Economic Crime Strategic Board minutes and agenda: 1 December 2021
Published 14 July 2023
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Agenda
Date: 1 December 2021
Time: 10:00-11:30am
Location: Home Office
- Welcome and Introductions
- Statement of Progress Actions Update
- Fraud Action Plan
- High End Money Laundering
- AOB
Welcome and Introductions
1. The Home Secretary welcomed attendees to the meeting and highlighted the programme of work underway to tackle economic crime. She highlighted that cutting crime is central to the Government’s mission of levelling up the country, as set out in the Beating Crime Plan published this summer.
2. The Minister for Security and Borders emphasised the importance of broadening the public private partnership to include the technology and telecommunications sectors and welcomed the attendance of techUK, Google and Vodafone to the Board for the first time.
3. The Board noted the papers submitted by the Civil Society Organisations Steering Group.
Statement of Progress Actions Update
4. HM Treasury presented the progress against the Economic Crime Plan Statement of Progress published in May 2021. Key progress included: operational activity on Cash Based Money Laundering, Suspicious Activity Reports (SARs) reform, and a public consultation on the Money Laundering Regulations (MLRs).
5. A framework for the next iteration of the Economic Crime Plan, with proposed priorities on Fraud, Cash Based Money Laundering and High-End Money Laundering was presented to the Board. The Board agreed the proposal and priorities. The Board also stressed on the need for the next Plan to have a clear focus on outcomes.
6. Separately, the Board also raised concerns over the lack of information sharing between private sector organisations and heard about the work of the Online Fraud Steering Group. UK Finance highlighted their work to develop thoughts on how to support the ability for firms to more easily investigate payments that may be linked to fraud.
Action: Government to present a near final draft of the next iteration of the Economic Crime Plan, focused on Fraud, Cash Based Money Laundering and High-End Money Laundering at the next meeting.
Action: UK Finance to present to Government a paper setting out thoughts on how to support the ability to take a more Risk Based Approach to faster payments.
Action: Home Office to follow up with techUK to explore information sharing models for the tech sector.
Fraud Action Plan
7. The Home Office presented an overview of the Fraud Action Plan, which is focused on two main pillars: Protect and Pursue. The Protect element explores how to support citizens and industry from the threat of fraud, and the Pursue element looks at improving the law enforcement response.
8. During a discussion on international comparators of fraud, it was highlighted that some characteristics of the UK’s financial system, including English language and the faster payments system, had made the UK particularly vulnerable to fraudulent activity.
9. Attendees raised concerns over online “paid for” advertising and the Online Safety Bill. The Board heard that the Online Safety Bill is undergoing pre-legislative scrutiny and is expected to be introduced to Parliament before Easter. The Bill, in its current form, incorporates user generated fraud, and the Government is looking at ways to address concern over online paid for advertising.
10. ECSB was updated on Google’s collaboration with the Financial Conduct Authority in dealing with scam adverts, and Vodafone’s work to trial improvements to prevent ID fraud. A focus on education and awareness amongst the public on how to protect themselves from fraudsters, as well as messaging around the convictions of culprits, were highlighted as important.
11. The Board were also provided a demonstration of Vocalink’s Mule Insights Tactical Solution technology. The technology enables Vocalink to trace funds through the faster payment system in real time, identify individual victims and alerts banks to those accounts. The Board were shown a case study of the proceeds of multiple frauds funnelled into crypto currency holding accounts. It was highlighted that the current regulatory framework to permit public and private data sharing does not support the output of technology as quickly. It was suggested that a smaller group of interested parties should be convened to consider the action needed to unblock this issue.
Action: Home Office to follow up with the financial sector on international comparators of fraud.
Action: HMRC and Vocalink to meet to discuss Vocalink’s Mules Insight Tactical Solution Technology further.
Action: UK Finance to convene a group of interested parties to consider what is needed to unblock the issues that prevent public to private information sharing as experienced by Vocalink.
High End Money Laundering
12. The National Crime Agency explained that High End Money Laundering flows are often the proceeds of crime, tax evasion and corruption. The Board heard the example of the Danske Bank scandal, in which money flowed through UK registered entities, but only a small amount through the UK’s financial system. NCA provided an overview of some of the current vulnerabilities and areas of focus for a public private response including crypto assets and professional enablers. It was highlighted that corporate transparency reform is one of the single most important things in reducing High End Money Laundering flows.
13. The Board agreed to step up public private activity on HEML with a focus on criminal professional enablers and the use of crypto assets. There was a discussion on the need to further discuss the potential trade-off that will be deemed acceptable between the security and prosperity agenda when designing the approach to crypto.
14. ECSB noted that the Institute of Chartered Accounts in England and Wales, in collaboration with HMRC, have created a drama film to show how easy it can be for firms to become professional enablers which is due to feature next year.
15. ECSB also discussed improving the information sharing flows between the public and private sectors.
Action: The National Economic Crime Centre, with the Board’s support to develop a joint public private plan to tackle High End Money Laundering, with a focus on criminal professional enablers, and use of crypto assets.
Item 5: AOB and closing
16. The Board suggested the agenda of the next meeting could include a review of the late draft of the next Economic Crime Plan, fraud and crypto.
17. In closing, the opportunity of public private partnership to make a significant impact on the economic crime agenda was highlighted.
Attendee List
| Attendee | Organisation/Title |
|---|---|
| The Rt Hon. Priti Patel MP | Home Secretary, Home Office |
| The Rt Hon. Damian Hinds MP | Minister for Security and Borders, Home Office |
| Alex Chalk QC MP | Attorney General’s Office |
| Chris Philp MP | Minister for Tech and the Digital Economy, Department for Digital, Culture, Media and Sport |
| John Penrose MP | Prime Minister’s Anti-Corruption Champion |
| Andrew Bailey | Governor of Bank of England |
| Nikhil Rathi | Chief Executive, Financial Conduct Authority |
| Ian Dyson | Commissioner, City of London Police |
| Graeme Biggar CBE | Director General, National Crime Agency |
| Chloe Squires | Director General, Homeland Security |
| Duncan Tessier | Director, Economic Crime, Home Office, |
| Giles Thomson | Director, Office of Financial Sanctions Implementation and Economic Crime, HM Treasury |
| Simon York | Director, Fraud Investigation Service, HMRC |
| Harry Methley | Special Adviser to the Home Secretary |
| Bob Wigley | Chair, UK Finance |
| David Postings | Chief Executive, UK Finance |
| Gregor Dobbie | Chief Executive, Vocalink |
| John Collins OBE | Chief Legal and Regulatory Officer, Santander |
| Pierre Decote | Group Chief Risk Officer, Revolut |
| Ian Stuart, | Chief Executive, HSBC UK |
| Ronan Harris | Managing Director UK and Ireland, Google |
| Andrew Yorston | General Counsel, Vodafone UK |
| Jacqueline de Rojas CBE | President, techUK |
| Duncan Wiggetts | Chief Officer, Professional Standards Department, Institute of Chartered Accountants in England and Wales |
| Juliet Oliver | General Counsel, Solicitors Regulation Authority |
| Mark Allen | Chief Fraud and Financial Crime Officer, Association of British Insurers |