This is the fourth and final part of a speech I gave to the national Economic Crime Conference (Socex) in November 2024. The context was the fraud crisis: 40% of all crime is fraud and the temptation is to form a Fraud Squad - a traditional 20th century solution. This would be a mistake, a tried and failed strategic mistake. We should, instead, use a 21st century solution and deploy Accredited Financial Investigators to the frontline - like we used to - but also do it better. This would more efficiently address some multiple problems faced by today’s police: Not just fraud, but the shoplifting epidemic, the scourge of bicycle theft, and other organised acquisitive crimes. In short we should follow the money to solve the crime wave.
“The profession of Accredited Financial Investigator is a unique British invention that helped solve multiple problems from 2003 onwards. After the Proceeds of Crime Act (2002) we came close to creating a new profession with the potential to change the crime world, but somehow, we stopped part way. The new generation, you, could finish the job.
We have a retention issue. Financial Investigators are trained at public expense and then go through a one-way door to the private sector. This is a huge waste of public money.
My solution is to harmonise the pay and conditions of Financial Investigators across all our agencies. To allow Financial Investigators to move. This would create an interesting career path (to address retention), we would improve interagency cooperation (to improve efficiency). We would raise the professionalism through the exchange of people (not just information), hugely increasing our expertise and diversity.
HR will say that this is impossible. But then they would say that. They are ‘impossible’ people.
We could create a Senior Financial Investigator role. This would maximise Financial Investigator efficiency, create a career path and eventually make financial investigation a central pillar of the law enforcement approach to all crime including economic crime.
We could sell this idea internationally, export our expertise. Deliver the Financial Investigator profession to the world. Imagine foreign Financial Investigators in every country, trained to handle financial intelligence and evidence, just like us. A foreign resource capable or tracing and seizing assets at our request. We could recover and repatriate assets gained from crime comitted in the UK, just as we have done in the past, remember Operation Captura and the recovery of houses along the Costa del Crime?
Foreign criminals based abroad prey on our public. This is a way to go and get them. In this way International Cooperation changes from being a problem to being a solution and the UK makes money from exporting our expertise on the way. Another win-win.
Finally, we could have private sector Financial Investigators. There would be protocols and disclosure issues, but the real gain of a genuine revolving door that creates a genuine public-private partnership would be a prize worth having.
Secondly. I’ve mentioned the Joint Asset Recovery Database. Where in the world does any country have all its cases, from all its agencies, using every one of the five asset recovery regimes, over twenty years all in one place. What an incredible national resource to have.
Thirdly. We have POCA, five different ways to recover assets. We should be exporting this law too. Personally, I think cash seizure power is the most important. It is still a quarter of our confiscation in our, apparently, cashless society.
But that is not why it is important. It is a catalyst. It demands management attention, to store it, count it, to litigate it. For most senior police managers, it is their first exposure to ‘economic’ crime. We should be doing academic research on the psychology of cash, why it is so culturally important, why seizing it is such a game changer in the fight against economic crime.
Fourthly. I think we struggle to explain what an economic criminal is. People don’t understand what this conference is about. My solution is the criminal lifestyle provision. Section 75 of POCA is the one that allows assumptions to be made. If the defendant matches the criteria you can seize everything and assume it’s all the proceeds of crime. We could do a lot more with s75, it is the definition of ‘being a criminal’, that the ordinary person understands. We should understand it ourselves. We should promote this in our thinking, our objectives, our press releases, our statistics.
We have a terrible narrative. That’s why I wrote the book [The War on Dirty Money] We need to change our story. When we try and explain crime we use the clear-up rate. Everyone more or less understands the clear-up rate, especially if they work in crime and justice. Why not a financial clear-up rate?
Take the number of people convicted in the Crown Court compared to the number of people given asset recovery orders. I can tell you this comes out in the UK at around 30%.
It is not a catastrophe. It is a measure of what we have in the in-tray and how we deal with it. It is something we can work with.
It links economic crime to the people committing it.
It links crime to economic crime.
It links both to the proceeds of crime.
It turns the problem of economic crime into a potential solution. It takes the cash out of crime and gives it to victims, to society, back to us all in a way that makes sense.
It changes the narrative from economic crime being a problem, to economic crime as the gateway to a solution. We should take our unique invention - the Accredited Financial Investigator and enhance it. We should develop the profession by creating career paths across agencies, ranks and international frontiers and into the private sector. We should follow the money and hit the criminals where it hurts.”
The earlier parts of the speech are here: Part 1, Part 2, Part 3
Excellent commentary