If you are a compliance officer or risk manager at a Brazilian financial institution, this playbook was built for you.
Operating in Brazil's regulated financial sector demands more than ad hoc fraud controls. You are under increasing pressure to demonstrate a systematic, auditable, and internationally recognized approach to anti-fraud governance. Regulatory scrutiny from national authorities, combined with rising incidents of identity fraud involving RG and CNH documents, requires a structured response that aligns with global standards while addressing local operational realities.
Manual processes, fragmented controls, and reactive investigations no longer meet stakeholder expectations. You must prove due diligence in preventing, detecting, and responding to fraud across digital onboarding, credit operations, and customer service channels. The absence of a formalized anti-fraud management system exposes your institution to financial loss, reputational damage, and non-compliance penalties.
With ISO 37001 now adopted as a benchmark for anti-bribery and anti-fraud programs, institutions are expected to implement risk-based controls, documented policies, and continuous improvement mechanisms. This playbook provides the exact structure needed to design, deploy, and certify such a system, without relying on external consultants for every phase.
Cost anchor
Hiring a Big-4 consultancy to design and guide implementation of an ISO 37001-aligned anti-fraud program typically costs between EUR 80,000 and EUR 250,000. Alternatively, dedicating internal resources would require 3 full-time compliance professionals working for 6 months to develop policies, conduct assessments, build controls, and prepare for audit. This playbook delivers the same foundational structure, tools, and documentation framework for $395, one-time payment, no recurring fees.
What you get
| Phase | Deliverable | File Type | Purpose |
| Foundation | Anti-Fraud Policy Template | Word | Establish organizational commitment and scope of anti-fraud program |
| Foundation | Program Charter | Word | Define objectives, governance structure, and accountability |
| Assessment | 7 Domain-Specific Risk Assessments (30 questions each) | Excel | Evaluate fraud risks across key operational areas |
| Assessment | Document Forgery Risk Assessment Workbook (Sample Chapter) | Excel | Assess vulnerabilities in RG and CNH verification processes |
| Design | Control Framework Matrix | Excel | Map preventive, detective, and corrective controls to identified risks |
| Design | RACI Template for Anti-Fraud Roles | Excel | Clarify responsibilities across departments and roles |
| Design | Work Breakdown Structure (WBS) Template | Excel | Break down implementation into manageable tasks with timelines |
| Implementation | Employee Training Program Outline | Word | Guide development of role-based anti-fraud awareness sessions |
| Implementation | Incident Response Plan Template | Word | Define procedures for reporting, investigating, and escalating fraud cases |
| Implementation | Whistleblower Policy Template | Word | Establish secure and confidential reporting channels |
| Monitoring | Key Risk Indicator (KRI) Dashboard | Excel | Track fraud trends, control effectiveness, and investigation outcomes |
| Monitoring | Internal Audit Checklist | Excel | Validate compliance with program requirements annually |
| Evidence | Evidence Collection Runbook | Step-by-step guide to gathering and organizing audit-ready documentation | |
| Audit | Audit Preparation Playbook | Prepare for certification audit with checklists, mock interview scripts, and gap remediation steps | |
| Mapping | Cross-Framework Mapping Matrix | Excel | Align ISO 37001 controls with COSO ERM and NIST CSF components |
Domain assessments
The seven domain assessments each contain 30 targeted questions to evaluate fraud risk exposure in critical areas of financial operations. Each assessment produces a risk score, identifies control gaps, and recommends mitigation actions.
- Customer Onboarding and Identity Verification: Evaluate weaknesses in digital and in-branch KYC processes, including document validation for RG and CNH.
- Loan Origination and Credit Approval: Identify opportunities for application fraud, income falsification, and collusion in lending workflows.
- Payment Processing and Fund Transfers: Assess risks related to unauthorized transactions, social engineering, and internal manipulation of payment systems.
- Employee Access and Privilege Management: Review controls over system access, role changes, and segregation of duties in core banking platforms.
- Third-Party and Vendor Relationships: Examine due diligence, contract terms, and monitoring of fintech partners and service providers.
- Internal Reporting and Whistleblower Channels: Measure effectiveness of reporting mechanisms, case handling, and anti-retaliation safeguards.
- Incident Response and Forensic Readiness: Test preparedness for fraud investigations, evidence preservation, and coordination with law enforcement.
What this saves you
| Activity | Time Required (Traditional Approach) | Time Required (Using This Playbook) |
| Develop anti-fraud policy from scratch | 40 hours | 4 hours (customize template) |
| Conduct fraud risk assessment across 7 domains | 120 hours | 35 hours (use pre-built workbooks) |
| Design control framework and RACI | 50 hours | 12 hours (adapt templates) |
| Prepare for ISO 37001 certification audit | 80 hours | 20 hours (follow audit playbook) |
| Total estimated time saved | 290 hours | 71 hours |
Who this is for
- Compliance officers in banks and credit unions seeking to formalize anti-fraud governance
- Risk managers at fintech companies preparing for ISO 37001 certification
- Internal auditors responsible for evaluating fraud control effectiveness
- Legal and governance teams needing documented policies for regulatory exams
- Operations leads overseeing customer onboarding and identity verification
- Information security officers integrating fraud risk into cyber resilience planning
- Chief compliance officers building board-level reporting on fraud posture
Cross-framework mappings
This playbook includes a detailed mapping of ISO 37001 requirements to the following frameworks:
- ISO 37001:2016 Anti-Bribery Management Systems
- COSO Enterprise Risk Management (ERM) Framework (2017)
- NIST Cybersecurity Framework (CSF) Version 1.1
What is NOT in this product
- This is not a software tool or SaaS platform. It does not include automated document verification or AI-based fraud detection.
- No integration with core banking systems, CRM platforms, or identity verification vendors.
- Does not provide legal advice or substitute for local regulatory counsel.
- No certification body affiliation or audit services included.
- Not designed for non-financial sectors such as manufacturing or healthcare.
- Does not cover anti-money laundering (AML) program design beyond fraud-related aspects.
- No ongoing support, training, or consulting included in the base purchase.
Lifetime access and satisfaction guarantee
You receive one-time download of all 64 files with no subscription, no login portal, and no expiration. Store the files in your internal knowledge base or compliance repository. If this playbook does not save your team at least 100 hours of manual compliance work, email us for a full refund. No questions, no friction.
About the seller
The creator has 25 years of experience in regulatory compliance and risk management, with deep expertise in financial services across Latin America. They have analyzed 692 compliance frameworks and built 819,000+ cross-framework mappings to help institutions reduce duplication and streamline implementation. Their resources are used by over 40,000 practitioners in more than 160 countries, focusing on practical, audit-ready solutions for complex regulatory environments.
Need this for your team? We offer site licenses starting at $2,500 for up to 25 users. Reply to this page or DM Gerard directly on LinkedIn.