FRA0107

Written evidence submitted by City of London Police

We were grateful for the opportunity to give evidence to your committee on 28th February. We are writing to provide further information on some matters raised during the session and additional points which may be of interest to the Committee. In particular, we would like the opportunity to outline the projected improvements of the Action Fraud system transformation, and the scale of the programme being undertaken.

National Lead Force

During the session, the Committee asked the panel what the role of the City of London Police was in responding to fraud, and why the City of London Police are best placed to deliver this.

The City of London Police is the national policing lead for fraud and the Nation Police Chiefs’ Council lead for economic and cyber crime. The National Lead Force’s mission is to protect the public and reduce the harm from fraud by providing national leadership and coordination services that are valued by policing and meet the needs of victims.

The City of London Police was appointed the National Lead Force for Fraud following the Attorney General’s Review of Fraud in 2006. The City Police’s appointment reflected the depth of expertise and priority placed on fraud by the force. The report noted that the “difference in performance between the City Police and the rest of the country reflected the different priority assigned to fraud. In the City, fraud is a priority because its police authority, the City of London Corporation and its major stakeholders in the City Financial insist upon this.”

The City Police already held a leading role in respect to fraud policing, with the City Police leading the National Fraud Working Group, acting as regional lead force for London and the South East, and the then-Commissioner being Chair of the Association of Chief Police Officers Economic Crime Portfolio.

In line with the Attorney General’s recommendation that the National Lead Force act as a “Centre of Excellence for fraud investigations” the City Police continue to provide expertise and specialism to improve fraud policing across the country. It has built effective collaborations with industry to address specialist crime types, and developed an Economic and Cyber Crime Academy that upskills policing and non-policing partners in how to effectively investigate and deal with economic crime and fraud.

National Lead Force responsibilities include:

• Setting the national fraud policing strategy

• Leading and coordinating the police’s 4Ps response to fraud (using the most effective mix of ‘pursue’, ‘protect’, ‘prevent’, ‘prepare’)

• National fraud and cyber crime reporting and recording (Action Fraud)

• Triage, analysis and allocation of crime reports to policing and other law enforcement (National Fraud Intelligence Bureau)

• Advisory support for forces investigating complex fraud (National Lead Fraud Operations)

• Investigation of nationally significant, serious and complex fraud (National Lead Fraud Operations)

• Workforce development, including training, continuous professional development and dissemination of good practice across police forces (Economic and Cyber Crime Academy).

The National Lead Force Operations team sits within the City of London Police. This team undertakes complex fraud investigations that have either been identified through intelligence development, reported into Action Fraud or escalated up by local and regional teams who do not have the expertise to deal with them.

There is also a dedicated team that supports forces nationally to improve performance and promote best practice, as well as centrally co-ordinate intelligence led investigations out into specialist teams across the country.

As recognised by the Attorney General’s report, collaboration with the financial and professional services industry is a key component of the City Police’s work. The City of London Police is based in the heart of the financial sector in the UK, facilitating close engagement with the financial and professional services sector, with whom the force work in tandem to tackle economic crime. The City of London Police and the City of London Corporation, through its Police Authority Board (PAB), provide a bridge for law enforcement into financial institutions and, importantly, the financial technology (fintech) sector.

With the support of the PAB and stakeholder groups such as UK Finance, the City Police works with the private sector in the pursuit and prevention of the perpetrators of fraud. This includes units funded by the private sector, including the Insurance Fraud Enforcement Department (IFED), an innovative policing unit entirely funded by the insurance industry to combat insurance fraud. IFED tackles various types of insurance fraud, from cross-border organised crime groups using professional enablers of fraud to opportunistic insurance fraudsters. The majority of IFED’s cases focus on motor insurance fraud, but the unit deals with the wide spectrum of insurance fraud, including: life, travel, property, household, medical, and professional enablers operating in these areas. The operationally independent unit was established in 2012, with funding from the Association of British Insurers (ABI).

Funded by the banking industry and based in the Square Mile at financial services trade association UK Finance, the Dedicated Card and Payment Crime Unit (DCPCU) is a joint Metropolitan Police Service/City of London Police team, with the sole purpose of combating crimes associated with banking and payments. DCPCU’s objectives are to proactively pursue fraudsters who cause the most economic harm, to disrupt organised crime groups, opportunistic fraudsters and online threats, and to use the media to help partners develop their counter-fraud capabilities.

Action Fraud

Committee members asked the panel about the progress of the transformation programme delivering the replacement service for Action Fraud.

City of London Police deliver the national reporting service for fraud and cybercrime; Action Fraud. Due to acknowledged and recognised flaws within the current service, a transformation programme to replace it is underway.

Replacing Action Fraud is an ambitious and complex programme of work, and it is crucial to get it right to give victims the confidence that their case will be dealt with properly. The replacement service will be delivered in 2024.

Work is already underway with the commercial suppliers to make improvements that will make a real difference. We are:

• Introducing systems to send cases to forces faster and provide better progress updates on cases to victims.

• Providing forces better data on victims in their area to help them safeguard and provide bespoke prevention and protect advice. 

• Developing a new user-friendly, accessible website where the public can report fraud and cybercrime to improve victim experience and offer simpler pathways to access further support and guidance. 

• Significantly enhancing capacity and capabilities to achieve a range of outcomes across Pursue, Protect, and Prevent.

• Building a service that uses data, has the ability to share and collect bulk data from government, law enforcement and industry to improve intelligence picture nationally.

Staff numbers will increase, growing the contact centre, victim care service, and the teams who review and assess the reports coming in. This, alongside radical improvements in technology, will provide an improvement in outcomes for victims and satisfaction with the service. Progress made so far includes:

• Supply Chain has been fully procured and is working to design and build services.

• Trauma informed victim centric website is going through user testing and enhancements.

• Functioning new crime management, intelligence and data platform and system

• Revised and tested new procedures for prioritisation of cases focused on vulnerability/harm and solvability of the case, and new alternative outcome channels.

• An enhanced cyber reporting service respecting the different needs of cyber incidents on business victims.

• A design brief and strategy for the development of a new replacement name and brand for Action Fraud

• A revised target operating model within City of London Police to deliver an end to end one service approach.

The service outlined in the Full Business Case will be delivered across the first 18 months of the Go Live date, and we are also operating a Continuous Improvement approach, so enhancements will continue throughout the initial 5-year life of the new service, with annual continuous improvement funding secured in the business case.

Policing of economic crime

The panel were asked about local policing’s role in the response to fraud nationally, and how this would best be delivered.

The scale of the threat of fraud means that a varied and large-scale response is needed to pursue fraudsters, support victims and prevent people becoming victims in the first place. For policing, this means that there are requirements from teams on a local, regional and national level.

Preventing crime has to be at the heart of modern policing and the response to fraud is no different, frontline officers have a key role to play spreading ‘protect’ advice at the first point of contact with the public, protecting victims from the harm and threat of fraud.

It is the City Police’s view that any suggestion to remove local policing from the fraud response would risk creating a gap between policing and local victim support; severing a key delivery arm of protect advice to local communities and removing a key source of intelligence on a crime type often linked with serious organised crime and local criminal activity.

Without local policing’s contribution, it is unlikely that low-value, high volume frauds would be investigated (as they would not be deemed sufficient priority), meaning many more victims would not see a justice outcome for their crime.

Our key requests to continue to improve the law enforcement response to fraud:

• Continuity of funding to sustain and deliver resource growth and the ability to forward plan beyond shorter periods.

• Greater accountability on policing to deliver an appropriate response and prioritisation to fraud. We fully support the inclusion of fraud within HMICFRS inspections – whether that be to incorporate it into PEEL inspections or for there to be a repeated thematic inspection.

• We would like to see other parts of the system fulfilling their obligations to prevent fraud and for there to be accountability where these are not met. This could be through tighter regulation with consequential penalties.

We would be more than happy to provide the Committee with any further information they may find useful, and we would like to take this opportunity to offer the Committee and its staff the opportunity to visit the City of London Police for a further insight into its work as national