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MICM2 - Enforcement Business Case v12


MICM2 Business Case Statement	Every part of the continuum contributes to guiding client behavior. The final and strongest tool available to ISB, and the element addressed in this business case, is the use of enforcement powers to pursue fraud, whether small or large, including recidivists and some of the most egregious offenders. During any fiscal year, ISB will conduct between 100 and 500 enforcement investigations. Enforcement investigations are seeking to establish evidence of “guilty mind” by the subject, compared to compliance investigations that are seeking to establish and adjudicate on the conduct of “guilt acts” by the subject. As part of processing an enforcement case, there is involvement with the judiciary, so obtaining evidence requires more diligence and effort to conduct and holds more risk to the organization should they be conducted inappropriately.