Red Flags of Infrastructure Fraud for Investigators Course

Module 1: Purpose and Scope of the Infrastructure Investment and Jobs Act (IIJA)

• Summarize the IIJA’s aims, scale ($1.2T), and five-year funding horizon.
• Identify major funded sectors (roads/bridges, transit, rail, energy, water, broadband, resilience).
• Review the high-level spending plan and responsible federal agencies.
• Note links to the American Rescue Plan and implications for workforce/readiness.

Module 2: Investigator’s and Reviewer’s Responsibility for Fraud Awareness and Detection

• Clarify responsibilities under GAGAS/Yellow Book, CIGIE, AICPA (SAS 22/99), and related laws.
• Define fraud and elements; contrast fraud with waste and abuse.
• Apply professional skepticism: assess risk, controls, and environmental red flags throughout engagements.
• Understand reporting expectations for internal control, compliance issues, and suspected fraud.

Module 3: Fraud Schemes and Red Flags

• Recognize common IIJA fraud types: defective labor/pricing, product substitution, billing schemes.
• Detect collusion (bid-rigging, rotation, suppression, market division) using bidding/price patterns.
• Spot operational red flags: poor documentation, unusual trends, fictitious vendors, altered records.
• List evidence sources to corroborate suspicions (timecards, invoices, delivery records, payroll data).

Module 4: Federal Statutes and Remedies on Fraud Applicable to IIJA Projects

• Link schemes to statutes: 18 U.S.C. §§ 371 (conspiracy), 641 (embezzlement), 1001 (false statements), 1341/1343 (mail/wire fraud), 201 (bribery), and FCA.
• Introduce RICO, antitrust (bid-rigging/price-fixing), and program-specific offenses.
• Differentiate criminal, civil, and administrative tools: PFCRA, suspension/debarment, and referrals.
• Outline evidentiary needs to support prosecutions or administrative actions.

Module 5: Cases of Infrastructure Fraud

• Study recent prosecutions (e.g., DBE pass-throughs, bid rigging, under-application of materials) and penalties.
• Connect case red flags to earlier modules to reinforce detection techniques.
• Discuss how fast-moving funds and weak controls enable repeatable schemes.
• Capture lessons learned to strengthen prevention, detection, and referrals.