Organisation: Australian Health Practitioner Regulation Agency
Job Title: Investigations Officer
Location: AHPRA Victoria Office – Level 8, 111 Bourke Street, Melbourne
Knowledge and experience in the conduct of professional standards investigations in a sensitive
and complex environment
Many of the investigations that I undertake relate to professional standards that govern National
Australia Bank employees and are often of a sensitive nature with many complex facets. A recent
relevant case that I managed related to a massive immigration scam perpetrated by an Indian
national who established himself as a Business Banker. He was utilising a loop hole in NABs
systems to write false loans for young Indian students who were trying to gain Australian
residency. On behalf of these students, who were in Australia on Student Visas, the Banker wrote
loans of $100,000 to be invested in state treasury bonds. For this investment the students
received extra points, often enough for them to gain residency. The Banker charged the parents of
the students between $20,000 and $30,000 to write the false loans. The exposure of the bank in
this case was 22 million dollars in total (22 loans of $100,000 each). The investigation also revealed
serious misconduct by NAB staff members, who were in collusion with the scam. My investigation
also highlighted the structural problems with NAB policies and systems that allowed this scam to
occur. The entire case took nearly two years to completely resolve and was extraordinarily
complex and sensitive. It involved misconduct by NAB staff, massive financial risk to the bank,
immigration fraud, reputational risk and criminal, as well as fraudulent activity. With the support
of external legal counsel I managed this case from start to finish including recouping the 22 million
for the bank through injunctions issued by the Federal Court. I also made a number of
recommendations to prevent this type of situation occurring in the future. In the past I have also
been required to investigate the misconduct (sometimes criminal) of high level executives within
NAB. Of course these investigations are highly sensitive and can result in significant losses for the
bank (both financial and with regard to its reputation).
Demonstrated ability to apply legislative, policy and procedural requirements as they relate to a
regulatory environment
NAB has a range of policies to identify, manage and mitigate the risk of opportunities for financial
crime across the organisation including ones governing Anti Money Laundering, Counter Terrorism
Funding, Sanctions and Embargoes, Anti-Fraud, and Anti-Bribery and Corruption. NAB requires all
of its directors, employees, contractors and consultants to comply NABs Code of Conduct and
policies, including the policies dedicated to the prevention of financial crime. Also reflected in NAB
policies and procedures are the Financial Action Task Force Recommendations (International
Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation) as
well as international Anti-Bribery and Corruption rules and regulations. NAB is also subject to a
range of guidelines from the Australian Prudential Regulation Authority (the Authority oversees
banks, credit unions, building societies and the insurance industry). The investigations I undertake
are made in compliance with all of these policies, procedures, guidelines and regulatory
constraints. I need to understand and apply these documents at every stage of an investigation
determining what breach has occurred and what the consequence of that breach may be. I also
need to understand and interpret employment legislation when undertaking investigations and
considering the consequences of internal misconduct. Another important consideration I have in
my position is whether incidents I am examining are of a criminal nature, so I have also gained a
significant ability to interpret the Crimes Act.
Strong problem-solving, analytical and conceptual skills
It is a necessary component of my current role to demonstrate excellent problem-solving,
analytical and conceptual skills. A recent investigation that I managed involved a major external
fraud that commenced with a phishing attack on NABs systems. As a result the security of internet
banking at NAB was compromised. A large number of customers received an email asking that
they confirm a number of personal details that were held by the bank. With this information the
instigator of the fraud could then open a joint account in their name and that of an NAB customer.
They then transferred money out of the customer’s account and into the joint account and from
there into a separate account entirely. The fraudster also arranged to port the customers phone
accounts so that when the bank rang the customer to confirm transactions the call was diverted to
them. With only a few pieces of information I worked out what was occurring and immediately
ordered a bank wide freeze on the opening of joint accounts remotely. I also put in place a request
that all withdrawals in excess of $100,000 had to be referred through me. I then analysed points of
compromise, determining who had been affected and the scope of their exposure. I utilised a
range of specialist staff such as IT specialists to collate information. I then put in place a range of
measures to prevent future losses. I also contacted the Criminal Branch within the Victorian Police
and worked with them to coordinate a sting operation that resulted in the arrest of one of the
main organisers of the fraud. My actions resulted in the bank recouping $100,000 for a customer
and preventing a loss of five million dollars. I also examined and analysed the internal control
systems and worked with a range of specialist staff to minimise this risk for the bank.
Demonstrated ability to exercise judgment and resolve issues independently
I manage most of my cases independently. A recent case that demonstrates this involved a
suspicious incident that was referred to me at 10am one morning. It involved an over limit loan
with an unusual expiry date. During the course of the day I investigated the loan and the officer in
question, examined a range of back end transactional data, identified the points of compromise as
well as other loans that had been compromised, interviewed the staff member and dismissed him
by end of day. I conducted this investigation autonomously, using my knowledge and judgement
to determine what the incident was, how it had happened and what breaches occurred. I then put
in place the appropriate consequence and followed through.
Strong written communication skills including experience in writing reports and
recommendations, preparing correspondence and agenda items
I have excellent written communication skills and prepare complex, analytical reports on a daily
basis. The reports I develop include details of the investigation, findings and recommendations
with regard to the specific incident as well as future considerations. These reports are presented
to senior NAB staff (the Risk Partners) who need to be to understand the range of information
contained in the document as well as the recommendations for ongoing risk mitigation. Therefore,
these reports need to be clear, concise and authoritative. I also need to compile reports with the
understanding that they may later form part of a criminal case. They could easily become part of
the banks chain of evidence or be subpoenaed in discovery by opposing counsel. I also am
required to prepare a great deal of correspondence in my position to various stakeholders in
investigations, seeking information or data relevant to particular incidents. Once again I need to
be clear and persuasive in these documents and take into account the audience that they are
targeted at. Finally, I also prepare outlines and agendas for the range of briefing sessions,
information sessions, awareness sessions and training that I deliver to bank employees.
Well-developed interpersonal skills with the ability to build and maintain productive working
relationships with a range of internal and external stakeholders
I have exceptional interpersonal skills and my success in my current role is built on having
established productive relationships with a range of stakeholders and important networks. With
regard to the recent phishing attack and the subsequent sting operation, with a single phone call
to the Victorian Police Criminal Investigation, within two hours seven detectives were participating
in this operation. This was based on the excellent relationship I have established with the Victorian
police and their respect of my ability and knowledge. Within the area of financial crime there is a
strong network of investigators across many banks and institutions. We network regularly to keep
abreast of trends in fraud and financial crime and share knowledge and information wherever
possible. We help each other to close compromised systems and ensure that crime trend data is
shared to protect the industry as a whole. I also have excellent contacts and networks with ASIO,
the Australian Federal Police as well a number of government bodies such as the Department of
Immigration and Citizenship. Often the investigations I undertake intersect with a number of these
bodies and having excellent established relationships means a seamless, efficient investigation.
Strong oral communication skills with the ability to deal with difficult and challenging
stakeholders
I also have strong oral communication skills and often have to interview uncooperative
stakeholders. As a bank employee I have no powers to question or interview staff or other
witnesses, however, I find that people rarely refuse to speak with me. I always try to be
personable and approachable, and I work very hard to build rapport with the people I question. I
remain calm and relaxed and invite the person to tell me their side of the story, to explain what
has occurred. I am honest and upfront, and warn them about their rights and obligations. I utilise
the PEACE method of interviewing (Preparation and planning, Engage and explain, Account,
Closure and Evaluate) and have found it be highly successful. To give a quick summary this model
focuses on undertaking substantial pre-planning and being very sure about the purpose of the
interview, establishing a relationship with the interviewee and explaining what kinds of action will
be followed during the interview. The next stage is to obtain the fullest possible account from the
suspect via various communication techniques. You then give closure to the process which
includes giving the interviewee the opportunity to ask any questions. It is crucial that the
interviewer always ensures that there is a planned closure, rather than an impromptu end, to the
interview. After each interview is completed, the event and the material that came from it should
then be evaluated fully and consideration given to whether the objectives of the interview were
achieved. It is also relevant that I provide information sessions, training, and briefings on fraud
awareness to staff in all areas and at all levels of NAB. My audience could be anything from senior
executives at a national meeting through to new tellers at an induction course and their area of
interest anything from high level fraud trends through to minor theft. All of these staff require
different information, pitched at a different level. I adapt my message and its content to meet the
needs of my clients and provide them with as much information possible relevant to their areas of
concern.
Strong organisational skills, including the ability to effectively prioritise and manage multiple
tasks and deadlines whilst ensuring attention to detail
I have excellent organisational and prioritisation skills. I currently am managing 17 open cases and
at any given time I am juggling a number of diverse tasks pertinent to individual investigations.
These tasks can include data mining, analysis, assigning tasks to analysts, conducting interviews,
undertaking internal and external liaison, collating information from specialists, reviewing policy
and legislation to determine breaches and compromises, determining the consequence of the
incident, and how to mitigate future risk. The types of cases I investigate can incorporate anything
from data loss, ID takeover, false documentation, false invoicing, kite flying, scams, electronic
attacks and personal theft. I need to constantly prioritise all my cases based on an ongoing risk
assessment. Risk can be financial, reputational or criminal and can be mandated by the elements
of the case as well as the priorities and focus of NAB management at any given time. I successfully
navigate this maze and have had excellent results and feedback on my ability to meet deadlines
and prioritise my work.
Ability to work collaboratively and effectively as part of a team environment and also show
initiative and work independently when required
I currently work within a close-nit team comprised of other investigators and analysts as well as
other specialist staff within NAB. Initially I work with the two analysts who support me to prepare
an investigation, including planning steps, determining stakeholders and required data. The team
can then expand to include IT specialists, HR experts, legal staff and credit card fraud analysts. We
work closely together, undertaking our separate tasks and then collating and reviewing compiled
information and evidence. The team can continue to vary and change as the investigation
continues often growing to encompass external parties. An example of this occurred when I was
investigating a Chines banker who was in Australia on a Business Visa. Under the conditions of his
visa he was not entitled to purchase property. I commenced working with staff from the
Department of Immigration to determine what financial activities this gentleman had been
undertaking that breached the conditions of his visa and to determine the appropriate
consequences of these incidences.
Intermediate to advanced Microsoft Office skills
I have excellent Microsoft Office Skills and utilise the following programs:
Word to prepare reports and correspondence
Visio to create flowcharts and diagrams to clarify items in my reports
Excel to prepare financial information for reports and briefings
PowerPoint to create presentations for the training that I deliver
Outlook to send emails and manage appointments on a regular basis
