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Case study

Building the First-Ever Fraud Framework for a Leading UK Pension Risk Insurer​

Headshot - Matt B
Lead partnerMatt Beattie
Lead partnerMatt Beattie

Our client, a fast-growing UK insurer, came to us because they had no formal fraud-risk measures in place. 

A recent Group Audit had highlighted to the team that there was currently no documented fraud programme, and that any controls that were in place might not adequately cover fraud risks. New regulations, in the form of the UK’s Failure to Prevent Fraud offence, would also apply to our client’s business, and so ‘reasonable procedures’ needed to be put in place to deter and detect internal fraud. 

With limited in-house fraud expertise and acquisition teams based in the UK, US and Australia, senior compliance leaders needed fast, practical answers to key questions: what kind of fraud framework was needed, how the new legislation affected that, where the business was exposed, and how much time and money should be invested in the response. 

  • Industry segment

    Insurance

  • Function

    Fraud

  • Core capabilities

    Programme Management

Key outcomes delivered
  • Demonstrable compliance: A solid, defensible paper trail for regulators and auditors.
  • Targeted investment: a plan focused on three high-impact areas rather than an expensive, blanket programme.
  • Business-wide confidence: Senior stakeholders understand the fraud risks, their role in managing them, and what’s being done, with clarity and ownership across the business. 

Results

Programme management

0 /3

of workstreams rated ‘high maturity’ (up from a predominantly ‘low maturity’ baseline)

Delivery

0 -70

milestones plotted per workstream, improving delivery discipline

Training

0

internal staff trained by BeyondFS on programme delivery

Approach

Intensive workshops, focused on delivery

BeyondFS ran three intensive all-day workshops that took the client from uncertainty to a clear, actionable plan.

  • Workshop 1 – Fraud 101 and Regulation: We clarified the legal definition of fraud, the difference between internal and external threats, and brought the Failure to Prevent Fraud offence to life with real-world examples. We also shared benchmarks to show what ‘good’ looks like in financial services. 
  • Workshop 2 – Threat Assessment: We mapped fraud risks across the customer and investment lifecycle using a tailored typology framework. This surfaced two blind spots: overseas sales teams producing potentially misleading materials, and supplier contracts lacking fraud-termination clauses.
  • Workshop 3 – Priorities and Roadmap: We agreed the top priorities and three quick wins—tagging relevant controls, tightening oversight of overseas sales content, and embedding fraud clauses into supplier contracts. A six-month action plan was provided with named owners, milestones and a supporting slide pack summarising threats, actions and next steps.
BFS-writing-board
Outcome

Reassurance and a clear, actionable roadmap

By the end of our engagement, BeyondFS was able to leave our client with a clear path ahead.
  • Regulatory peace of mind – The Board and Audit Committee can now show that fraud risk has been assessed and a proportionate plan approved, which will be key under the new legislation.  
  • A clear view of actual exposure – The workshops confirmed the firm’s inherent fraud risk is modest, allowing them to avoid over-engineering their response.  
  • An actionable, in-house roadmap – Compliance, Audit and Legal left with a practical to-do list they can deliver internally.