The essential principles of the Bank’s procedures for the prevention, detection and prosecution of fraud and corruption are that everybody in the Bank is involved; there is no central starting point or central figure in charge; and there is a seamless connection between underwriting, operating, monitoring and collections and the prevention, detection and prosecution of fraud and corruption. The procedures for the prevention, detection and prosecution of fraud and corruption are diffuse procedures that are heavily dependent upon a cultural awareness throughout the Bank of the dangers of fraud and corruption in the Bank’s transactions.
- Vigilance by all parties. The primary bulwark against fraud and corruption in Bank transactions is underwriting. The various Bank programs are underwritten in different ways. Some rely to a significant degree on underwriting by lenders and others are more directly underwritten in-house. In addition, different Bank programs have different fraud and corruption-risk profiles just as different programs have different credit-risk profiles. However, the Bank encourages and expects all participants in EXIM Bank transactions to be aware of the risk profiles of the programs in which they participate, to be vigilant regarding such risks, and to report any suspicions of fraud or corruption in Bank transactions.
- Standard and Enhanced Underwriting; Training. The Bank utilizes standard screening procedures pursuant to which loan officers run names of transaction participants against a database clearing house including the OFAC lists and the Federal Government exclusion list on SAM.gov. This protects the Bank from approving transactions in which participants are known bad actors. Additionally, the Bank’s Loan officers and underwriters make judgments, based on the risk profile of a transaction and based on information that is developed during underwriting, as to what additional due diligence, including enhanced due diligence in certain circumstances, should be conducted on a transaction. Any due diligence that increases the Bank’s knowledge about program participants ipso facto helps to decrease the risk of fraud and corruption. Finally, underwriters and loan officers are required, from time to time, to take various “fraud” trainings offered by the Bank. This helps keep fraud and corruption concerns at the forefront of awareness as well as providing training to detect indications of fraud. Fraud trainings are offered by the Bank’s Division of Human Capital, as well as by the Credit Review and Compliance Division.
- Fraud Investigation and Prosecution. The Office of the Inspector General, working with the Department of Justice, manages criminal and civil investigations and prosecutions related to Bank transactions and activities. All participants in Bank transactions are encouraged to support the Bank’s efforts in combatting fraud and corruption in Bank transactions.
- If you have any suspicions regarding fraud or corruption in Bank transactions, you may report those suspicions anonymously using the OIG Hotline (1-888-OIG-EXIM/1-888-644-3946) or by other methods set forth on the OIG website (http://www.exim.gov/about/oig/oig-hotline). Additionally, you may contact the Bank’s Office of the General Counsel (202-565-3460).