One thing well known about fraudulent activity is that fraud involving collusion is one of the hardest to detect and prevent. It is extremely difficult to design a system of internal controls that can or woulds be effective in preventing or discouraging collusion from happening. A simple internal control that requires two signatures on each check is ineffective if the two signatures conspire to both sign a check to a fictitious company and then split the proceeds.
Source: PNWC’s Government Contracting Update: “Steering Contracts” Results in Guilty Plea
New Regulation Formalizes Ombudsman Practice and Identity for IDIQ Contracts
An ‘ombudsman’ is an official charged with addressing and/or investigating the interests of individuals’ or companies’