out

The fraud ran fourteen months and cost Rs 15.4 crore net. Before the control below is moved: how long would it have had to run to take the year past the invented bank's own Rs 60.0 crore loss limit?

Play with it

Move the detection month and watch the limit stay out of reach

One control: m, the run month within incident I13's fourteen month run at which the scheme is detected, from 1 to 14. Two consequences are drawn together. The lower line is the net loss on this event, or Rs 1.10 crore times m. The upper line is the invented bank's whole year of net operational loss, with the other twelve incidents held still at Rs 28.4 crore, so it reads Rs 28.4 crore plus Rs 1.10 crore times m. Limit L11, the bank's own rolling twelve month cap of Rs 60.0 crore, is drawn far above both and is never reached anywhere on the control. The solved points are these. At m of 1 the event books Rs 1.1 crore and the year reads Rs 29.5 crore, being 49.2 per cent of limit L11. At m of 4, Rs 4.4 crore and Rs 32.8 crore, being 54.7 per cent, and Rs 4.4 crore is also the whole of category 7's net loss for the year. At m of 5, Rs 5.5 crore and Rs 33.9 crore, being 56.5 per cent, and Rs 5.5 crore passes incident I4 at Rs 5.2 crore. At m of 7, Rs 7.7 crore and Rs 36.1 crore, being 60.2 per cent. At m of 13, Rs 14.3 crore and Rs 42.7 crore, being 71.2 per cent. At m of 14, Rs 15.4 crore and Rs 43.8 crore, being 73.0 per cent, and that is what happened. TWO CROSSINGS DO NOT EXIST ANYWHERE ON THIS CONTROL. Passing the other twelve incidents at Rs 28.4 crore needs run month 25.8, nearly twice the run. Reaching limit L11 needs run month 28.7, more than twice it. The control starts at m of 14, reproducing the case exactly.

FOUND IN RUN MONTH 1m = RUN MONTH 14FOUND IN RUN MONTH 14
TWO PARALLEL LINES, AND A CAP NEITHER OF THEM REACHES Vindhya Commercial Bank Limited, invented. The other twelve incidents are held still at Rs 28.4 crore, which they would not be. LIMIT L11, Rs 60.0 CRORE, THE INVENTED BANK'S OWN CAP THE YEAR: OTHER TWELVE AT Rs 28.4 CRORE PLUS THIS EVENT NET LOSS ON THIS EVENT ALONE 0 2 4 6 8 10 12 14 RUN MONTH AT WHICH THE SCHEME IS DETECTED, 1 TO 14 0 20 40 60 NET LOSS, Rs CRORE
Run month detected
14
Net loss on this event
Rs 15.4 cr
The year, all thirteen
Rs 43.8 cr
Limit L11 utilisation
73.0%

Detected in run month 14, this event books Rs 15.4 crore and the year reads Rs 43.8 crore against a limit of Rs 60.0 crore, which is 73.0 per cent of it.

Run month detectedNet loss on this eventThe year, all thirteenLimit L11 utilisation
1Rs 1.1 croreRs 29.5 crore49.2 per cent
4Rs 4.4 croreRs 32.8 crore54.7 per cent
5Rs 5.5 croreRs 33.9 crore56.5 per cent
7Rs 7.7 croreRs 36.1 crore60.2 per cent
13Rs 14.3 croreRs 42.7 crore71.2 per cent
14, what happenedRs 15.4 croreRs 43.8 crore73.0 per cent

Utilisation is computed from whole rupees divided by the whole rupee limit and never from a rounded crore figure. Passing the other twelve incidents at Rs 28.4 crore needs run month 25.8 and reaching limit L11 needs run month 28.7, and neither exists inside a fourteen month run.

Educational illustration. The straight line is the reader's own assumption and the invented case does not say how the loss accrued; the alternative basis is Rs 15.4 crore over 9 letters of credit, being Rs 1.71 crore each. The other twelve incidents are held still and in reality would not be, and the control moves detection inside the run rather than moving the event into or out of the twelve month reporting window. The readout is the loss booked on the event and is never a loss avoided: earlier detection is stated as a smaller booked figure and not as money saved by anybody. Every figure belongs to one invented bank and the Rs 60.0 crore of limit L11 is the bank's own decision under appetite clause A7, not a requirement from any authority.
Try it out

Detected in run month 5, this event would have booked Rs 5.5 crore of net loss. What would that have made it in the year's record?

Rebalancing: When, Why and What It Costs teaches you to choose a rebalancing rule and say what it buys and what it costs.

Does a limit on annual operational loss protect against fraud at all?

The invented bank has a limit numbered L11 capping net operational loss over a rolling twelve months at Rs 60.0 crore. The limit sits under appetite clause A7, and both the limit and the clause are the bank's own decisions rather than anything required by an authority. At month 12 the year stood at Rs 43.8 crore, being 73.0 per cent of the limit. A utilisation of 73.0 per cent reads like a sensible margin, and the question worth asking is whether the margin did any work.

Work it out. The other twelve incidents carry Rs 43.8 crore less Rs 15.4 crore, or Rs 28.4 crore. For the year to touch Rs 60.0 crore, this event alone would have to carry Rs 31.6 crore, and at Rs 1.10 crore a month that is run month 28.7. The fraud ran fourteen. So reaching the limit would have needed it to run more than twice as long as it did. And there is a second landmark that also fails to arrive: for this one event to be worth more than all the other twelve put together it would need Rs 28.4 crore, being run month 25.8, again nearly twice the run. At its full fourteen months it is Rs 15.4 crore against Rs 28.4 crore, or 54.2 per cent of them.

A limit on annual operational loss is not a control against fraud, and this arithmetic is the whole argument. The largest single net loss in this bank's year ran for fourteen months, and at no point in those fourteen months did the limit come within reach of being touched. Nothing in the limit framework would have brought the event forward by a single day. None of that is a criticism of the limit. The limit does the job it was built for, and that job is to tell a committee whether the total is drifting. The arithmetic is a statement about what the total cannot see.

THE YEAR AGAINST LIMIT L11, AND THE DISTANCE THAT WAS NEVER CLOSED Vindhya Commercial Bank Limited, invented. Limit L11 is the bank's own cap and is not a requirement from any authority. LIMIT L11, Rs 60.0 CRORE, THE BANK'S OWN CAP THE YEAR AS RECORDED: Rs 43.8 CRORE OTHER TWELVE, Rs 28.4 CRORE THIS EVENT Rs 15.4 CRORE WHAT REACHING LIMIT L11 WOULD TAKE Rs 16.2 CRORE MORE run months 15 to 28.7, which do not exist in this record 0 10 20 30 40 50 60 70 NET OPERATIONAL LOSS FOR THE TWELVE MONTHS, Rs CRORE NEITHER CROSSING EXISTS INSIDE THE FOURTEEN MONTH RUN passing the other twelve needs run month 25.8 and reaching limit L11 needs run month 28.7, both far beyond it.
Reaching this bank's own annual loss limit would take run month 28.7, twice the fourteen months it ran.

Where this goes wrong in practice

Two failures, and they are different in kind. The first is the screening one already refused above: reading the triangle as a list of things to look for in people. Screening intrudes, the signal does not work, and the effort lands on the two legs that cannot be moved. A frame that explains after the event has been turned into a test applied to individuals before one, and the conversion is not a stretch of the frame, it is the opposite of it.

The second is a measurement failure and it is quieter. A committee looks at Rs 43.8 crore against a Rs 60.0 crore cap, sees 73.0 per cent, and concludes that operational loss is under control. Every word of that is arithmetically true, and the conclusion still does not follow. The largest single item inside the total ran for fourteen months without the total ever noticing. An annual figure measured against an annual cap is a measure of drift, and a fraud is not drift.

The third thing is not a failure but a limit on what the arithmetic above can say. Detection in run month 5 produces a smaller booked loss on this event. Nobody at this invented bank ever had the choice being modelled, so a smaller booked loss is not money saved. Earlier detection is stated here as a smaller figure in a record and never as a benefit anybody realised, and the difference between those two statements is the difference between measurement and wishful accounting.

How this is actually used by somebody with the job

Somebody sitting in an operational risk function does not use the triangle to think about people. The frame is used in one narrow way, as a checklist for reading a loss event backwards until the design question falls out. A loss lands. What was the opportunity? Not who did it, not why, but what arrangement made it possible for the act to be completed without anything disagreeing? The question has a written answer somewhere, in a procedure or a system entitlement, and finding it converts an incident into a change somebody can be asked to make.

The same reading works far away from a bank. A shop with one person who takes the cash, writes the book and does the banking has an opportunity, and it is a fact about the shop rather than about the person. Saying it out loud accuses nobody of anything. A household that has one person who holds every account password and every statement has the same shape, and it is also the shape that leaves the household unable to check anything if that person is ill. A housing society treasurer who both approves the bill and signs the cheque has it too. In every one of those the useful sentence is identical: which single arrangement means that nothing has to agree with anything else?

The practitioner value of Cressey's frame is that it stops the conversation about the person and starts the conversation about the arrangement, every single time, and it does so without needing anybody to be suspicious of anybody. A conversation about arrangements can be had in the open, in front of the people affected, and can end in a change to a procedure. A conversation about who might be under pressure cannot be had in the open at all, and that is a good clue as to whether it should be had.

Segregation of duties as a control, meaning the incompatible pairs, what separation costs, where it is impossible and what it cannot reach, has a treatment of its own; the opportunity leg is used here as a finding. Root cause analysis is covered separately, and no causal chain is run here. The loss event and its dates, and the near miss and its links, are covered separately too, and near miss N4 appears here only as the moment the pattern was refused. Control testing, the audit finding, the deficiency rating and remediation belong to financial controls and assurance, a subject area that checks what this one designs. Letters of credit, and how they pay, belong elsewhere entirely. Investigation, discipline, employment consequences, reporting to any authority and recovery action against any individual are treated nowhere in this material.
Try it out

What does this material say about what should happen to the officer in this case?

India

Where the obligations around fraud risk actually come from

The frame set out here is jurisdiction free and it belongs to Donald Cressey rather than to any authority. Pressure, opportunity and rationalisation work the same way in any country, and so does the observation that only one of the three is a design question.

The requirements differ by country, and the sources for them are named below. The seven operational risk event categories, within which internal fraud is category 1, are published by the Basel Committee on Banking Supervision at the Bank for International Settlements, bis.org. The Basel Committee is a standard setting body and not an Indian supervisor. Naming only the global standard is the confident and common error in this subject, and it settles nothing about what binds. An Indian bank's actual duties on fraud risk management, including how an event is classified and what has to be reported to whom and by when, come from the Reserve Bank of India at rbi.org.in.

Every classification, reporting timeline, threshold, ratio and effective date must be taken from the issuing body. Where a control failure has to be reported on in the accounts, the duty on internal financial controls sits in the Companies Act, whose text, applicability and exemptions come from the Ministry of Corporate Affairs at mca.gov.in, with the assurance standard from the Institute of Chartered Accountants of India at icai.org.

Risk Management Program Bootcamp — Fin Maverick

Sources

SourceDocumentSite
Donald CresseyOther People's Money, 1953, the work in which the fraud triangle of pressure, opportunity and rationalisation was set outnamed in the text
Bank for International SettlementsThe Basel Committee on Banking Supervision publications setting out the seven operational risk event categories, within which internal fraud is category 1bis.org
Reserve Bank of IndiaWhat an Indian bank must actually do about fraud risk management, classification and reporting, and about operational risk more widelyrbi.org.in
Ministry of Corporate AffairsThe Companies Act duty on internal financial controls, its applicability and the form of the reportmca.gov.in
Institute of Chartered Accountants of IndiaThe assurance standard and guidance note behind reporting on internal financial controlsicai.org

Vindhya Commercial Bank Limited is invented.
Educational material. Not advice on any investment, tax, budget or market position.

← PreviousNext →
Fin Maverick Micro CoursesExplore Micro Courses
Fin Maverick BootcampsExplore Bootcamps
Fin Maverick

Finance education that ends in a job, not a certificate that gathers dust. Built for young India.

LEARN
CalculatorsFrameworksComparisonsCareersShowdown
RESOURCES
All CoursesMicro CoursesBootcampsInternships
COMPANY
AboutJob openingPartnership
LEGAL
Privacy PolicyTerms & ConditionsContent LicenseReturn & Refund Policy
© 2026 FIN MAVERICK / BUILT FOR INDIA.DO FINANCE, DO NOT JUST READ ABOUT IT.