Spotting What’s Missing In ACCA’s “Combatting Fraud In A Perfect Storm”

A review of the Association of Chartered Certified Accountants (ACCA) recent report, Combatting Fraud in a Perfect Storm found some notable omissions - especially from an intelligence, cyber-fraud, and open-source intelligence (OSINT) perspective:

• While ACCA mentions investment scams, it doesn’t dig into boiler-room fraud or cold-call investment schemes as a distinct typology - despite the significant losses these variants can cause.

• There’s only very general talk of “intelligence” in detection, but no practical, methodological breakdown of investigative intelligence, OSINT, or how organisations can build intelligence capabilities to help combat fraud.

• The term OSINT is entirely absent, meaning the report misses a key analytic tool for modern fraud investigators.

• In the appendices (A–D), there is no reference to boiler-room fraud, OSINT, or intelligence-gathering techniques - this is an opportunity missed, given that most fraud investigators routinely rely upon OSINT in one form or another.

Why This Matters and How OSINT plus Artificial Intelligence (AI) Can Help

That’s where the work we do at The Coalition of Cyber Investigators (the Coalition) comes in. Our recent article, “How AI and OSINT Tools Can Uncover Fraud Risk in UK Companies - Why Verification Matters”, is a powerful counterpoint. It highlights:

• How AI-powered OSINT helps uncover hidden fraud risks in UK-registered companies (even those with seemingly innocent or dormant profiles).

• The importance of verification: one investigation showed how AI-generated leads - initially pointing to a suspected fraudster - were wrong, because they came from cached or incorrectly attributed data.

• The role of breach-data intelligence: using breach records (from infostealer malware), we traced usernames, devices, and historical breaches — revealing a more complex and suspicious network behind a clean corporate facade.

Take-Aways

1. Anti-fraud frameworks (like ACCA’s) must evolve to explicitly include intelligence disciplines, not just high-level risk categories.

2. OSINT and AI are not magic: human verification remains critical to avoid misattribution, false positives, and flawed conclusions.

3. Organisations, compliance teams, and fraud investigators should learn from real-world intelligence practices - like those we use at the Coalition - to strengthen their fraud detection and threat assessment capabilities.

4. Given its global standing, ACCA can play an important role in shaping good practice in OSINT investigations, building collaborative partnerships, and supporting the development of globally agreed standards.

Find out more by checking out the full article here: How AI and OSINT Tools Can Uncover Fraud Risk in UK Companies – Why Verification Matters from The Coalition of Cyber Investigators.

Authored by: The Coalition of Cyber Investigators

Paul Wright (United Kingdom) & Neal Ysart (Philippines)

©2025 The Coalition of Cyber Investigators. All rights reserved.

The Coalition of Cyber Investigators is a collaboration between

Paul Wright (United Kingdom) - Experienced Cybercrime, Intelligence (OSINT & HUMINT) and Digital Forensics Investigator;

Neal Ysart (Philippines) - Elite Investigator & Strategic Risk Advisor, Ex-Big 4 Forensic Leader; and

Lajos Antal (Hungary) - Highly experienced expert in cyberforensics, investigations, and cybercrime.

The Coalition unites leading experts to deliver cutting-edge research, OSINT, Investigations, & Cybercrime Advisory Services worldwide.

Our co-founders, Paul Wright and Neal Ysart, offer over 80 years of combined professional experience. Their careers span law enforcement, cyber investigations, open source intelligence, risk management, and strategic risk advisory roles across multiple continents.

They have been instrumental in setting formative legal precedents and stated cases in cybercrime investigations and contributing to the development of globally accepted guidance and standards for handling digital evidence.

Their leadership and expertise form the foundation of the Coalition’s commitment to excellence and ethical practice.

Alongside them, Lajos Antal, a founding member of our Boiler Room Investment Fraud Practice, brings deep expertise in cybercrime investigations, digital forensics, and cyber response, further strengthening our team’s capabilities and reach.

The Coalition of Cyber Investigators, with decades of hands-on experience in cyber investigations and OSINT, is uniquely positioned to support organisations facing complex or high-risk investigations. Our team’s expertise is not just theoretical - it’s built on years of real-world investigations, a deep understanding of the dynamic nature of digital intelligence, and a commitment to the highest evidential standards.