(COR110)

Written evidence submitted by the City of London Police (COR0110) Submitted by the Office of the City Remembrancer

Introduction

1. City of London Police is the National Police Chiefs’ Council Lead for Economic Crime and National Lead Force for Fraud. City of London Police operates Action Fraud, funded by the Home Office, which is the national reporting centre for fraud and financially motivated cyber-crime. It investigates serious, complex and cross- border fraud which is beyond the capability of local policing. It also provides training and continuous professional development for the police and private sector workforce through its Economic Crime Academy.

2. City of London Police notes the Committee’s first Report of Session 2019-20 “Home Office preparedness for Covid-19 (Coronavirus): Policing” published on 17 April 2020 and the Committee’s requests for the Home Office, National Crime Agency and NPCC to set out what action they are taking to address COVID-19 related online fraud in the short term. City of London Police will be contributing to the Home Office’s response to the Committee on behalf of NPCC.

3. City of London Police also notes the concerns raised about the Action Fraud service. Last year the Police Authority Board of the City of London Corporation commissioned an independent review led by former Deputy Commissioner of the Metropolitan Police Sir Craig Mackey1. The report makes 15 recommendations. Work has commenced to progress a number of these recommendations, a number of which have funding implications.

4. The review found that “Action Fraud and the NFIB [the National Fraud Intelligence Bureau] have potential to serve policing well in the UK.” However, the review noted that operations were hampered by:  An operating system delivered by IBM that is not fully functional  Resourcing levels that have not kept pace with increased reporting  Lack of prioritisation for fraud investigation by police forces in England & Wales

5. The review suggests that transformational change is needed at three levels to bring fraud into check and serve victims well:  Action Fraud and the NFIB need adequate resources  Action Fraud and the NFIB need a dependable ICT platform  Multi-skilled economic crime teams should be created at a regional level with forces responding to local threats and supporting victims in their communities.

6. In January, an internal review of reporting demand into Action Fraud and the National Fraud Intelligence Bureau was undertaken. This identified a £4.5m funding gap. Working with the Home Office, some additional funding has been identified for the financial year 2020/21, reducing this funding deficit to circa £3m.

COVID-19 Fraud Threat

1 Published January 2020: https://www.cityoflondon.gov.uk/about-the-city/about-us/Documents/action-fraud- report.pdf (COR110)

7. Centralised national reporting of fraud (and cyber-crime) through Action Fraud provides a detailed understanding of emerging threats including those linked to COVID-19.

8. As at 19 April, there had been 960 COVID-19 related fraud and cyber reports to Action Fraud representing £2.25m in losses and over 3,900 phishing email reports. COVID-19 related fraud and cybercrimes represent less than 3% of all other fraud and cyber crime reports.

9. While overall fraud reporting levels have not increased, there is a number of different scams circulating relating to COVID-19. These include those relating to online shopping, for example, the purchasing of testing kits, protective face masks or hand sanitiser that do not exist or do not work.

10. Criminals are using government branding to try to trick people, including HMRC logos to make spurious offers of financial support through unsolicited emails, phone calls and text messages. It is anticipated that there will be new phishing scams or calls claiming to be from government departments offering grants, tax rebates, or compensation. There are also fake websites and emails being set up purporting to be genuine companies.

11. This situation is likely to continue, with criminals seeking to take advantage of the pandemic, by exploiting people’s financial concerns. This may include fraudulently applying upfront fees to bogus loans, offering high-return investment scams, and targeting pensions.

Action Fraud and the National Fraud Intelligence Bureau during COVID-19

12. Telephone calls to the contact centre initially reduced in the lockdown period but the volume of online reports remained largely consistent and is rising. This reduction in telephone contact is not expected to be a long term trend but has resulted in improved performance in the contact centre, reducing average speeds to answer and abandonment rates (the percentage of callers that hang up before the call is answered).

* Figures in red represent the average figure across both months. Call volumes reflect the core service (8am - 8pm) Mon - Sun

13. Despite the reduction in telephone contact, in the week commencing 13 April, fraud and cyber crime reports2 recorded by the National Fraud Intelligence Bureau were

2 Note that telephone calls to Action Fraud result in both crime and information reports based upon definitions within National Crime Reporting Standards and Home Office Counting Rules. Action Fraud also receives telephone calls from victims following up on previous reports. Therefore, the level of reduction in telephone contact is not mirrored by the same level of reduction in recorded crime (COR110)

only 2% below weekly averages in January and February indicating that crime reporting is returning to usual levels.

14. Prior to COVID-19 the Action Fraud contact centre operated with 64FTE call handlers. This figure decreased significantly during the first week of lockdown reducing to 39.5FTE due to staff self-isolating or suffering from COVID-19.

15. In order to maintain crime reporting services, technology was rolled out to enable the majority of contact centre staff to work from home by 25 March, protecting staff and enabling those self-isolating without symptoms to continue working. Calls continue to be monitored for performance information and quality assurance by supervisors. As at Monday 20 April, 58FTE staff are delivering the Action Fraud service.

16. City of London Police has worked with the Home Office to identify funding to open a second contact centre site in Newcastle and increase the overall Action Fraud headcount to 94FTE following the review by Sir Craig Mackey (see paragraph 3). Work has continued to recruit and develop remote training for these additional staff at pace. 15 new staff will commence providing Action Fraud services, working from their homes, on 1 May.

17. Staffing levels at the National Fraud Intelligence Bureau (who develop and disseminate Action Fraud reports to police forces) have remained largely constant and the majority are able to work from home. These staff are supporting the national response to COVID-19 through fast time dissemination of COVID-19 related fraud and cyber-crime to forces (see section on national leadership and coordination below). This is in addition to reviewing crimes, developing intelligence and supporting victims linked to other types of fraud and cyber-crime.

18. City of London Police has temporarily redeployed 20FTE to support the work of the National Fraud Intelligence Bureau. These officers have additional capacity due to the slowing of the criminal justice system and reductions in other criminal activity. This will increase capacity for crime review, intelligence development and disruption in the short term.

National Leadership and Coordination of the Police Response to COVID-19 Fraud

19. City of London Police has been working as part of the multi-agency National Economic Crime Centre to step up the law enforcement response to fraud since October (Project Otello). In January, City of London Police piloted a new approach to tackle courier fraud, a high harm fraud affecting vulnerable and elderly citizens.

20. This approach provided a template for coordinating the response to COVID-19 fraud. City of London Police has played a leading role in establishing Project Etherin, the overarching law enforcement response to fraud during the crisis, led by the National Economic Crime Centre. Project Etherin objectives are to:

 Deliver consistent public messaging which will reassure, educate and protect  Support vulnerable victims at most risk  Anticipate, identify and respond to changes in offending behaviour (COR110)

 Reduce the opportunity for crime  Identify and disrupt offenders who are seeking to take advantage of the crisis

21. Under Project Etherin, City of London Police is leading and coordinating the police response in England and Wales. This involves:

 Monitoring all COVID-19 related crime reported to Action Fraud  Analysing and accelerating the dissemination of offending linked to the crisis  Developing intelligence and undertaking activity to a) identify and prosecute offenders and b) trace and seize funds linked to offending  Working closely with the ROCU network and forces to understand capability and prioritise activity  Chairing a daily operations meeting to coordinate activity  Developing and initiating website, email and telephone disruption activity to reduce offending  Working with UK police forces to provide consistent support to victims  Providing communications expertise to support and/or lead national crime prevention campaigns

22. As at 22 April, 81 COVID-19 related reports have been disseminated to police forces by NFIB for investigative action and victim support. This accelerated process has had positive results including, most recently, 3 arrests by the Metropolitan Police Service, 2 arrests by Hampshire Police and £250,000 repatriated to victims within 24 hours of reporting to Action Fraud.

23. Between 23 March and 22 April, City of London Police issued disruption notices to industry partners requesting suspension of 52 websites, email accounts and telephone accounts identified through Action Fraud reports as being linked to COVID-19 fraud.

24. The National Fraud Intelligence Bureau has been sharing intelligence with National Crime Agency, the Medicines and Healthcare Products Regulatory Authority, Office of Product Safety and Standards and international partners including Interpol. Through this, City of London Police was able to successfully prevent a Swiss company from losing €498,000 in a fraud linked to the purchase of face masks that did not exist. It has also been contacting recipients of fake testing kits purchased by UK citizens from Holland, warning them not to use them.

25. City of London Police is also monitoring phishing emails linked to COVID-19. It worked with the National Cyber Security Centre to expedite the launch of a new public phishing reporting tool which in its first day received 4,416 reports and resulted in the takedown of 69 phishing sites.

26. All City of London Police national economic crime investigative units are supporting operational activity in collaboration with partner agencies.

27. The Police Intellectual Property Crime Unit (PIPCU)3 has extended its remit and is providing essential support to a National Crime Agency-led operation targeting the

3 PIPCU is a City of London Police unit established to tackle online intellectual property crime fully funded by (COR110)

illicit supply or offering of personal protection equipment and cures/testing kits. Within 24 hours of receiving information from the Medicines and Healthcare Products Regulatory Authority and the United States Food and Drug Administration, a British man making and selling counterfeit treatment kits internationally was arrested, charged and remanded in custody. 300 treatment kits and 20 litres of chemicals used to produce the kits were seized during the arrest. The treatment kits are thought to contain potassium thiocyanate and hydrogen peroxide, which are extremely harmful chemicals when the user is instructed to wash and rinse their mouth with them. PIPCU has also been issuing cease and desist notices to stop the selling of fake NHS lanyards and other IP infringing products for sale online.

28. The Dedicated Card and Payment Crime Unit (DCPCU)4 has also incorporated COVID-19 fraud into its current priorities. Over the past two weeks, DCPCU has successfully targeted and disrupted several criminal gangs involved in sending COVID-19 related scam texts and emails to unsuspecting members of the public. It has executed warrants in London, Leicestershire and Dorset seizing devices used to send bulk scam messages including fake HMRC text messages offering financial support and refunds. The unit is actively progressing another 6 investigations to executive action. This includes an investigation that has originated out of the National Economic Crime Centre Data Fusion Cell.

Victim support and care during the COVID-19 crisis

29. Victims reporting to Action Fraud who are identified as vulnerable are being referred to local forces for support on a daily basis. Some forces have adapted how they are supporting vulnerable victims, replacing home visits with telephone contact where appropriate to maintain social distancing.

30. City of London Police continues to operate a service for victims of fraud whose crimes are not suitable for investigation through its Economic Crime Victim Care Unit. This service provides tailored crime prevention advice to reduce repeat victimisation and signposts victims to services that can help them to cope and recover. This service is primarily conducted by telephone and there has been an increase in number of calls answered and accepted by victims due to a larger number being at home than usual.

31. This service is currently operational in 6 forces and plans to roll this out to a further 10 forces this financial year continue to be implemented at pace.

Raising Awareness of the Threat of Fraud

32. City of London Police has undertaken engagement with the media to raise public awareness of the threat from COVID-19 fraud. The first press release was issued in

the Intellectual Property Office 4 DCPCU is a unique proactive police unit, with a national remit, formed as a partnership between UK Finance, the City of London Police and the Metropolitan Police. It is fully funded by the banking industry. (COR110)

March. This was covered by a number of national outlets including the Telegraph, Guardian, Independent, Daily Mail, Sun, Metro and Daily Express. The story was also picked up by nearly 20 regional titles. A follow-up release was issued two weeks later. This, again, received widespread coverage in print and online. City of London Police officers took part in interviews across BBC Breakfast, BBC Evening TV news and local BBC radio stations including Tees, Somerset, Manchester, Norfolk, Nottingham, Yorkshire and Jersey.

33. City of London Police has provided regular alerts to policing and other law enforcement partners on the types of offending being perpetrated to inform crime prevention advice. The Action Fraud website and social media pages are frequently updated with the latest advice. COVID-19 fraud prevention messaging has resulted in 20.6m social media impressions and 9.3m social media accounts reached as its content has been shared by numerous police forces, police and crime commissioners, local councils, banks and journalists.

34. The social media content has generated a constant level of press coverage in all types of media from more finance-focused outlets like the Financial Times to more consumer-based titles like the Daily Mirror. To help reach audiences that may not be online as much, we have taken part in further interviews on radio and TV including BBC’s The One Show, ITV News, The Steph Show on Channel 4 and LBC.

April 2020