With reports suggesting that more than 1,600 companies and RM45 million may be involved, the recent Daya Kerjaya 2.0 investigations have attracted significant public attention.

Many assume that in a false claim investigation, the key question is simply: Who received the money?

Not necessarily.

In investigations involving alleged offences under section 18 of the MACC Act 2009, or related offences such as section 471 of the Penal Code, the focus is often not limited to who ultimately benefited from the claim.

Instead, the focus of the investigation is often on who prepared, verified, approved, submitted (through the relevant portal), or used the documents in question, and whether the representations made in those documents were false, misleading, or relied upon as genuine.

This is what makes false claim investigations particularly complex. A single claim process may involve directors, HR personnel, accountants, company secretaries, and agents, each playing a different role.

As with many white-collar crime investigations, the earliest stage is often critical. The available documents, surrounding circumstances, and explanations provided by the individuals involved may influence how investigators assess each person’s role and level of involvement.

In complex investigations involving multiple parties and documents, the distinction between a witness and a suspect is not always as straightforward as many assume.