Fraud Work
YAMNA KHAN
Investigations & Compliance Professional | 12+ Years in Fraud and ABAC, Compliance and Regulatory Audits
📧-| 📱 - | 🌐 linkedin.com/in/yamna-khan-b316517a
Anti-Bribery & Corruption (AB&C) Reviews and Investigations
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Conducted investigations and compliance reviews for pharmaceutical clients in Dubai, evaluating
Anti-Bribery and Corruption (AB&C) practices across the Gulf and Sub-Saharan Africa. The
assessments focused on policies, processes, and distributor records to ensure compliance with the
FCPA and UK Bribery Act.
Conducted an FCPA compliance review of a distributor in Pakistan for a multinational
pharmaceutical company, focusing on debit notes, free goods, congress sponsorships,
educational grants, and margin analysis. The review highlighted gaps in the agreement, including
the absence of general clauses on reimbursable expenses, lack of clarity in expense
documentation, and non-monitoring of distributor commissions by the company.
Conducted an Anti-Bribery & Corruption (AB&C) compliance review for a multinational freight
forwarding company in Pakistan. The assessment focused on integrity due diligence of customs
clearing agents, covering areas such as facilitation payments, donations, and grants to customs
authorities, as well as compliance with the company’s AB&C policies and procedures. The review
identified non-compliance issues within the customs clearing agent’s practices.
Conducted an AB&C investigation into allegations of improper business conduct by a distributor
and a commercial sales manager of a multinational pharmaceutical company in Pakistan. The
investigation revealed control deficiencies, channel stuffing, fake invoices for key account
customers, and unsupported incentive claims.
Conducted an AB&C investigation into allegations that a distributor offered sponsorships to
healthcare professionals (HCPs) in government hospitals without sufficient documentary evidence.
The review exposed missing attendance sheets and lack of photographic proof verifying HCP
participation.
Led an AB&C compliance review for a multinational pharmaceutical company in Pakistan,
evaluating key areas such as compliance programs, allegations, training effectiveness, global
policies, leadership, donations, third-party due diligence, market research, promotional materials,
and employee expenses.
Led an allegation of improper business conduct by a distributor and the sales team of a
multinational pharmaceutical company in Pakistan. Findings indicated that while distributors had
not supplied goods to customers, the manufacturer received invoice payments from an
anonymous source.
Led an AB&C investigation into allegations that a distributor exerted undue influence over hospital
procurement departments to sell products from competing pharmaceutical companies. Findings
revealed excess inventory held by the distributor, raising concerns about compliance violations.
Led an AB&C compliance review for a multinational industrial product manufacturer in Pakistan,
assessing petty cash disbursements. The review uncovered policy gaps, including the absence of
standard operating procedures for petty cash usage and inadequate supporting documentation
for expenses such as gifts, CEO perquisites, and salaries paid via petty cash.
Led an AB&C investigation for a multinational pharmaceutical company in Pakistan into allegations
of offering improper benefits (e.g., foreign trips) to Health Care Professionals (HCPs) in exchange for
product prescriptions. The investigation revealed significant policy ambiguities, improper payments
to government officials, inadequate documentation of promotional events, and insufficient due
diligence around hospital and institutional donations.
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YAMNA KHAN
Investigations & Compliance Professional | 12+ Years in Fraud and ABAC, Compliance and Regulatory Audits
📧-| 📱 - | 🌐 linkedin.com/in/yamna-khan-b316517a
Fact-Finding Investigations
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Investigated fraudulent payroll schemes (falsified wages, improper hiring, promotions, and
unauthorized increments) and expense reimbursement fraud (mischaracterized expenses,
overstated claims, fictitious reimbursements, and duplicate claims) for a multinational
pharmaceutical company in Pakistan.
Investigated allegations that the CEO of a multinational industrial product manufacturer in Pakistan
bypassed HR in recruitment decisions, granted himself unauthorized salary increases, and favoured
relatives with promotions, increments, and bonuses. The investigation exposed segregation of duty
failures, policy gaps, and procedural lapses.
Investigated allegations that the CEO of a multinational industrial product manufacturer in Pakistan
bypassed HR in recruitment decisions, granted himself unauthorized salary increases, and favoured
relatives with promotions, increments, and bonuses. The investigation exposed segregation of duty
failures, policy gaps, and procedural lapses.
Led a fact-finding investigation for a multinational consumer goods manufacturer in Pakistan,
identifying financial implications and control deficiencies resulting from non-compliance with
standard operating procedures.
Led a fact-finding investigation into allegations of improper contract awards by senior
management (including the CEO) of a multinational industrial product manufacturer in Pakistan.
Findings indicated insufficient transparency in the tender process, including a lack of pricing
documentation for submitted bids.
Led a fact-finding investigation into a non-profit organization in Pakistan, examining governance
structures, bank transactions, petty cash payments, and supplier payments deposited into the
personal account of an accountant. Findings showed discrepancies in regulatory filings with the
Securities Exchange Commission of Pakistan (SECP), lack of financial controls, insufficient
documentation to justify expenses, and errors in fund transfers—though funds were later correctly
redirected.
Led a fact-finding investigation into allegations of fictitious payments made to vendors through
clearing agents for imported goods by a leading fast food restaurant chain in Pakistan. The
investigation revealed policy and procedural gaps, duplicate vendor records, insufficient invoices,
payments to multiple vendors for similar expenses, lack of financial department expertise in the
import cycle, and absence of beneficiary details for company payments.
Led a fact-finding investigation into the operational and financial affairs of one of Pakistan’s largest
banks, covering a 13-year period. The review encompassed internal and external circulars,
committee minutes, internal audit reports, borrower credit files (sanction letters, KYCs, eCIBs,
financial statements, mortgage deeds, valuation reports, bank statements, and fund utilization
records). Key focus areas included letter of credit facilitation at nil margin, credit facilities for family
group businesses, inadequate collateral, facility renewals, asset-liability mismatches, and liquidity
management strategies. The investigation revealed potential financial impact and control
weaknesses stemming from internal misconduct.
Led a fact-finding review of credit borrowers at a leading Islamic bank in Pakistan, conducting an
end-to-end assessment of credit sanctioning, disbursement, monitoring, settlement, and
restructuring/classification. Findings showed that group companies obtained credit and used it to
settle overdue facilities for one another, preventing classification and provisioning risks for the credit
borrowers.
Led a fact-finding investigation for a Dubai-based bank, examining potential conflicts of interest
with contractors, including allegations of kickbacks received by a bank employee to secure
contracts and variation letters. The investigation involved data analysis, keyword searches on
electronic records, interviews, and financial assessments.
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YAMNA KHAN
Investigations & Compliance Professional | 12+ Years in Fraud and ABAC, Compliance and Regulatory Audits
📧-| 📱 - | 🌐 linkedin.com/in/yamna-khan-b316517a
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Led an investigation into gross misconduct allegations against the General Manager of a
Dubaibased hospitality asset owner. The review focused on electronic evidence and documents related
to intellectual property misuse and preferential vendor relationships.
Assisted in preparing a police report concerning theft and breach of trust at a Dubai-based
company, resulting in financial losses. The investigation included CCTV footage analysis, fraud
scheme identification, and financial impact assessment.
Dispute Advisory Services
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Assisted in independent accounting expert services, computing cost overruns claimed by the
company due to delayed handover of land/infrastructure by the customer. Analysis was
conducted in alignment with the applicable clauses of the concession agreement between the
parties.
Regulatory Compliance
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Conducted a 15-month regulatory compliance review of a local company in Pakistan, assessing
circulars, directives, internal policies, procedures, acts, rules, regulations, committee minutes, and
internal audit reports. The review uncovered non-compliance issues across various regulatory and
policy areas.
Media Compliance Audit
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Assisted in a third-party media compliance audit for a multinational media agency, conducted on
behalf of a leading FMCG company in Pakistan. The audit focused on financial compliance with
contractual clauses, including bulk volume discounts and operational testing.
Fraud Risk Management & Training
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Forensic in the Audit (FITA): Assisted KPMG audit teams in Pakistan during discussions with key
management of various banks, identifying fraud risks in accordance with ISA 240 standards.
Investigation Skills Training: Assisted in conducting an investigation skills course for a leading
Pakistani bank and a major industrial group operating in fertilizers, food, and energy production.
Fraud Risk Strategy Assessment: Assisted in assessing fraud risk management strategies for a leading
industrial group in Pakistan within the fertilizer, food, and energy sectors.
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