Ghost claimants and compensation fraud: the controls that actually work
Where large payments meet weak identity records, diversion follows. Detection is cheap if the register was built for it.
A compensation programme moves large sums to people with weak documentation, through a chain of officials with local discretion, in places where oversight arrives quarterly at best. Diversion is a predictable risk rather than an unfortunate surprise, and the controls that prevent it are ordinary.
The recurring schemes
- Ghost claimants. Records inserted into the register for people or assets that do not exist, paid to an account somebody controls.
- Inflated assets. Real household, exaggerated counts — trees, area, structure dimensions — with the excess split.
- Substituted payees. A real entitlement paid to someone other than the entitled person, often an intermediary who then keeps part of it.
- Deductions at the table. A facilitation charge taken from a correct payment, which the recipient has no way to contest.
- Post-cut-off insertion. Assets built or planted after the cut-off and enumerated as though they predated it, usually with the cooperation of someone in the process.
Every one of these leaves a signature in the data if the data was built to show it.
Fraud in a compensation programme is not usually clever. It survives because nobody compares two numbers that should match.
Controls in the register
The controls that matter are structural rather than investigative:
- Attribution on every change. Who created a record, who changed a figure, when, and from what to what. A record inserted late by an unexpected user is visible immediately.[2]
- Geolocation and photographs captured at enumeration. A ghost parcel has no coordinates, or coordinates that fall somewhere implausible.
- Separation of duties. The person who enumerates, the person who values, the person who authorises and the person who disburses should be four different people.
- Reconciliation to confirmed receipt, not to payment instruction. The gap between the two is where the money goes.[3]
- Public display of the draft register. Communities know who lives there and what they had. It is the single most effective detection mechanism available and it costs a notice board.
Analytics that find it
With a well-structured register, a small set of routine checks surfaces most of it: records created outside the enumeration window; asset counts in the top percentile by enumerator; duplicate names, phone numbers or bank details across records; payments where the confirmed amount differs from the assessed amount; parcels with no coordinates; and clusters of revisions by a single user shortly before payment.
Run these monthly rather than at audit. The value of detecting a pattern in month four is that it can be stopped; detecting it at completion audit produces a finding and no recovery.[4]
The reporting channel
Affected people usually know when something is wrong, and they will not report it through the officer who is doing it. A reporting route that bypasses the field team entirely — a number, a person, an address outside the district — is a necessary complement to the grievance mechanism rather than a duplicate of it.
It has to protect the person reporting, and it has to produce a visible response at least once, or nobody will use it again.
Proportion and tone
A control environment can become its own harm. Verification requirements that treat every claimant as a suspect delay payments to thousands of legitimate households in order to catch a few, and the delay falls hardest on the poorest. The balance the standards imply is protective rather than punitive: pay people properly and promptly, and build the record so that irregularity is visible without making every household prove its innocence.[1]
Sources
- [1]Performance Standard 5: Land Acquisition and Involuntary Resettlement — International Finance Corporation, 2012.
- [2]Good Practice Handbook: Land Acquisition and Involuntary Resettlement — International Finance Corporation, 2023.
- [3]Evicted and Abandoned: The World Bank's Broken Promise to the Poor — International Consortium of Investigative Journalists, 2015.
- [4]Environmental & Social Issues Update — Office of the Compliance Advisor/Ombudsman (CAO), 2023.
Olule Solomon
Lead Consultant, ValueSpace
Olule Solomon is Lead Consultant at ValueSpace, where he works on land acquisition and resettlement systems for donor-financed infrastructure in East Africa. He writes about the practical gap between what the safeguard standards require and what a project can actually evidence at completion audit.
Related reading
- Verifying identity when half the register has no IDPaying the right person is a compliance requirement and an exclusion risk. Building an identity standard before payments start.
- Reconciling compensation payments: the evidence gap nobody budgets forPaying compensation and proving you paid it are different problems. How disbursement files are reconciled back to entitlements.
- Tax, levies and deductions: what should never come off a compensation paymentCompensation restores a loss; it is not income. Deductions at the payment point are common, informal and usually wrong.
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