Recommendation 9

HM Government Not Addressed

The government believes that a multi-agency approach is the right way to fight economic crime and fraud. It enables us to differentiate between different crime types. For instance, fraud within the public sector requires a different response to fraud committed by individuals or businesses. Similarly, some forms of fraud are minor and localised and therefore requires a local response. Collaboration between agencies enables the UK to deploy relevant expertise and resources in a targeted and specific manner. The government has taken important steps to ensure effective coordination, most notably through the NECC, which sets the strategic priorities for the system’s response to economic crime and tasks the UK’s law enforcement response. In this role the NECC has brought together agencies and intelligence in a way that has been integral to several areas of successful enforcement activity. The NECC has helped facilitate a number of interventions to prevent, prepare, and protect against economic crime, and to pursue those responsible for it, including through targeted communications on emergent threats. The NECC’s capabilities were displayed in work to improve government’s collective knowledge of the company formation system, as well as the risks associated with the Trust and Company Service Provider (TCSP) sector through joint working with the NCA’s National Assessment Centre, HMRC, and private sector partners. Several intelligence assessments have now been produced on these issues, contributing to the increase of the risk level applied to the TCSP sector in the 2020 National Risk Assessment from MEDIUM to HIGH. The NECC’s approach to assessing economic crime threats and how they are changing is imperative to ensuring capabilities and resources are focused on the highest priority threats causing or likely to cause most harm. This consolidated view of economic crime threats was vitally important in pulling together and coordinating our response to, for example, economic crime related to Covid-19 across 2020 and 2021. The UK Financial Intelligence Unit (FIU), an operationally independent arm of the NECC within the NCA, has the national responsibility for receiving, analysing, associated decision-making and disseminating Suspicious Activity Reports (SARs), and makes all SARs available to appropriately trained officers in law enforcement agencies and other approved bodies for their own analysis and investigations (with the exception of SARs in certain sensitive categories). It is important to note that the UK SARs regime takes an ‘all-crimes’ approach—any suspicions of money laundering or financing of terrorism must be reported to the FIU. The FIU works in close partnership with other key international organisations. For instance, the FIU is an active member of the international Egmont Group of Financial Intelligence Units, set up to improve cooperation in the fight against money laundering and the financing of terrorism. The NECC also hosts the Proceeds of Crime Centre and the Expert Laundering Evidence cadre which provides impartial expert evidence to courts hearing money laundering cases throughout the UK, so that the courts can better understand complex money laundering methodologies, and an interpretation of evidence. It is through this ability to coordinate that the NECC can facilitate interventions to prevent, prepare, protect against economic crime, and to pursue those responsible for it, including through targeted communications on emergent threats. We believe that the NECC operates effectively in its role, and that whilst there could be benefits from unifying law enforcement within a simple department, the size and scope of the new body would likely by unwieldy and ineffective in delivering operational outcomes.