Here is a fact that should sit uncomfortably with any government that says it takes fraud seriously. The most authoritative global picture of occupational fraud — how much is stolen, by whom, how it is caught and what it costs — does not come from a state, a treasury or a police force. It comes from a private membership association in Austin, Texas.
The Association of Certified Fraud Examiners was founded in 1988. It is a professional body, funded largely by its members — more than ninety thousand of them, across some 180 countries. It sets the leading professional credential in the field, the Certified Fraud Examiner. It runs much of the training. And every two years it publishes the Report to the Nations, the largest study of real, investigated occupational fraud in the world.
I want to be careful here, because this is not a criticism of the ACFE. Its work is rigorous and genuinely useful; I have relied on it myself. That is rather the point. The problem is not that a private body does this work well. The problem is that, to a remarkable degree, only a private body does it at all.
What the data actually shows
Look at what that one report tells us. In its 2024 edition, built from 1,921 real cases across 138 countries, the median loss was around US$145,000 — and for small organisations, those with fewer than 100 employees, the median was about US$141,000, among the highest of any size band. The single most effective way fraud came to light was a tip, in roughly 43% of cases; the external audit that so many organisations treat as their safety net caught only about 3%. The 2026 edition, drawn from 2,402 cases across 143 countries, put total reported losses above US$3.4 billion and the median loss at around US$104,000, with tips still leading detection.
That is an extraordinary evidence base. It shapes how investigators, auditors and boards around the world think about fraud. And it is produced, curated and owned by a private association, on a subscription model, as a professional service to its field.
Why that should worry a government
If the scoreboard, the rulebook and much of the training in a field this costly are privately held, where is the state?
In Australia, there is no equivalent authoritative public measure of what fraud costs ordinary people and small businesses — no standing national account of the scale of the problem, the way it is detected, or what happens to the victims afterward. And what a country does not measure, it does not prioritise, and does not fund. Fraud slips down the list precisely because no public institution owns the number.
This is not an argument that government should crowd out professional bodies. A members' association can often move faster and more expertly than a department, and that agility is worth keeping. But measurement and coordination of a harm this large are a public responsibility. When the referee is a private club, the public sector is one step removed from a problem it is supposed to be policing — and the people who fall into that gap are those least able to climb out of it: individuals and small businesses with modest, uninsured losses.
From measuring the problem to answering it
Measurement is only the first step. The second is doing something with it. If we accept — and the data makes it hard not to — that fraud is common, expensive and disproportionately borne by those least able to absorb it, then the state's job is not just to count the losses. It is to build fairer ways for victims to trace and recover their money, and to coordinate the agencies that each hold one corner of the problem.
That is the harder, more important reform, and I have written about it separately: giving an ordinary fraud victim a supervised path to the records of their own money, instead of a wall and a court case they cannot afford. But it starts here, with a question governments should be embarrassed to have left unanswered for so long.
If the best global picture of fraud is produced by a private club in Texas, that is not a credit to the club. It is a measure of how far the public sector has yet to step up — and a good reason to ask it to.
Commentary by Daniel Baulch, written in a personal capacity. Figures: ACFE Report to the Nations (2024 and 2026 editions).