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.

Olule Solomon9 min read

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:

  1. 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]
  2. Geolocation and photographs captured at enumeration. A ghost parcel has no coordinates, or coordinates that fall somewhere implausible.
  3. 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.
  4. Reconciliation to confirmed receipt, not to payment instruction. The gap between the two is where the money goes.[3]
  5. 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. [1]Performance Standard 5: Land Acquisition and Involuntary Resettlement — International Finance Corporation, 2012.
  2. [2]Good Practice Handbook: Land Acquisition and Involuntary Resettlement — International Finance Corporation, 2023.
  3. [3]Evicted and Abandoned: The World Bank's Broken Promise to the Poor — International Consortium of Investigative Journalists, 2015.
  4. [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.

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