ACFE Insights Blog

When Reputation Becomes an Opportunity for Fraud

Explore how brand trust can become a reputational smokescreen that enables opportunistic fraud, such as quality-washing and fraud-washing, and what to look out for. 

By Dr. Princely Dibia, Ph.D., CFE, FHEA October 2025 Duration: 8-minute read
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Trusted brands inspire loyalty. But that loyalty can also create the perfect conditions for opportunistic fraud. Worse still, they can become the perfect camouflage for sophisticated fraud. 

Consider an organization celebrated for impeccable customer service and top-quality goods. It's a darling of industry awards, a household name and a textbook case study in lean management efficiency. However, behind the scenes, its so-called lean strategy is selectively applied. Controls are piecemeal or siloed; counter fraud and loss prevention policies are vague; and substandard products occasionally “slip through” the value chain.  

In my recent research on fraud risks in a global retail organization practicing lean management, I found that brand trust can serve as both a shield and a sword: a shield against consumer skepticism or suspicion, and a sword for quietly reducing internal vigilance and cutting corners, under the guise of operational excellence or goodwill. In effect, brand trust can inadvertently enable opportunistic fraud, creating vulnerabilities that range from product misrepresentation to elaborate tax scams, often concealed behind a reputational smokescreen. 

Quality-Washing and Fraud-Washing 

Compared to greenwashing in environmental marketing, two distinct but related patterns emerge in corporate misconduct: 

  1. Quality-washing: Presenting a false or exaggerated image of product quality, operational efficiency or lean management commitment.
  2. Fraud-washing: Misrepresenting counter-fraud, ethics or integrity commitments to shield or downplay harmful practices. 

In both patterns, claims often involve aspects of the following: 

  • Vague or exaggerated lean or loss prevention messaging, including misleading assertions of efficiency, quality control or defect-free products and delivery. 
  • Selective highlighting of minor improvements or ethics initiatives to overshadow significant defects or risks.
  • Ethics-signaling imagery and slogans without substantive policy or operational backing. 

Such tactics lull stakeholders into complacency, enabling substandard goods to be passed off as premium, adulterated products to enter the market or fraudulent activities to be hidden in plain sight. 

Trusted Brands as Reputation Shields  

Several high-profile cases illustrate how brand prestige can create a cognitive and regulatory blind spot: 

  • Toyota’s Sudden Unintended Acceleration: Concealed safety defects from U.S. regulators, consumers and the public; delayed recalls; and issued misleading statements. Toyota’s lean values and reputation for “zero defects” shielded it until investigations led to a $1.2 billion fine and lasting reputational harm (Austen-Smith et al. 2017; Cole, 2011; Greto et al. 2010; Quelch et al. 2011) 
  • Volkswagen Dieselgate: Marketed as meeting strict emissions standards while secretly deploying “defeat devices” to cheat regulatory tests (Barth 2022; Ewing, 2017; Hasan et al. 2023). 
  • Food Industry Mislabeling: Premium “organic” or “pure” goods cut with cheaper substitutes, concealed under strong brand reputations (Agnoli et al. 2016; Barnard and O’Connor 2017; Bitzios 2017; Cox et al. 2020).
  • Tech Sector Security Claims: “End-to-end encryption” claims masking partial or flawed implementations (Agnihotri and Bhattacharya 2022; Chaudhri and Yue, 2021; Edelman, 2010; Henry et al. 2021; Segalla and Rouzies 2023). 

In each example, brand trust acted as a protective layer and delayed detection. While short-term objectives may have included protecting profits or brand equity, eventual exposure caused far greater financial, legal and reputational losses than timely corrective action would have. 

Extension into Corporate Tax Fraud 

Reputation-driven washing behaviors are not confined to consumer-facing operations; they can also intersect with corporate tax crimes.  

Gift aid scams involve fraudulent claims for charitable donations, often routed through reputable foundations, to gain illegitimate tax relief. In this instance, organizations promote corporate social responsibility initiatives (e.g., charity tie-ins) that mask operational shortcomings while leveraging brand trust to validate inflated or falsified donation figures. Enablers in this scam may include the public trust in the brand’s social mission, reliance on symbolic gestures over substantive proof, or satisfaction in compliance checks. 

Another example involves eco-investment schemes, when fabricated or exaggerated green projects are marketed to socially conscious investors and stakeholders for tax benefits — with little or no real environmental impact. Organizations market lean or waste-free production claims and narratives, while operations waste resources or mix inferior inputs, selectively publicizing small sustainability wins. An enabler in this scheme can be organizations exploiting consumer demand for ethical/eco products, vague and unverifiable marketing or bounded rationality in leadership prioritizing public and social impact over audit integrity. 

In both examples, trusted brand positioning and public perception serve as a cloak for deception and a likely basis for organizations and its decision-makers to rationalize such behaviors, albeit bounded by thinking errors and exploitative. 

Bounded Rationality and Fraud Risk 

According to Herbert Simon’s theory of bounded rationality (Simon, 1979; Simon, 1991; Simon, 1997), decision-makers operate under three major constraints: 

  1. Limited information: They rarely see the full picture. In most organizations, operational leaders rely on curated dashboards, not raw defect data, which may hide underlying irregularities. 
  2. Cognitive limitations: Human brains filter and simplify complex realities.
  3. Time pressures: Fast decisions can override fully optimal ones. 

In trusted brand environments, these limits are compounded by cognitive biases such as: 

  • Halo effect: “We’ve always been good, so this must be fine.” 
  • Moral licensing: “We do so much good, a little compromise won’t hurt.” 
  • Availability heuristic: Recent awards or CSR efforts outweigh ongoing control gaps.
  • Satisficing: Settling for ”good enough” lean adoption or compliance that passes casual inspection, rather than following recommended holistic models and achieving full operational integrity. 

Behavioral psychology literature on contaminated mindware, heuristics and biases details how these shortcuts often feel justified internally, yet they can result in reputationally shielded misconduct. The faulty reasoning patterns may also develop and become embedded in organizational culture, making certain fraud-enabling practices seem normal. 

What Fraud Examiners Should Watch For 

  • Check substance, not just story: Counter-fraud claims should have documented policies, cross-departmental reach and measurable enforcement. Scrutiny should be applied on the actual mechanics behind gift aid or eco-investment claims.
  • Follow the control chain and verify: Does the organization's lean model apply everywhere or only in showcase processes? Is loss prevention applied only selectively?
  • Narrative Audit: Compare marketing claims with operational realities.
  • Apply forensic analytics: Monitor for anomalies such as repeated donor identities, inflated valuations or unrealistic ROI projections.
  • Audit trust-laden spaces: The more loyal the customer base, the more tempting the environment for undetected deviation. Apply extra scrutiny where brand loyalty is strongest.
  • Challenge halo-driven assumptions: High reputation should raise, not lower, investigative curiosity and rigor.
  • Bias Mapping: Identify where leadership decision-making reflects satisficing or moral licensing. 

Trust and reputation are not immunity from fraud risk; they can be enablers for it. For fraud examiners, the task is looking beyond the brand’s narrative to assess whether lean, ethical and green claims are either genuine or a front and opportunity for more elaborate schemes. 

References: 

Agnihotri, A., & Bhattacharya, S. (2022). Meta: A new direction to leadership [Ivey case study No. W27712]. Ivey Publishing, Ivey Business School, Western University. 

Agnoli, L., Capitello, R., De Salvo, M., Longo, A., & Boeri, M. (2016). Food fraud and consumers’ choices in the wake of the horsemeat scandal. British Food Journal, 118(8), 1898-1913. 

Austen-Smith, D., Diermeier, D., Zemel, E., Diermeier, D., & Merkley, G. (2017). Unintended acceleration: Toyota’s recall crisis. Kellogg School of Management Cases, 1-16. 

Barnard, C., & O'Connor, N. (2017). Runners and riders: The horsemeat scandal, EU law and multi-level enforcement. The Cambridge law journal, 76(1), 116-144. 

Barth, F., Eckert, C., Gatzert, N., & Scholz, H. (2022). Spillover effects from the Volkswagen emissions scandal: An analysis of stock and corporate bond markets. Schmalenbach Journal of Business Research, 74(1), 37-76. 

Bitzios, M., Lisa, J. A. C. K., Krzyzaniak, S. A., & Mark, X. U. (2017). Country-of-origin labelling, food traceability drivers and food fraud: Lessons from consumers’ preferences and perceptions. European Journal of Risk Regulation, 8(3), 541-558. 

Chaudhri, V., & Yue, T. (2021). Teaching note – Facebook’s reputation: Trials and tribulations [Instructor teaching note RSM063]. Rotterdam School of Management Case Development Centre, Erasmus University. 

Cox, A., Wohlschlegel, A., Jack, L., & Smart, E. (2020). The cost of food crime. Food Standard Agency (Research Project code: FS 301065). 

Cole, R. E. (2011). What really happened to Toyota?. MIT Sloan Management Review. 

Edelman, B. (2010, January 27). Google’s privacy breach: Lessons for companies. Harvard Business Review. https://hbr.org/2010/01/googles-privacy-breach-lessons 

Ewing, J. (2017). Engineering a deception: What led to Volkswagen’s diesel scandal. The New York Times, 16.: https://www.nytimes.com/interactive/2017/business/volkswagen-diesel-emissions-timeline.html 

Greto, M., Schotter, A., & Teagarden, M. B. (2010). Toyota: The accelerator crisis. Glendale, AZ: Thunderbird School of Global Management. 

Harvard Business Publishing Education. (2023). The ethics of managing people’s data [HBR Educator case study]. Harvard Business School Publishing. 

Hasan, I., Noth, F., & Tonzer, L. (2023). Cultural norms and corporate fraud: Evidence from the Volkswagen scandal. Journal of Corporate Finance, 82, 102443. 

Henry, B., Roulet, A., & Stabile, M. (2021). Teaching note – WhatsApp: Tech watchdogs collide with tech giants [INSEAD case No. IN1779]. INSEAD Business School. 

Jack Ewing, “Engineering a Deception: What Led to Volkswagen’s Diesel Scandal,” New York Times, March 16, 2017, 

Segalla, M., & Rouzies, M. (2023). The ethics of managing people’s data [HBR Educator case study]. Harvard Business School Publishing. 

Simon, H.A. (1979a). Models of Bounded Rationality: Empirically Grounded Economic Reason. Cambridge, MA: MIT Press. 

Simon, H. A. (1991). Bounded rationality and organizational learning. Organization science, 2(1),125-134. 

Simon, H.A. (1997a). Administrative Behavior. (4th ed.). New York, NY: The Free Press.Simon, H.A. (1997b). Models of Bounded Rationality: Empirically Grounded Economic Reason, Vol.3. Cambridge, MA: MIT Press. 

Quelch, J., Knoop, C. I., & Johnson, R. (2011). Toyota Recalls (A): Hitting the Skids. HBS Case 9-511-016. 

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