Investigating financial crime in Kenya’s government takes technical skill, agility and plenty of on-the-ground practical experience. Just as important, though, is a commitment to ethics and integrity, as that is the key to fraud prevention, according to Christine Ombaka FCCA, an investigator at Kenya’s Ethics and Anti-Corruption Commission (EACC).
‘This is a fight that starts with the individual,’ Ombaka says. ‘We start nurturing ethics and integrity from a young age. We have integrity clubs in schools, where we emphasise the importance of ethics as we grow up, along with the importance of honesty – because we know the younger generation are going to be the future leaders.’
‘Ethical behaviour also needs to be in the small things you do’
She adds: ‘If you are ethical, you will not commit fraud because you’re able to restrain yourself and not give into your areas of weakness or your desires, or take advantage of opportunities in the system. Ethical behaviour needs to be in your day-to-day practice and in the small things you do. That’s how you grow to be an ethical person. That’s how you train those around you to be ethical.’
Starting out
After graduating with degrees in economics and accountancy and qualifying with ACCA, Ombaka joined Deloitte East Africa in 2013. At the Big Four firm, she worked in forensic accounting, fraud investigations and compliance audits, having gained early experience in dispute resolution and fraud investigation during an HR internship at a bank as an undergraduate.
Deloitte was, she says, a transformative experience. ‘I gained a lot of exposure to fraud investigations, financial analysis and compliance audits across many industries.’
With client engagements across East, Southern and West Africa, she also amassed experience of different working cultures and regulatory regimes. It all served to sharpen her technical skills and instil the independence and integrity critical to anti-corruption work.
The big switch
In 2019, after six years at Deloitte, she decided to challenge herself with a change of direction. Keen to use her skills and experience to contribute to Kenya’s future, she joined the Ethics and Anti-Corruption Commission (EACC), which is mandated to combat and prevent corruption and economic crimes through law enforcement, preventive measures, public education, and the promotion of integrity and ethical standards.
‘We do a lot of awareness raising and anti-corruption training’
Ombaka’s work at the EACC focuses on probes into and the financial analysis of corruption and economic crime in government departments and public sector bodies. ‘Primarily my role is around investigations,’ she says. ‘We do have a lot of technical skills that are required, and that’s why it is important for accountants to have technical expertise so that we can deploy the different skillsets required to conduct an investigation effectively.’
Importantly, the EACC’s mandate includes awareness raising and fraud prevention efforts. ‘We do a lot of public education and sensitisation to increase awareness and to curb corruption,’ Ombaka explains. ‘We also have a prevention arm that aims to build resilience within public sector entities. We review processes and procedures, carry out risk assessments, see where the exposures are, and give recommendations on how they can tighten controls.’
Fraud fight
The EACC’s investigatory work includes looking into procurement fraud, illicit financial flows and payroll fraud.
Procurement fraud in public contracting is an area of particular concern due to the potentially large sums involved. Common concerns include contracts being awarded to unqualified individuals, inflated pricing or conflicts of interest. Payrolls inflated with non-existent workers is another area of vulnerability.
In cases of illicit financial flows or money laundering, tracing assets can be a delicate and complex task, she says. The EACC works with other entities to follow the money. ‘This is an area where we’re currently getting a lot of support. There is a lot of legislation being reviewed and additional messures being put in place to help support the fight against corruption when it comes to these vulnerable areas.’
‘We have committed to tech-intensive anti-fraud strategies’
The 2025 passing of a Conflict of Interest Act to support the identification of beneficial owners and prevent public officials from trading with the government (their employer) should further reduce Kenya’s exposure to this form of financial crime.
Technology and digital forensics play an increasing role in investigations, Ombaka says, and teams are being trained to support digital fraud prosecutions with credible evidence.
Government entities, meanwhile, are being migrated to more transparent and traceable systems, including one for procurement. ‘The Commission, through our strategic plan, has committed to these technology-intensive strategies where we have systems in place and we upskill teams to be able to investigate frauds.’
Nurturing ethics
Fraud, she says, is a matter of character. ‘As an investigator, even when I interact with people during my day-to-day job, I always try to understand what the exposures were, what the vulnerabilities were. There is the principle of the fraud triangle, where there’s opportunity, there’s pressure and there’s the motivation.’
‘Being principled is a factor in career success’
She takes prides in working to mainstream ethics in the public sector. As well as participating in the EACC’s outreach work, she mentors ACCA students. In both activities, she gets to interact with a younger generation and hear the challenges they face. ‘From when they’re looking for jobs right through to sitting exams, we encourage them in the importance of ethics and doing things right, and we hope they get to see the importance of being principled as a factor for success.’
When Ombaka thinks about her aspirations, she always thinks about the privilege of being in a position where she can impart change. ‘I’ll use whatever position I have to influence those around us to make the right decisions,’ she says.
