Tag: Serious Fraud and Economic Crime

New national ‘Report Fraud’ service launches

Posted on by Caitlin Duncan

Report Fraud, the UK’s national reporting service for cyber crime and fraud, has launched as the central platform for submitting fraud-related reports. The service replaces Action Fraud as the primary reporting route for individuals and organisations across England, Wales and Northern Ireland. It became operational in December 2025, with a full public rollout in January 2026.

Operated by the City of London Police, Report Fraud aims to offer a clear, modern and streamlined reporting experience for victims of phishing, ransomware, business email compromise, CEO fraud and other online scams.

What the new service provides

Report Fraud introduces updates to the way fraud and cyber crime reports are submitted and managed:

  • Structured reporting – A guided process supports users in submitting relevant information in a consistent format.
  • Guidance and information – Reporters are provided with information on what types of fraud and cyber crime can be reported, along with details on what happens after submission.
  • Victim support information – Reporters receive guidance and signposting to support services where applicable.
  • National crime analysis – Submitted reports are incorporated into a centralised analysis function used to identify trends, patterns and repeat activity at a national level.

How reports are processed and used

Reports submitted through Report Fraud are reviewed and handled as part of the national fraud reporting framework:

  • Intelligence assessment – Reports are assessed to identify links, patterns or indicators associated with organised or harmful criminal activity.
  • Dissemination – Where reports meet established criteria or are linked to other cases, they may be shared with the relevant police force for further consideration.
  • Reporter updates – In cases where police action follows, reporters may receive updates or a point of contact in accordance with the Victims’ Code of Practice.
  • Ongoing intelligence use – Reports that do not result in immediate investigation are retained for intelligence purposes, supporting monitoring activity, disruption measures, or future investigations.

National reporting for fraud and cyber crime

Cyber crime and fraud are among the most prevalent and economically damaging crimes in the UK, costing individuals and organisations billions each year. Report Fraud intends to provide a single national gateway for reporting and intelligence that strengthens collaboration between the public, businesses, law enforcement and other agencies.

Further information, including how to submit a report, is available at reportfraud.police.uk.

Fraud investigations by ESA Risk

If you suspect that a fraud has occurred within your business and need advice or support on the next steps, we’re here to help.

Additionally, we can help you to prevent fraud from occurring through manager and employee training and resource provision.

For further details, contact our Client Services team, at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

 

Inside the Insolvency Service’s 2026–2031 Investigations and Enforcement Strategy

Posted on by Caitlin Duncan

The Insolvency Service has unveiled a sweeping new five-year strategy that signals a fundamental evolution in its role from an insolvency-focused regulator to a central pillar in the UK’s fight against economic crime. 

With fraud now the most commonly reported crime in the UK, the Service’s 2026–2031 Investigations and Enforcement Strategy lays out a clear and ambitious roadmap. The strategy outlines an expanded role for the agency, including increased enforcement powers, use of data analytics and technology, and closer collaboration with other government bodies. 

From liquidations to law enforcement 

Traditionally viewed as a body focused on liquidations and disqualifications, the Insolvency Service is expanding its scope. Its new strategic priorities emphasise criminal enforcement, asset recovery, and fraud prevention, particularly in areas of systemic abuse, such as Covid-19 Bounce Back Loan Scheme fraud and the misuse of corporate entities as vehicles for laundering money. 

What’s changing? 

  • A broader investigative remit that extends beyond insolvency cases 
  • Greater use of AI and data analytics to uncover complex fraud 
  • Stronger ties with enforcement partners like NATIS, CPS, HMRC, and Companies House 
  • A clear mandate to recover proceeds of crime, including from crypto-assets 

The numbers behind the strategy 

The strategy follows a period of heightened enforcement activity. In the 2024–25 financial year, the Insolvency Service: 

  • Secured 77 criminal convictions 
  • Disqualified over 1,000 company directors 
  • Achieved more than £4 million in compensation orders 
  • Delivered over £50 million in estimated economic benefit by removing bad actors from the market 

The strategy sets targets to expand enforcement activities over the next 5 years. 

Protecting market confidence 

One of the central themes of the strategy is restoring confidence in the UK’s corporate ecosystem. The Service will play a more prominent role in deterring misconduct, ensuring directors understand the consequences of non-compliance and that victims of economic crime see accountability in action. 

This aligns with the government’s broader ambitions to make the UK one of the safest places in the world to do business, especially in the wake of recent reforms at Companies House and increased scrutiny on shell companies and nominee directors. 

Tackling emerging threats 

The strategy doesn’t just address known threats; it also anticipates emerging ones. The Service is investing in expertise to handle: 

  • Cryptocurrency-linked fraud 
  • Cross-border financial crime 
  • Sophisticated abuse of government funding schemes 

With specialist teams and better intelligence-sharing frameworks, it aims to disrupt criminal networks before damage is done, moving from reactive to preventative enforcement. 

Strategic collaboration 

Perhaps most significantly, the strategy emphasises inter-agency collaboration. It recognises that no single authority can tackle complex fraud alone. The Insolvency Service will work closely with other government bodies, using shared data, joint investigations, and aligned enforcement tactics to deliver faster, more effective outcomes. 

Looking ahead 

As someone who’s worked in risk management and investigations for over 3 decades, I see the 2026–2031 Investigations and Enforcement Strategy as a major turning point in the UK’s approach to corporate oversight.  

For risk professionals, compliance leaders, and directors, the implications are clear: regulators will expect more transparency, better governance, and faster responses to warning signs of misconduct.  

This introduces both challenges and opportunities; increased scrutiny, a more aggressive enforcement posture, and expanded data surveillance mean businesses must take internal controls more seriously than ever. At the same time, the strategy promises a fairer marketplace, where those who follow the rules are no longer undercut by fraudsters operating with impunity. 

At ESA Risk, we’ll be tracking how this strategy plays out in practice, how cases are investigated, which industries come under the spotlight, and what risk professionals can do to stay ahead. 

Fraud investigations by ESA Risk 

If you suspect that a fraud has occurred within your business and need advice or support on the next steps, we’re here to help. 

Contact us at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form to find out more. 

 

New specialist squad to tackle fraud in UK public services

Posted on by Admin Admin

The Risk, Threat and Prevention Service, led by the Public Sector Fraud Authority (PSFA), will work closely with various government departments to help prevent fraud, ensuring that public funds are used efficiently and effectively.

The importance of tackling fraud in public services

Fraud is a significant issue that affects the integrity of public services and the efficient use of taxpayer funds. The PSFA estimates “the extent of fraud and error across all of government” was up to £58.8 billion in 2020-21.

By addressing fraud, the government can ensure that public services are delivered effectively and that resources are allocated where they are most needed.

The new counter-fraud team, which starts work today (24th May 2023), will consist of experts from across the civil service, law enforcement, and the private sector. This multidisciplinary approach is to enable the Risk, Threat and Prevention Service to tackle fraud in a comprehensive and effective manner, and is described by the government as “a global first, with no other government in the world currently providing such a cross-government resource and capability to identify and counter fraud.”

The role of the Risk, Threat and Prevention Service

The new team will work with government departments to identify and prevent fraud in public services. This will involve sharing best practices, providing support and guidance, and implementing effective counter-fraud measures.

Some of the key responsibilities of the Risk, Threat and Prevention Service will include:

  • Identifying and assessing risks of fraud in public services.
  • Developing and implementing strategies to prevent and detect fraud.
  • Providing training and support to government departments in counter-fraud measures.
  • Collaborating with law enforcement and private sector partners to tackle fraud.

The benefits of the Risk, Threat and Prevention Service

The government expects the establishment of the new team to bring numerous benefits to public and government services. By identifying and preventing fraud, the team will help to ensure that public funds are used efficiently and that resources are allocated where they are most needed.

By working together with law enforcement and private sector partners, the service will also contribute to the broader fight against fraud and financial crime.

The formation of the Risk, Threat and Prevention Service should be a significant step forward in the UK government’s efforts to combat fraud in public services. By working together with government departments, law enforcement, and private sector partners, the Risk, Threat and Prevention Service can play a crucial role in ensuring that public funds are used effectively and that public services are delivered with integrity.

Fraud investigations by ESA Risk

If you suspect that a fraud has occurred within your business and need advice or support on the next steps, we’re here to help.

Additionally, we can help you to prevent fraud from occurring through manager and employee training and resource provision.

For further details, contact Mike Wright, Risk Management & Investigations Consultant, at mike.wright@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

Economic Crime Plan 2 announced by UK government

Posted on by Admin Admin

The Economic Crime Plan 2 promises the addition of “475 new highly trained financial crime investigators” with the aim of recovering “an additional £1 billion in criminal assets over the next ten years.”

The three-year plan is linked to the Economic Crime and Corporate Transparency Bill currently making its way through parliament and looks to “maximise the new powers” included in that Bill.

New levy funding

The government is making an investment of £400 million to deliver the plan, with half of the funds raised from the private sector through the Economic Crime (Anti-Money Laundering) Levy. The levy applies to anti-money laundering (AML) regulated business – such as financial institutions, estate agents and crypto exchanges – from July 2023, with the amount paid determined by an organisation’s UK revenue.

Treasury Lords Minister Baroness Penn said: “Economic crime harms our economy and destroys lives. More funding from government and the new contribution from industry through the new levy will allow us to deliver a step change in our response.”

£100 million of the investment has been earmarked for “cutting edge technology, including data analytics” for law enforcement.

A “system-wide response”

The plan aims to produce a “system-wide response to economic crime”, bringing together law enforcement, government, supervisory agencies and the private sector. Home Secretary Suella Braverman said: “Backed by our partnership with the private sector, we have the resources and expertise we need to identify criminal networks and confiscate the proceeds of their illicit activities.”

Response to criminals’ use of crypto

The Economic Crime Plan 2 recognises that criminals are utilising “new ways to launder their profits” and, as such, the plan includes the creation of “a new multi-agency crypto cell” aimed at the identification, seizure and storage of illicit cryptoassets.

This follows the government’s announcement last month on its plans to regulate cryptoasset activities.

The role of accountants

Responding to the role to be played by the private sector, which the government has described as “critical”, Michael Izza, Chief Executive of ICAEW, said: “A key success of the first Economic Crime Plan was developing the partnership between accountancy and the public sector to crack down on money-laundering.

“Tackling economic crime and driving dirty money out of the UK’s financial systems will be best achieved by government working closely with professional body supervisors, and we look forward to collaborating on the actions outlined in the second Economic Crime Plan.”

Similarly, accountants have been asked by the government to play a greater role in tackling fraud (through the Joint Fraud Taskforce).

Criticism of the new economic crime plan

However, the plan has drawn some criticism from the government’s political opponents (as may be expected) with Labour MP Dame Margaret Hodge claiming that “no additional funding has been allocated to the fight against dirty money.”

The full plan with supporting data is available to download from the government website.

Advice and support from ESA Risk

For advice and support on economic crime issues, please contact us at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

Three lessons from the Amec Foster Wheeler DPA

Posted on by Admin Admin

It was the SFO’s tenth Deferred Prosecution Agreement (DPA) since the DPA regime was introduced in February 2014. The Statement of Facts was released following confirmation by the SFO that it would not be proceeding with prosecutions against any individuals connected to the investigation.

The conduct set out in the Statement of Facts is egregious and endemic. The judge, in approving the DPA, was scathing in his assessment of the conduct of senior leaders at Amec. He noted that, but for the fact that the company had been acquired by an innocent party, the John Wood Group, he would not have granted the DPA. The Statement of Facts offers some valuable insights and lessons for corporates who may find themselves entangled in a law enforcement investigation of a similar nature.

1. Have a clear strategy for dealing with material that is covered by legal professional privilege (LPP)

While the material may properly be cloaked by LPP and does not require disclosure for cooperation credit, it is important to consider whether a limited waiver of LPP is appropriate in the circumstances of the investigation and the alleged offending.

If the company has decided that it will cooperate with the investigation, then it may require a degree of pragmatism over privileged material in its possession that will enable the investigation to proceed at pace and assist the authorities to reach a conclusion.

In Amec, there was a limited waiver of LPP over legal advice that had been received by the company in relation to its dealings with agents and public officials. This waiver was regarded by the SFO as part of the extensive cooperation of the company.

However, the parameters of a limited waiver of LPP should be clearly documented and sufficiently detailed to avoid any misunderstandings as to the extent of the waiver.

2. Policies and procedures don’t effect change, people do

Who is responsible for the effective implementation? Do they have the required visibility into frontline operations? The lack of visibility and access to information can be a major impediment to ensuring that the policies and procedures have the desired effect of managing behaviour and mitigating risk.

In Amec, an Employee Handbook was issued in 2001 which contained a Code of Ethics and set out procedures on the use of agents. In 2004, the company issued a Code of Business Ethics & Conduct and subsequent policies and procedures followed over the years. All were circumvented and disregarded by employees who were determined to continue corrupt practices, without the knowledge of the compliance department. They appeared to have been blind to the “culture of disregard” or powerless to stop it.

Those responsible for implementation of policies and procedures must have the visibility into highest risk operations and the authority to effect change.

3. Avoid ‘paper’ internal investigations and reviews

The simplified essence of an internal investigation is to identify the issue, resolve it and mitigate the risk of reoccurrence.

The collection of factual information that alludes to corporate misconduct and potential criminal offending should be a call to action and not to carry on regardless. Senior leaders should be committed to taking the steps needed to resolve the identified issues and implement measures to stop such conduct from reoccurring.

Amec instructed the same law firm to conduct four separate internal investigations, between 2007 and 2010, into suspicions of bribery in India, Malaysia, Saudi Arabia and Nigeria. Each investigation uncovered evidence of corruption and yet senior employees at Amec did the bare minimum to tackle these issues.

Those who are instructed as an external resource should ensure that they have requisite independence and impartiality, otherwise the investigation is undermined and is an expensive exercise in futility.

Advice and support from ESA Risk

For advice and support on fraud prevention and investigations, please contact Lloydette Bai-Marrow, Serious Fraud and Economic Crime Consultant at lloydette.bai-marrow@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

 

First published in the Parametric Global Consulting newsletter.

Legislation update: Economic Crime Act 2022

Posted on by Admin Admin

The Economic Crime (Transparency and Enforcement) Bill became law on 15th March 2022. It was expedited due to recent UK sanctions announced against Russia. The Act is intended to bolster the UK’s response to economic crime threats and is set out in three main parts.

Key features of the Act are:

Part 1: Register of Overseas Entities and their Beneficial Owners

  • It requires overseas entities that own property in the UK to disclose details of their beneficial owners.
  • Companies House will manage the Register.
  • There is a duty to update the Register every 12 months; failure to do so will attract a daily default fine.
  • The overseas entity must take “reasonable steps” to identify registrable beneficial owners and share this information with Companies House.
  • ‘Registrable beneficial owners’ are those that hold 25% or more of the shares in the entity or of the voting rights in the entity, have the right to appoint or remove the majority of the entity’s board of directors, and have the right to exercise or actually exercise significant influence or control over the entity, or over a trust or other entity that meets these conditions.
  • The Act requires the overseas entity to serve an information notice on any possible registrable beneficial owners. A criminal penalty is attached to a failure to comply with the notice, or the provision of false information.
  • The deadline for registration is six months from Parts 1 and 2 of the Act coming into force. It applies retrospectively to property acquired (since 1st January 1999 in England and Wales, and 8th December 2014 in Scotland).
  • Non-compliance will result in criminal liability, with managing officers facing criminal sanctions. Penalties for breaches include fines for the entity and imprisonment for individuals.
  • Overseas entities that have not registered will face restrictions when trying to sell, lease, or deal with their property. This is to deter those who attempt to sell their property to avoid registration.

Part 2: Expanding the remit of the Unexplained Wealth Orders (UWO) regime

  • An enforcement authority will get extra time to review material received in response to a UWO, before discharging interim freezing orders over relevant assets.
  • UWOs are extended to assets ‘obtained through unlawful conduct’ and can be imposed on company directors, even if they do not personally own the assets.
  • The Act creates a new category of persons who can receive a UWO, including ‘responsible officers’ of the entity that owns the property.
  • The ‘responsible officer’ of an entity (that is the subject of a UWO) must provide information to authorities regarding the UWO. They can be directors, board members, general managers, company secretaries, and partners.
  • The Act caps the costs awarded against an enforcement authority if a UWO is challenged successfully.

Part 3: Strengthening the UK sanctions regime

  • The Act will make it easier for the government to impose sanctions on companies and individuals. The UK government can now make designations of sanctioned persons much more quickly, especially for those already sanctioned by other countries.
  • The Office of Financial Sanctions Implementation (OFSI) has new powers to publicly identify organisations and individuals that breach financial sanctions, even if they are not the subject of a penalty. They can also ‘name and shame’ companies or individuals that they consider likely to have breached compliance of obligations or financial sanction prohibitions. This enhances the risk of damage to reputation.
  • The Act makes it easier for OFSI to impose penalties for sanctions breaches on a strict liability basis, rather than having to demonstrate that an organisation had knowledge or reasonable grounds to suspect sanctions were being breached.
  • Lack of compliance with sanctions legislation already constitutes a criminal offence subject to fines and imprisonment.

What next?

Governance and controls should be examined thoroughly to ensure that they align with the Act. In particular, the risk of incurring a financial penalty for a sanctions breach is now much higher. The Act is far from perfect, but it is a step in the right direction. There are clear gaps present, and it is questionable whether enforcement authorities will be given the resources to utilise new powers effectively. The six-month period for registration also leaves room for disposing or transferring illegitimate assets. We should expect another Economic Crime Bill to follow soon to deal with the lacunas in this Act.

First published in the Parametric Global Consulting newsletter.

Advice and support from ESA Risk

For advice and support on economic crime issues, please contact Lloydette Bai-Marrow, Serious Fraud and Economic Crime Consultant at lloydette.bai-marrow@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

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