ABSTRACT
When news of scandalous fraud losses comes to the fore, industry executives often deflect criticism from their own agencies through what might be termed defense by display of functional apparatus. They counter suggestions of wide-open vulnerability to fraud by listing all kinds of apparatus, in operational use, aimed at fraud prevention and detection. When their critics accuse them of failing to adequately invest in fraud controls, they respond that those critics only count the resources devoted to specialist investigative units and fail to acknowledge all the other controls embedded within the claims-processing system.
