To detect an emerging risk of potential fraud, an organization should establish an anonymous platform for reporting suspected unethical behaviors. Such platforms enable employees and others to report suspicious activities without fear of retaliation, facilitating early detection of fraud and other unethical conduct within the organization.
Best practices in fraud risk management and internal controls.

According to the standards and practices of internal auditing, the internal audit function is primarily responsible for providing an independent and objective assurance and consulting service aimed at adding value and improving an organization's operations. If internal auditors were tasked with developing controls in business procedures, it could compromise their objectivity. Objectivity is crucial as it allows auditors to carry out audits impartially and without bias. Involvement in control creation could lead internal auditors to later audit their own work, which is a conflict of interest and undermines the principle of independence and objectivity as set by the Institute of Internal Auditors (IIA).
The Institute of Internal Auditors (IIA) - International Standards for the Professional Practice of Internal Auditing

The internal audit activity contributes to the implementation of the risk management framework by assisting with the prioritization of identified risks. This is done through the provision of assurance and consulting services that help the organization to understand which risks are most significant and how they should be addressed based on their impact and likelihood.
IIA Performance Standards on risk management; literature on internal audit's role in risk assessment and management.

An evaluation of the current performance and compensation program would be the most effective control to address the underlying cause of fraudulent behavior described. The pressures from unrealistic targets and aggressive monitoring likely encouraged employees to engage in fraudulent account openings. By evaluating and potentially revising these targets and the associated compensation schemes, the bank could mitigate the pressures that lead to such unethical behaviors.
Standards on the role of internal control systems in preventing and detecting fraud, including guidance on managing performance and compensation to align with ethical standards.

The internal auditor's objectivity is best protected in the scenario where a former human resources manager conducts an effectiveness review of the appointment and termination process six months after transferring to the internal audit activity. This duration allows for a cooling-off period, which helps to mitigate potential conflicts of interest or biases related to the auditor's former role and responsibilities.
IIA Standards regarding objectivity and conflicts of interest.