This award recognised an operation that made the most effective use of a fraud recovery solution. It was won by Operation Cheesy, a collaboration between the Department for Work and Pensions (DWP), Liverpool City Council and HM Revenue and Customs (HMRC).
Operation Cheesy focused on a complex benefit and tax fraud investigation concerning two local businesses. These businesses were owned and managed by five members of the same family. They were operated illegally and ‘under the radar’, employing 14 DWP benefit claimants collusively and evading tax, National Insurance and VAT to HMRC.
The investigation involved close collaboration between the Local Service Investigator (LSI), the Local Authority Investigator and the HMRC Investigator. Other agencies and departments also contributed to the successful outcome, including Merseyside Police, the Vehicle and Operator Services Agency (VOSA), Environmental Health, Crown Prosecution Service (CPS) and Land Registry.
Other teams from within Liverpool City Council, HMRC and DWP – such as the Organised Fraud Team and analysts from Central Criminal Investigations Service (CCIS), HMRC analysts, Local Government Chemist, Operational Intelligence Unit (OIU) and Financial Investigations Unit (FIU) – were also involved.
The operation’s investigation phase took over four years and culminated in a range of penalties – 10 DWP claimants (including the five owners/managers from the same family and five employees) were prosecuted and received court summons, while a further four employees have been given administration penalties, which are DWP fines of between 30–50% of the total overpayment of benefit.
The total DWP overpayments fraudulently claimed was £330,000 with a further £398,500 in VAT and tax avoidance charges.
Operation Cheesy impressed the judges for a number of reasons. It was an excellent example of agencies working together, turning a complex case into an effective working arrangement. It took multiple events into consideration and the funds recovered and preserved were significant.
The judges were especially impressed with the Memorandum of Understanding used between the different agencies, considering this an approach that could be adopted by other organisations.
This award recognised outstanding team work across departments or organisations. It was won by Operation Renegade and Operation Eagle, two teams who joined forces on a complex fuel fraud case involving multiple agencies and jurisdictions.
In June 2016, representatives from the Revenue Commissioners in Dublin (Operation Eagle) advised the Fraud Investigation Service in Belfast (Operation Renegade) that they suspected oil, suitable for use as diesel, was being imported into Northern Ireland and the Republic of Ireland in commercial quantities.
Mislabelled as ‘anti-corrosive product’ or ‘crude’ oils, which do not attract excise duty, this system was enabling Organised Crime Groups (OCGs) to evade duty and distribute this oil as diesel directly to forecourts.
Fuel laundering had been successfully curbed following the introduction in 2016 of a new government marker, so this move by OCGs to smuggle diesel or a diesel substitute represented the evolution of fuel fraud.
When the Revenue Commissioners in Dublin notified their colleagues in Belfast, there had been much speculation about new trends in fuel laundering but little or no evidence of what might be taking place. It was clear from the initial meeting between Dublin’s Operation Eagle and Belfast’s Operation Renegade that this was a significant threat to both the UK and Irish economies. Additionally, though the ultimate buyer was unknown, surveillance had indicated the isotanks of mis-described oil were being collected by individuals linked to previous fuel frauds.
Under the auspices of Joint Investigation Team (JIT) status, Operations Eagle and Renegade agreed to assist each other. Further analysis on the Northern Irish vehicles and premises identified by Operation Eagle was carried out, which improved the intelligence picture. But putting an isotank under surveillance (the only real evidential component which would prove the oil was actually being used as diesel) was problematic, given the hostile terrain of South Armagh where it was suspected the fuel would end its journey.
The Renegade team sought armed Police Service of Northern Ireland (PSNI) support to assist with a controlled delivery and PSNI readily agreed to moving resources from elsewhere to support the investigation.
When the OCG moved an isotank from Dublin port, surveillance by the Eagle team observed the isotank crossing the border. The Renegade Silver Commander then confirmed the isotank’s arrival at premises in Cullaville, Crossmaglen and waited before calling the ‘knock’, to give the OCG time to start offloading the product.
When PSNI and Fraud Investigation Service officers entered the premises, one man was busy decanting the ‘anti-corrosive product’, which tests confirmed as diesel into a storage tank.
Over the following seven days with the assistance of Border Force Officers, ten further isotanks, containing approximately 250,000 litres were held and later seized by the Operation Renegade team at Belfast Docks. Operation Eagle seized eight tanks, 200,000 litres at Dublin Port.
Operation Renegade and Operation Eagle’s nomination stood out to judges as an exceptional example of what can be achieved when cross-border agencies join forces. The teams were working under very challenging circumstances, but achieved impressive results through a concerted effort to collaborate, pooling their resources, sharing intelligence and involving other agencies when needed.
It clearly demonstrated that cross-border collaboration managed effectively can combat fraudsters who do not respect jurisdictional boundaries.
This award recognised an organisation or individual who developed or used an innovative policy or process to prevent fraud from entering the system. It was won by NHS Scotland Counter Fraud Services (CFS) who devised a very successful pre-treatment prevention programme, supported by NHS practitioners, and aimed at patients.
In April 2015, CFS carried out a data analysis which suggested that in the previous year the level of fraudulent or erroneous dental patient claims in Scotland, under the NHS Tax Credit exemption category, was 28.2%. With the total cost of tax credit payments that year amounting to nearly £11.5m, this implied that over £3.25m was being wrongly claimed.
In response to this, CFS immediately set about creating a pre-treatment prevention initiative. Its aim was to reduce the number of patients who appeared to be wrongly claiming and to channel monies back into NHS patient care.
The CFS team approached NHS Forth Valley, which agreed to take part in a planned and co-ordinated pilot. With the support of the health board, staff from the 49 dental practices in the NHS Forth Valley area providing NHS treatment, were targeted through a number of channels.
In late summer 2015, CFS Investigators visited dental staff from each of the participating practices and provided them with advice, guidance and supporting materials about the project.
During the following six month period, practice staff were asked to engage with patients at the earliest opportunity and provide them with details of the CFS initiative. The aim was to strengthen the treatment access point; by empowering staff to engage with patients about their alleged exemption status. This allowed them to influence patient behaviour before their treatment payment status was declared.
A key principle of the project was that any required treatment would continue to be provided, regardless of whether the patient was able to provide proof of their NHS Tax Credit exemption status. This ensured that the oral health of the community would be maintained. However, patients were informed that should they not produce evidence of NHS Tax Credit exemptions, CFS would carry out a check of their claim with HM Revenue and Customs.
Follow-up data comparison analysis established that there had been a 12% decrease in the total number of Tax Credit exemption claims from the same six month period of the previous year. On that basis, the annual savings figure for NHS Forth Valley equated to £64,000. This is a 43% reduction in the fraud or error figure estimated in 2014. If these results were achieved throughout Scotland, this would represent annual savings of £1.3m.
Additionally, a month on month comparison was made of the relationship between the total NHS Tax Credit Claims made and those that were checked with HMRC. This suggested that practice staff had been successful in deterring wrongful claims being made by non-exempt patients.
The judges were impressed by CFS’s initiative in mining their existing data to identify an area vulnerable to fraud. The approach they devised and the way it was executed – in clear, distinct phases and empowering staff – was also exemplary. Most significantly, the pilot can now be extended and rolled out industry-wide for even greater impact.
This award recognised an organisation or individual who demonstrated outstanding initiative in combatting internal fraud and was won by King’s College Hospital NHS Foundation Trust.
In 2010, the Trust became the first NHS body to implement electronic document scanning technology to validate identity documentation, as part of its standard recruitment process for all new employees. In 2015 the Counter Fraud Team launched the Recruitment Standards Project whereby all employees who had not already undergone the robust recruitment checks had their identity verified using the technology.
The Recruitment Standards Project was fully endorsed by the Board and required all staff – those recruited pre-2010 and those who transferred into the organisation after 2010 – to have either their passport or UK photo card driving licence scanned for verification purposes.
Participation in the Trust-wide project was mandatory with non-compliant staff facing potential disciplinary action. It launched with a comprehensive communications campaign that involved the Counter Fraud Team meeting with all Divisional Senior Management Teams to raise awareness of the project.
The project was featured on the Trust intranet site, giving staff access to supporting information and FAQs, which were accessed over 5,500 times during the project. The project was included in Chief Executive bulletins and the quarterly Counter Fraud Newsletter. Widely publicising the project ensured staff awareness and compliance, and also assisted in raising awareness of the work of the Counter Fraud Team.
As part of the project, over 5,000 employees had their official photographic identification verified using electronic document scanning technology, not only validating the authenticity of the identity documentation but providing further verification regarding employees’ legal right to work.
In one case, an employee in a senior nursing role who had worked for the Trust for almost 17 years made deliberate attempts to avoid the scanning sessions. The Counter Fraud Team worked with the department’s management team and an investigation run by Trust investigators confirmed that the employee had never had a legal right to work in the UK.
The subject was arrested following close liaison with the police and was subsequently charged with multiple fraud offences. An internal disciplinary process was instigated immediately and resulted in the employee being dismissed. The Trust referred the matter to the Nursing and Midwifery Council (NMC) and has worked closely with the NMC throughout the investigation. The subject faced a fitness to practice hearing in 2016.
Financial recovery was also instigated in this case, which resulted in a total of £107,498 being recovered. This money has been returned to the Trust for use in delivering core clinical services. In this case criminal, disciplinary, regulatory and financial sanctions were all pursued.
Overall, the project generated a return on investment of 400% and inspired thought provoking debate amongst the judges. They were very impressed by the Counter Fraud Team’s use of new technologies to automate and improve internal processes and highly commended the Team’s success in engaging staff in the project, an area that often proves challenging.
This award recognised an individual or team who delivered a fraud awareness programme in a fresh, innovative way and was won by the National Trading Standards (NTS) Scams Team’s Friends Against Scams initiative.
The NTS Scams Team was created in 2012, to tackle the problem of postal, telephone and doorstep scams. Its aim was to improve the then fractured process of identifying and supporting the ‘silent’ victims of scams, individuals who are often unaware or unable to admit that they are a victim of a crime.
Since the team’s inception, they have made a real difference to people’s lives. They have created a highly successful support and referral system and have saved UK consumers over £50 million.
Determined to further raise awareness of scams and to empower those affected, the Scams Team launched the Friends Against Scams initiative in 2016. It is aimed at consumers and features a dedicated website packed with guidance on how to recognise scams. Through the website, individuals are encouraged to become a ‘Friend Against Scams’ and are taught where to report any incidents.
Internet usage is on the rise for those over a certain age, however there is still a large proportion of the population who do not use or have access to the internet. In addition to providing a platform for people to report scams, Friends Against Scams wanted to target these more vulnerable individuals because they were unlikely to come across online information warning against scams.
They devised a campaign that targeted whole communities to ensure that even those that are hard to reach and often forgotten, received the awareness messages.
The campaign relied on the self-declared ‘Friends Against Scams’ who were asked to share their knowledge about scams by making a pledge that could be one of the following:
- Tell five people about the Friends Against Scams initiative
- Educate and talk to people about scams
- Share their Friends Against Scams status on social media
- Look out for people who are at risk of being a scam victim in their community
- Write to their local MPs asking them to promote scams awareness
- Actively support local fights against scams by setting up or taking part in a scam awareness activity or event in their local area
- Make a difference to someone’s life by getting in touch and staying in touch, with someone who has been a victim of a scam
- Display a poster in the window of their home to show their neighbours that they are part of Friends Against Scams and to promote the initiative
- Challenge attitudes about scam victims and help to stamp out the stigma of this commonly misunderstood problem by talking about scams and influencing people to consider scams from a different point of view
Friends Against Scams really impressed the judges. The team established processes with partner organisations to identify victims and used all possible avenues to share best practice and inform local authorities and agencies on how they can work with and support scam victims.
By using their own Friends Against Scams advocates they ensured an even greater reach, particularly amongst those more vulnerable members of the community – a model that could be very effectively adopted by other organisations hoping to achieve similar goals.