This case describes the implementation of a fraud and corruption control policy initiative within the Victorian Department of Education and Early Childhood Development (the Department) in Australia. The policy initiative was administered and carried out by a small team of fraud control officials, including the author of this article, in the Department. The policy context represents a large, devolved and fragmented governance and accountability system. This case highlights the complexity of the policy initiative, the contextual constraints that challenged the implementation, and the pragmatic approach taken by the Department. While there are no easy solutions for fraud and corruption control or proven models to follow, this case presents helpful lessons for the professionals working in large and devolved education systems.