CPS Economic Crime Strategy 2025 - two year progress report

• Introduction
• Our People
• Digital Capability
• Strategic Partnerships
• Casework Quality
• Public Confidence
• Future Work
• List of Abbreviations

Introduction

The CPS remains committed to tackling economic crime and bringing fraudsters to justice. Since the publication in 2021 of the CPS’s Economic Crime Strategy 2025, the changing nature of economic crime has continued to present challenges. Fraud accounts for over 40 percent of all crime. It is estimated that over 80 percent of fraud reported nationally is ‘cyber-enabled’ and over 70 percent either originates abroad or has an international element . 
The CPS’s Economic Crime Strategy 2025 provides a high-level vision of where we want to be by 2025. It is supported by a commitment to ensure the right person is prosecuted for the right offence in a timely manner, that victims and witnesses are at the heart of our casework and that any proceeds of crime are recovered. It continues to represent a clear articulation of the role that the CPS will play in contributing to improving criminal justice outcomes for economic crime.

The CPS Economic Crime Strategy 2025 (‘the Strategy’) sets out five strategic aims:

1. Our people will have the skills and tools they need to prosecute increasingly complex economic crime cases, 
2. Digital tools are utilised for case management, preparation, and presentation in economic crime cases,
3. CPS operational insights are used by partners to improve the UK’s response to economic crime, 
4. An innovative approach will ensure our casework delivers improved justice outcomes in a timely manner, and
5. Victims and witnesses are at the heart of every case, and we communicate effectively about our role in tackling economic crime.

This Progress Report is structured so that it sets out the activities we have undertaken, up to September 2023, towards the outcomes set out in our CPS Economic Crime Strategy, and thereby towards the overarching aims for each of the five strategic aims. The highlights include:

• The CPS continues to maintain a high conviction rate and steady charge rate where Fraud and Forgery was the principal offence. In the year ending June 2023, the conviction rate was 84.1 percent. and the charge rate was 76 percent.
• Since the launch of the Strategy, in the period between April 2021 – March 2023, the CPS prosecuted over 13,480 defendants, where Fraud and Forgery was the principal offence category.
• We also have strong performance on asset recovery. In the last five years (2018 to 2023) over £480 million has been recovered from CPS obtained Confiscation Orders. Of this amount, £105m has been returned to victims of crime by way of compensation.
• In April 2022, we launched the Serious Economic, Organised Crime and International Directorate (SEOCID), bringing together specialists on fraud, international, extradition, organised crime, and proceeds of crime. This internal reorganisation reflects the CPS adapting to the changing nature of crime. It ensures that the CPS has flexibility, resilience, and the right kind of specialist legal expertise to navigate and keep pace with the complex evolving nature of these crime types.
• In June 2022, the CPS set up a new Economic Crime Prosecutors’ Forum with lead economic crime prosecutors in every CPS Area, to help strengthen the links between prosecutors in our SEOCID divisions and across the 14 CPS Areas and share best practice and learning.
• In October 2022, SEOCID launched a new Disclosure Standard, which further promotes early engagement between investigators and prosecutors in complex casework, which includes economic crime.
• The CPS welcomes the introduction of a new ‘failure to prevent’ fraud offence, and the reform of the identification principle for certain economic crime offences, in the Economic Crime and Corporate Transparency Act 2023. This came following the Law Commission review of Corporate Criminal Liability, where we worked closely with the SFO and the Government to call for an expansion of the ‘failure to prevent’ model to wider economic crime, supported by the former Director of Public Prosecutions (DPP), Max Hill KC, during the Law Commission webinar debates.

We understand the public concern about the declining number of criminal justice outcomes for victims of Economic Crime. This is a challenge that requires a long-term, system-wide approach with commitment from all parts of the criminal justice system and the CPS will play its part including through the delivery of the Economic Crime Strategy 2025. We continue to work with partners across the criminal justice system to support ‘a whole system approach’ as articulated in the Government’s recently published Fraud Strategy: Stopping Scams and Protecting the Public (the ‘Fraud Strategy’) and the Economic Crime Plan 2 (2023-2026), as well as the forthcoming UK Anti-Corruption Strategy.

Baljit Ubhey
Director of Strategy & Policy
Strategy and Policy Directorate

Andrew Penhale
Chief Crown Prosecutor
Head of the Regional and Wales Division
SEOCID

Joanne Jakymec
Chief Crown Prosecutor
Head of the International London and Southeast Division
SEOCID

Adrian Foster
Chief Crown Prosecutor
Head of the CPS Proceeds of Crime Division
SEOCID

Our People

Aim: Our people will have the skills and tools they need to prosecute increasingly complex economic crime cases

Outcome: A network of prosecutors who have the skills and tools they need to prosecute the most complex economic crime cases is created and maintained.

Since the launch of SEOCID in 2022, we have seen strengthened links with prosecutors across the 14 CPS Areas and an increase in the organisation’s ability to tackle complex crime types, including economic crime. Our prosecutor networks have played a significant role in achieving this objective.

The Economic Crime Prosecutors Forum

In June 2022, the CPS set up a new Economic Crime Prosecutors’ Forum with lead economic crime prosecutors in every CPS Area. The Forum meets regularly to discuss Economic Crime issues in CPS Areas, drawing on expertise from SEOCID and Area Fraud Hubs to share best practices and develop wider CPS expertise in prosecuting economic crime. Recently this Forum has helped ensure SEOCID and Areas join up in relation to a large-scale fraud with multiple defendants across England and Wales. Whilst SEOCID prosecute the most complex cases, several cases would be referred to CPS Area Prosecutors. The Economic Crime Prosecutor Forum was used to ensure join up between SEOCID and CPS Areas, by sharing guidance and a SEOCID point of contact to prosecutors.

Cyber SPOC Network

We recognise that cyber-enabled or cyber-dependant economic crime constitutes a significant proportion of the nationally reported cases of fraud. In 2022, we set up a Cyber Single Point of Contact (SPOC) Group, which is a network of prosecutors with expertise in cybercrime across SEOCID and CPS Areas. The Cyber SPOC Network brings together prosecutors to share casework knowledge and best practices and support training. The Cyber SPOC Network is also supported by a Cyber Strategic Governance Group, which leads the formulation of a cross-organisational plan to build resilience amongst prosecutors dealing with cyber-dependent and cyber-enabled crime, which includes economic crime and identifies operational risks to casework quality.

International Casework Leads Network

Equipping our prosecutors across all parts of the CPS to confidently identify and address the international dimensions of their cases has never been more important. The International Casework Leads (ICL) network was a significant part of the CPS’s preparations for the UK’s exit from the European Union and has since become an invaluable part of how CPS supports prosecutors with progressing casework with an international dimension under the EU-UK Trade and Cooperation Agreement (TaCA).

The ICL network consists of a team of experienced prosecutors located in each CPS Area and Central Casework Division, supported by International and Extradition within SEOCID, and provides prosecutors with a first point of contact to answer questions concerning international cooperation. This network has helped colleagues formulate appropriate case strategies and make the best use of international tools. 

Outcome: All legal staff across the CPS are supported and confident in prosecuting economic crime cases

We have now established a new structure to facilitate agile and effective management of live cases and handling of casefile risks: SEOCID holds regular Casework Forums to consider learning derived from cases selected from SEOCID and CPS Areas. The Casework Forums also act as effective vehicles to deliver training and share learning from completed cases, including economic crime cases. There is also a process of joint prosecutor and investigator de-briefs on concluded cases through Local Casework Quality Boards.

Outcome: Our people understand the implications of new technology and the changing nature of economic crime

We are committed to utilising innovative ways of delivering training and upskilling of our people:

• SEOCID regularly hold “Lunch & Learn” sessions, in addition to formal training sessions and upskilling through Casework Forums mentioned above, to enhance prosecutor’s understanding of new technologies and the changing nature of economic crime. Recent topics have included crypto assets and international cooperation.
• The CPS and Home Office delivered joint training and issued guidance for prosecutors on ‘Post-EU Exit Extradition and International Enquiry’ following the UK’s exit from the EU. 
• We have also partnered with other agencies to explore training opportunities. For example, in 2023 HM Revenue and Customs provided cryptocurrency foundation course to our prosecutors.

Our case successes demonstrate the expertise we are developing in such areas, and through our network of prosecutors we will continue to ensure that such expertise is shared across the organisation.

• In January 2023, we successfully prosecuted four offenders for fraudulently obtaining and laundering Bitcoin and other cryptocurrency worth tens of millions of pounds from an Australia-based cryptocurrency exchange. The offenders were associates of another fraudster who identified and then exploited a loophole on the cryptocurrency trading platform which allowed him and his associates to dishonestly obtain credits worth £21 million at that time. We used Civil Recovery powers to obtain a Civil Recovery Order against the estate of the main perpetrator, who had died before he could be charged, and confiscation proceedings are on-going against the other defendants.
• In May 2023, we successfully prosecuted an individual responsible for running an industrial-scale facilitation of fraud through a website which provided a one-stop crime shop paid by monthly Bitcoin subscription. This case highlights the importance of domestic and international cooperation in successfully bringing such cases before the courts.

Outcome: Training and support materials are up-to-date and easy to find

SEOCID has developed a new induction pack for prosecutors, overseen by its Legal Training Committee. The committee has supported the rolling programme of induction events for new lawyers and is also focused on developing a catalogue of training materials to support lawyers in meeting the challenges of prosecuting ever more complex, serious economic and organised crime. One of the objectives behind setting up the SEOCID is to enable our lawyers to undertake all types of work across SEOCID and thereby, ensure operational resilience to respond to changes in demand. Prosecutors can also develop a bespoke training plan aligned with the advanced criminal litigation skills expected from a confident and competent specialist prosecutor who can deal with any file that comes across their desk effectively.

In May 2021, CPS POCD developed a new technical Proceeds of Crime manual. This was published in a dedicated intranet hub for CPS POCD, improving accessibility to economic crime specific legal resources for prosecutors.

The CPS continues to monitor and update its prosecution guidance. For example, in June 2021 we published our revised Money Laundering Offences Legal Guidance for prosecutors, to clarify that it is possible to charge someone under section 330 of the Proceeds of Crime Act 2002 even though it cannot be proven that money laundering was planned or undertaken. All CPS legal guidance for prosecutors (prosecution guidance) is accessible on our website.

Digital Capability

Aim: Digital tools are utilised for case management, preparation and presentation in economic crime cases

Outcome: Evidence is clearly presented, with any data illustrated, so it’s easily understood at court

Building on our previous experience of using digital tools in economic crime case proceedings, the CPS is working with HMCTS on a pilot for using digital jury bundles for trials in criminal proceedings. In August and September 2023, we conducted mock trials in selected court centres. These trials tested the technology, planning and operational changes needed and whether jurors would find digital bundles easier to use than paper ones. In cases where they have been used, jury tablets have enabled easier navigation of large jury bundles and provided greater opportunity for jury members to explore the evidence in an accessible manner. Tablet devices have also facilitated a more efficient trial process through easier navigation and annotation of the evidence, which can help ensure that the evidence is understood. The CPS support the rollout of such technologies across the justice system.

We are engaging with HMCTS on their DAVE (Digital Audio-Visual Evolution) project which aims to deliver additional equipment to enhance the court user experience, for example, additional larger monitors within the courtroom. 

Outcome: Use data to identify thematic trends and inform future planning, improving our response to the threat

In June 2022, we launched the CPS International App with the aim of improving the management of our international casework and the way in which we oversee caseloads from and engage with countries around the world. Through this central digitalised system, the International App removes the need for CPS Areas to maintain separate records of MLA requests.

In proceeds of crime casework, we liaise closely with the UK Central Authority in the Home Office to reconcile respective case lists and ensure overall case management and progress. We anticipate that the App may also help us to identify trends relating to international cooperation in cases with an international dimension, including economic crime.

Outcome: We conduct virtual hearings where appropriate

During the Coronavirus Pandemic, the CPS considerably expanded the use of remote evidence, frequently using the HMCTS Cloud Video Platform (CVP) to allow victims and witnesses to give evidence from locations more convenient to them. We hope that the use of CVP becomes much more commonplace in the future, particularly for vulnerable and elderly witnesses. In May 2021, two fraudsters were imprisoned for defrauding vulnerable victims out of £36 million in a ‘boiler room’ fraud operation. The total number of victims in the case was 112. Considering the needs of all victims, 23 victims gave evidence via HMCTS Cloud Video Platform.

Outcome: Our IT infrastructure effectively accommodates economic crime cases

The CPS Digital and Information Directorate’s (DID) mission is to deliver data and technology that enable prosecutors to focus on high quality casework to support the delivery of justice.

In 2022, CPS DID began a process to replace the existing CPS Case Management System, to make it more efficient and user-friendly. We are running a series of exercises to define user needs around key elements of the work. This includes a current work management discovery project, which has employed extensive user research to uncover the key challenges our people experience with current task management. It will then look at the technical feasibility of potential solutions to address challenges. Further discovery projects are also planned, which will look at off-system cases and how we receive case materials from the police. 

Outcome: The use of AI in disclosure is explored

The CPS is committed to exploring where AI may be deployed to support our work. We are actively linking in with policing and other partners, as well as our tech suppliers, to explore options around other new technologies, including where we may benefit from the use of AI, but with due care to the risks and concerns around security.

We have launched our Case Review app (Polaris) and are looking at its application more widely for case review and redaction. The app has been in Private Beta (live testing with a small number of users) since early June 2023. It provides improved reading and searching of case materials, and one-click redaction. We have received a hugely positive response from the users and are now planning its wider roll-out.

Strategic Partnerships

Aim: CPS operational insights are used by partners to improve the UK’s response to economic crime

Outcome: Relevant legislative reforms and wider government objectives, strategies and initiatives reflect our priorities and insights

Since the launch of the CPS Economic Crime Strategy, we have shared our operational insights to help inform several government priorities and actions.

Economic Crime and Corporate Transparency Act 2023

Corporate Criminal Liability (CCL)

The CPS, supported the Law Commission review of Corporate Criminal Liability, this included the former DPP taking part in webinar debates to present unique operational insights to advocate for the expansion of the current ‘failure to prevent’ model, which exists for Bribery and Facilitation of Tax evasion, to wider economic crime, including Fraud and Money Laundering. We also worked, alongside operational partners, to support the Government in considering the options for reform as set out in the June 2022 Law Commission report. We therefore welcome the progress in expanding the ‘failure to prevent’ model to Fraud, in the Economic Crime and Corporate Transparency Act 2023 (the ‘ECCT Act’). We also support the amendment which reforms the Identification Doctrine for particular economic crimes only, but we also recognise the importance of the Government’s commitment to legislate for further reform of the Identification Doctrine for all crime at a future legislative opportunity.

Recovery of Cryptoassets

The ECCT Act also contains amendments to the Proceeds of Crime Act 2002, which will enable law enforcement to seize and recover crypto assets which are the proceeds of crime or associated with illicit activity such as money laundering and fraud more quickly and easily. The CPS has been engaged in sharing operational insights and, highlighting prosecutor views on the operation of payment orders issued by the magistrates’ courts and how that can be expanded to cover payments from crypto assets to assist in the enforcement of Confiscation Orders – this is now included in the new provisions of the ECCT Act.

Fraud Strategy – Court Capacity

The CPS has supported the Government commitment in the Fraud Strategy to consult on solutions to improve the volume and speed of fraud cases. Despite Fraud accounting for over 40 percent of all crime, currently less than 1 percent of all frauds committed end with a criminal justice outcome. The Fraud Strategy commits to government investment to increase police capacity dedicated to tackling fraud. Given the scale of fraud and the investment in additional law enforcement resource, it is vital that the criminal justice system, as a whole, is able to deal with any additional demand that this creates, including for the court system.

The CPS continues to support any plans for dedicated economic crime courts, a focus on early guilty pleas and the use of virtual case management hearings at the earliest stage. The CPS believes that case management could also be enhanced by ensuring that complex economic crime cases go before specialist judges who have the expertise to effectively deal with such cases. Virtual hearings would also be beneficial for confiscation and related proceedings, which can have time limits attached to them.

Fraud Strategy – Independent Review into challenges of investigating and prosecuting fraud

The CPS welcomes the commitment in the Government’s Fraud Strategy published in May 2023, to conduct an Independent Review into the challenges of investigating and prosecuting fraud, including modernising the disclosure regime for cases with large volumes of digital evidence. For the CPS these are issues that apply to a range of crime types, not just economic crime, and we have sought to support the Government in making sure that challenges and potential solutions are considered for all crime types where there may be large volumes of digital material. We look forward to continuing to work with partners and the Independent Reviewer, Jonathan Fisher KC, to explore how the disclosure process could be improved to make it more manageable in the digital age.

Economic Crime Plan 2 (2023-2026) – CPS Action

The CPS contributed to the development of the Economic Crime Plan 2 and continues to support the delivery of its ambition. The CPS jointly owns an action which commits to investing in additional capacity to improve the detection and disruption of money laundering, criminal use of crypto and money mules, and increase asset recovery.

The CPS Proceeds of Crime Division will receive funding for a resource uplift from the Economic Crime Levy to complement the additional law enforcement response to recover criminal assets, specifically in relation to civil recovery, and reconsideration of confiscation orders as part of enforcement activity and prosecutor presence part of the multi-agency Regional Asset Recovery Teams (RARTs), based in the Regional Organised Crime Units (ROCUs).

Anti-Corruption Sanctions Regime

In 2021 the UK introduced a new Anti-Corruption Sanctions Regime. We engaged with relevant partners to share our operational insights around the importance of ensuring that we could continue to take prosecution or asset recovery action when financial sanctions are imposed on individuals. In 2022 the UK Government issued a General Licence which allows asset recovery action to take place against any property otherwise subject to a financial sanction.

Outcome: We are a key partner in delivering a whole system response to economic crime

We work closely with partners, including the SFO, to provide asset recovery expertise across government through the Strategic Asset Recovery Group (SARG). Our recent engagement has enabled us to submit bids for projects from the dedicated funding stream, attached to this Group, to support investment in key national and regional capabilities or test innovative new approaches to improve asset recovery processes and performance.

Tackling economic crime requires a sophisticated multi-agency approach and the CPS plays a vital part in that response, including through the National Economic Crime Centre (NECC). The CPS is working with the NECC at both an operational and strategic level. Our Heads of the SEOCID Regional and Wales Division and the CPS Proceeds of Crime Division sit on the NECC Strategic Board. This enables us to come together with partners to tackle economic crime and we have utilised this engagement to raise issues of importance to the CPS, including Corporate Criminal liability reform.

In March 2023, the DPP attended the Economic Crime Strategic Board (ECSB), chaired by the Home Secretary and Chancellor, which agreed on the publication of the Economic Crime Plan 2. The ECSB maintains strategic oversight of the Economic Crime Plan and brings together senior figures from the Government, law enforcement, prosecutors and the private sector including the financial, legal and accountancy sectors. Through CPS engagement on this, we continue to demonstrate that we are a key partner in delivering the ‘whole system’ response to tackling economic crime.

Outcome: Our responses to new and emerging threats and challenges, including those stemming from Covid-19, are planned and delivered with, and through, key partners

Through the Covid-19 pandemic we continued to engage with partners to build our understanding of new and emerging threats emerging from that situation, including through engagement in relevant cross-government and agency forums, such as OP ETHERIN Threat Group (a multi-agency coordinated response to Covid-19 frauds).

The following case is an example of a dynamic and quick investigation and prosecution outcome, which was only possible through close collaboration and planning with our law enforcement partners. In August 2021, a text scammer was jailed for sending out bulk text messages to members of the public claiming to be from various well-known organisations (Royal Mail, Nationwide, HSBC, THREE and EE). The victims were directed to fake websites where they were asked for personal financial information, including their banking details. Notably, messages that claimed to be from HMRC sought to attract victims to provide personal details via a hook that they may be eligible for a COVID-19 grant, targeting those who may have suffered due to the COVID pandemic. Based on the average loss to victims of “phishing” fraud and the number of victims’ personal details found in the defendant’s possession, the total potential loss was over £185,000.

The following case is an example of SEOCID working closely with law enforcement to successfully convict the creator and administrator of a website, which allowed users from across the world to buy tools for facilitating fraud, paying a monthly subscription. The scale can be summarised as: 10 million fraudulent calls made globally in 12 months, 2.5 million calls in the UK, worldwide losses exceeding £100 million, and losses in the UK over £43 million for over 4,500 victims of fraud. The challenges included the computer servers being overseas and moving between countries. The Metropolitan Police sought early advice from the CPS, and this led to collaborative working that enabled evidence from abroad via International Letters of Request. Partnership-working between the metropolitan police and SEOCID helped us to develop an investigation and prosecution strategy. The website owner, the main defendant, pleaded guilty and was sentenced to imprisonment for more than 13 years in May 2023. 

Outcome: Our diverse partners understand the different ways in which CPS expertise contributes to their work

The CPS sits on the Home Office Fraud Reform Programme Board and the Anti-Money Laundering and Asset Recovery (AMLAR) Programme Board which oversees the implementation of the Fraud Strategy and the Economic Crime Plan 2. We supported the development of these and now we continue to provide operational insights and contribute to achieving common objectives.

The CPS SEOCID continue to chair a multi agency Disclosure Board, which includes partners from the NCA, HMRC and SFO and an opportunity to share learning and come together to consider issues and challenges under the current disclosure regime. Through this forum, we also continue to promote the importance of early engagement between investigators and prosecutors. This is considered key to effective case-building and successful prosecution outcomes. It is particularly encouraged in The Director of Public Prosecution’s Guidance on Charging 6th Edition in serious, sensitive, or complex cases.

Building and maintaining relations with other prosecuting authorities around the world is a key part of our work. For example, through our active membership of the Camden Asset Recovery Inter-Agency Network (CARIN) Steering Group, we continue to engage with a network of practitioners from 171 countries who investigate and prosecute asset recovery casework. Our presence on the Steering Group is currently also supporting the delivery of the Financial Action Task Force (FATF) recommendation for jurisdictions to be active members of their regional ARINS.

Outcome: Operational delivery is advanced by strong international partnerships on economic crime

In 2023, the CPS refreshed its International Strategy, which sets out the objectives for our international work, whether it is assisting the police to gather evidence from other jurisdictions, locating suspects who have fled abroad or recovering criminal assets. Therefore, this new strategy will complement the CPS Economic Crime Strategy.

In September 2023, the CPS hosted the annual conference for the International Association of Prosecutors, the largest global prosecution conference. The conference focused on developing international cooperation to meet the challenges posed by the changing nature of crime. Presentations were delivered by CPS prosecutors and prosecutors from around the world, and topics included asset recovery and cybercrime. Around 450 lawyers attended from 90 countries, and nearly 200 bilateral meetings on individual cases took place in the margins, all with the aim of working towards achieving justice across borders.

The CPS deploys Liaison Prosecutors (LPs) around the world, as part of a collective HMG effort to deliver improved criminal justice outcomes for the UK. Liaison Prosecutors have enhanced our judicial cooperation (MLA, Extradition and Asset Recovery requests), by focusing on reciprocal casework, and forging strong and productive relationships with overseas authorities. The CPS has a LP embedded at Eurojust who can facilitate cooperation with other jurisdictions, as well as hold coordination meetings, where there may be parallel investigations ongoing. Joint Investigation Teams (JITs) are often the most effective way of investigating and prosecuting cases where criminals operate across jurisdictions.

The CPS is committed to working with overseas criminal justice partners to combat the threat. In February 2023, three hedge fund managers were found guilty of fraud by abuse of position of trust and sentenced for a large-scale fraud which amounted to losses of $8.45 million which were meant for the people of Libya.

Casework Quality

Aim: An innovative approach will ensure our casework delivers improved justice outcomes in a timely manner

Outcome: We have the right structures and resources in place at a local, regional and national level

In April 2022, we launched the Serious Economic, Organised Crime and International Directorate (SEOCID), bringing together specialists on fraud, international, extradition, organised crime, and proceeds of crime. SEOCID ensures that we have the resilience, expertise and flexibility in our staff and our organisational structure to best respond to new and changing areas of complex crime, which includes economic crime.

The CPS Proceeds of Crime Division (POCD) now conducts all confiscation casework from CPS Areas, as soon as a timetable for confiscation has been set by the Crown Court, including cases that have been committed under section 70 of POCA. To ensure that proceeds of crime opportunities are still considered in every case at the local, regional, and national levels, CPS POCD has an ongoing Confiscation Project to ensure early engagement with prosecutors across the CPS, to ensure there is an Asset Recovery Strategy at the outset in every relevant case. 

Outcome: Improved criminal justice outcomes in a timely manner

We continue to pursue fraudsters and bring them to justice. Since the launch of the Strategy, in the period between April 2021 – March 2023, the CPS prosecuted over 13,484 defendants, where Fraud and Forgery was the principal offence category.

CPS continues to maintain a high conviction rate and steady charge rate where Fraud and Forgery was the principal offence. In the year ending June 2023, the conviction rate was 84.1 percent. and the charge rate was 76 percent.

SEOCID prosecutors have worked on some of the most serious, high-risk, and complicated cases that we have seen as an organisation. From romance fraud to money laundering, case successes include:

• In November 2022, a high-value romance fraudster was convicted of four counts of Fraud by False Representation after of duping victims out of just over £324,000 in an investment scam.
• A romance fraudster who conned 80 victims out of significant sums of money was jailed in December 2022. 
• In April 2022, a group of individuals and corporate bodies were sentenced for their involvement in bribing a senior manager at Coca Cola Enterprises UK Limited.
• In June 2023, a former director of a finance company, was sentenced to 14 years' imprisonment for being responsible for a £70m investment fraud which stole money from members of the public. The fraudster was found guilty of fraud by false representation, fraudulent trading, and money laundering at Southwark Crown Court. 

Outcome: We proactively shape complex economic crime cases, providing early investigative advice

The CPS is committed to working with criminal justice partners to combat fraud and economic crime. Early engagement between investigators and prosecutors is vital to help develop case strategies, especially given the challenges around large volumes of digital material and disclosure. Early engagement with the defence is also crucial in helping to identify reasonable lines of inquiry, as well as narrowing down the case issues.

The following cases from 2022 and 2023 (respectively) demonstrate the impact of our engagement with law enforcement:

• The CPS advised our police partners throughout a complex international investigation which led to the successful prosecution of four offenders for fraudulently obtaining and laundering Bitcoin and other cryptocurrency worth tens of millions of pounds from an Australia-based cryptocurrency exchange. Painstaking analysis of vast amounts of digital material and collaborative liaison with the Australian and Finnish authorities enabled us to mount a successful prosecution against the criminals.
• In a complex and challenging case, the CPS worked with the Metropolitan Police and the many national and international law enforcement partners to secure the evidence for us to present in the case where the defendant was found guilty of making or supplying articles for use in fraud, encouraging or assisting the commission of an offence, possessing criminal property, and transferring criminal property. As a result, we were able to show how the fraudster was instrumental in the setting up of the website which gave people the tools to defraud others and causing losses of more than £43 million to victims in the UK alone.
• Following a collaboration with the NCA, the CPS was able to build a strong case resulting in the conviction of two men for offences including money laundering and supplying fraudulent passports to criminals, disrupting a major organised crime network, and helping to dismantle their illegal operation. The CPS worked closely with the NCA prior to charging the case, right through to conviction.

In December 2021, the CPS held a joint HMRC investigator and prosecutor virtual conference. Through a series of presentations and talks on issues such as early advice for investigators, handling of disclosure, asset recovery, international issues, and corporate criminal liability the conference brought together around 760 delegates and demonstrated the importance of working together to bring both individuals and corporates to justice in a timely manner.

In October 2022, the SEOCID launched a new Disclosure Standard, which further promotes early engagement between investigators and prosecutors. These standards set out the expectations of the approach to disclosure, the standards required for the preparation and completion of specific documents used to manage the disclosure process and the continuing duty of disclosure under the Criminal Procedures and Investigations Act (CPIA) 1996 and the CPIA Code of Practice.

SEOCID held a Disclosure Conference in June 2023 with operational partners reinforcing the importance of early engagement between investigators and prosecutors, which can help develop effective case strategies around disclosure, especially in cases with large volumes of digital material.

Outcome: Asset recovery (both criminal and civil) and ancillary orders are successfully considered and pursued in all economic crime cases where possible

In 2022 CPS POCD developed a new CPS Proceeds of Crime Strategy with the overarching aim of adopting a robust, targeted approach to recovering the proceeds of crime, depriving criminals of their ill-gotten gains.

• This commits to the identification and referral of suitable cases for confiscation reconsideration applications where criminals have been convicted of economic crimes. The Reconsideration Team collected £15.7m between 2021 and 2023.
• The CPS has continued to develop CPS POCD’s Civil Recovery capability and capacity as a priority. So far in the Fiscal Year 2023/24, we have recovered over £1.5m.

Our prosecutors have continued to develop case strategies to maximise the use and opportunities for asset recovery, considering all appropriate powers at an early stage:

• In October 2021, the CPS, City of London Police and the private sector worked together, using specialist powers, to achieve the largest ever Account Forfeiture Order (AFO) in the UK. Working with partners across three continents this was an extremely complex investigation which centred around establishing the source of €50m transferred into a UK business bank account, and the subsequent distribution of €11m to individuals and companies outside the UK. Our POC specialists worked with the police to apply to the magistrates’ court for Account Freezing Orders, which can be granted in the absence of a conviction. The orders were granted, and because of specific powers under the Proceeds of Crime Act (POCA), the DPP agreed to appear on behalf of the police. We were able to use our expertise to assist the police in presenting the strongest case, resulting in an AFO for £29m. This case sends a clear message that a company or individual does not have to be convicted for us to pursue, seize, and take the proceeds of crime passing through the UK.
• In August 2023, the former Governor of a state in Nigeria who systematically defrauded the state, and its citizens of millions of pounds was ordered to pay over £101m or face an additional eight years in prison. The CPS was able to prove that the defendant had benefited from his offending and had considerably more assets than he had disclosed. As a result, the judge has determined that the defendant had at least £101m available assets and made a Confiscation Order in that amount, noting that a failure to pay that order in full would result in him being subject to an additional eight years in prison. His solicitor and co-defendant received a Confiscation Order of over £28m and sentenced to 6 years' imprisonment in default, if the order is not paid in full.
• In January 2023, a Confiscation Order was made against an accountant, covering all his available assets, together valued at over £237,000. In April 2021, the defendant was sentenced to 11 years and five months' imprisonment for defrauding the NHS, companies, and individuals. He had three months to pay and in the event of non-payment, the default sentence was set at 20 months' imprisonment. 

Outcome: International deployments are used to tackle economic crime where there is an impact on domestic casework

We have a network of CPS Liaison Prosecutors deployed overseas as well as UK-based ‘roving’ prosecutors, who cover Ireland among other countries. These prosecutors are part of a collective government approach to deliver improved criminal justice outcomes domestically, and to tackle crime in source or transit countries to reduce harm and impact on the UK. The CPS’s network of Liaison Prosecutors forges close relationships with overseas authorities, focusing on reciprocal casework, to overcome operational challenges and enhance our cooperation abilities to improve justice outcomes. They work to ensure that information, evidence, and assets can be secured from abroad, and that suspects and witnesses who are located overseas are available to support domestic investigations and prosecutions.

Examples of their work include:

• In a recent case, one of our Liaison Prosecutors assisted in providing advice and assistance on obtaining key evidence located overseas to support the prosecution of a money laundering offence. By utilising their expert knowledge of judicial cooperation tools, the Liaison Prosecutor secured timely facilitation of the evidence to the CPS lawyer which secured a guilty plea from the defendant. 
• In another recent case, our Liaison Prosecutor worked closely with the CPS Area lawyer and an overseas judicial authority in a European Country which helped secure a successful extradition to the UK so a suspect can be prosecuted for an investment fraud.

Public Confidence

Aim: Victims and witnesses are at the heart of every case, and we communicate effectively about our role in tackling economic crime

Outcome: Our economic crime policies are developed and informed by victim feedback and community engagement

In April 2021, the CPS hosted a Community Accountability Forum (CAF) on economic crime, bringing together community members and colleagues from across the criminal justice system and voluntary sector to hear insights from expert speakers and attendees about how to better support victims and witnesses. Feedback received went on to inform the first action plan for the CPS Economic Crime Strategy and the development of guidance for prosecutors focused on economic crime victims and witnesses.

In March 2022, we appointed two Inclusion and Community Engagement Managers (ICEM) to lead on SEOCID Community Engagement, with focus areas including Economic Crime and Proceeds of Crime. The ICEMs have now established a SEOCID Community Engagement Delivery Group (‘Delivery Group’) to support the development and delivery of external community engagement relating to economic crime and organised crime working with partners in the criminal justice system, charities, and the private sector.

In April 2023, our SEOCID ICEMs launched an Economic Crime toolkit to support the CPS ICEM Network to identify and facilitate local and regional level opportunities for engaging with communities on issues relating to economic crime, and thereby help increase public confidence in CPS prosecution of such crime.

Further examples of ICEM engagement work:

• Case Study: Age UK – In September and October 2023, our ICEMs engaged with Age UK, and utilised the Economic Crime Toolkit in discussions with 16 regional Fraud Advisory Managers to help inform their anti-fraud programme. In addition to sharing our work, we supplied them with four questions to add to their annual survey which goes out to over 1,000 people over the age of 60 to record their fraud-related experiences. Feedback from this engagement will feed into CPS’ wider work with victims. We have also invited Age UK to talk to the CPS about their work and how best we can work together to improve our collaboration with the voluntary sector.
• Case Study: Fraud Women’s Network – In July 2023 one of our Chief Crown Prosecutors met with the Chair of the Fraud Women’s Network to talk about the work of the CPS and our commitment to building stronger relationships with networks aimed at preventing fraudulent criminal activity. As a result of this meeting in September 2022, our Chief Crown Prosecutor was invited to be a keynote speaker at the annual Fraud Women’s Network event, attended by over 100 members. 

Outcome: A clear economic crime communication strategy, promoting our work and casework successes, is delivered

In January 2023, we launched a SEOC Communications Plan which, includes an objective to “Build public confidence in the CPS by increasing public understanding of the CPS’s unique role and success in tackling economic and serious organised crime”, thereby signalling the continued importance of this for the CPS.

The CPS continues to work with NECC partners on a more strategic approach to communications across the public and private sectors, which includes an aim of preventing people from becoming victims of economic crime in the first place. This has resulted in the development of a Fraud and Cyber Crime Communications Toolkit, which the CPS is applying in all our future communications.

We are raising awareness of cases that we have prosecuted through both national and local communications. By demonstrating the outcomes of our casework to the public, we also aim to help prevent people becoming victims in the first place, break the stigma associated with economic crime, and send a clear signal that criminals will face justice.

The CPS press releases have sought to raise awareness of the techniques used by fraudsters targeting vulnerable individuals:

• Investment Fraud
  • In July 2022, two scammers were found guilty of conspiracy to defraud and money laundering. The pension fraud worth over £20 million caused many of the victims to lose their entire pensions. The fraudsters devised a plan to persuade pension holders to transfer their pensions into accounts controlled by one of the defendants. The customers were persuaded to sign application forms which had blank sections, later completed by the scammers.
  • In January 2023, a couple was imprisoned for defrauding multiple elderly victims out of over £2.7m in a boiler room investment fraud. The defendants were part of an organised criminal group. This was a particularly unpleasant fraud, which resulted in vulnerable victims losing their life savings and impacting their physical and mental health. The defendants had cynically targeted elderly and generally inexperienced investors. The investors were cold-called at home and pressured into investing money in schemes with the promise of high-value returns. The fraudsters presented themselves in a credible way and secured the trust of over 170 victims.
• Romance fraudsters are known to exploit vulnerable victims during opportune times of the year such as Valentine’s Day. The CPS has made press releases and tweets ahead of these times to raise awareness of this type of fraud.
  • In November 2022, a high-value serial romance fraudster was found guilty of duping victims out of over £320,000 in an investment scam. The fraudster pretended to four female victims, whom he met through an online dating agency, that he was a successful stockbroker and that he could make high returns on investment opportunities, in different places including Hong Kong. He also used aliases in his dealings with the victims. The total losses suffered by the four victims amounted to over £320,000. The CPS will be pursuing ill-gotten gains through the Proceeds of Crime Act.
  • In January 2022, an individual was imprisoned for 2 years and 4 months. He was committing multiple romance frauds on behalf of an organised crime gang with links to the ‘Black Axe’ group. This was uncovered by the National Crime Agency and prosecuted by the CPS. The individual used a false identity to work as a school caretaker and then using this false identity, he arranged to meet women via internet dating websites and befriend them. As the relationships developed, he would ask for money with the pretext that they were helping him out of some unforeseen difficulties. He had been in contact with over 200 people but some of the victims had not been identified. He obtained approximately £20,000 in total from four of the victims that were identified. The CPS press release urged people looking to form relationships to take simple steps to help protect themselves, families, and friends from romance frauds, but highlighting the techniques used by fraudsters.

Outcome: The diverse needs of victims and witnesses will be considered so they are supported to give their best evidence

In September 2021, the CPS developed, for the first time, guidance focussed solely on how our prosecutors engage with the victims of economic crime. It sets out how we will add real value to improving the experience for victims by ensuring that investigators and prosecutors work closely and have a joint victim and witness engagement strategy from the outset. This is vital in complex economic crime cases which can have multiple victims based in multiple jurisdictions. Our work to achieve best evidence from victims is supported by our initiatives under the Digital Capability pillar of this Strategy.

More broadly, economic crime operational insights and community engagement initiatives are feeding into the CPS’ long-term Victims Transformation Programme. This programme is underway to improve the way we communicate and engage with victims of crime. We are designing a new universal service for all victims with an enhanced service for victims with the greatest needs, incorporating the views and experiences of stakeholders and victims. We are also developing a POC-specific process to support victims where there are parallel Compensation Orders. The Victims Transformation Programme will be aligned with the forthcoming Victims Bill and Victims Code which set out the minimum level of service victims should receive from the criminal justice system.

Outcome: Proceeds of crime, both domestically and internationally, are recovered, depriving criminals of their ‘ill-gotten gains’ and compensating victims where possible.

In the last five years (2018 to 2023) over £480 million has been recovered from CPS obtained Confiscation Orders, ensuring that thousands of convicted criminals cannot profit from their offending. Of this amount, £105m has been returned to victims of crime by way of compensation.

• Recently, the CPS prosecuted a former solicitor who scammed victims through the investments that he suggested. He was arrested for theft and fraud offences and ultimately made subject to a Confiscation Order in the sum of over £700,000 with a significant number of Compensation Orders. The CPS embarked upon a realisation process, and a total of over £650,000 was realised without the appointment of a receiver, which meant that the full amount was made available as compensation for the victims of the fraud.
• In another case, we negotiated with the USA to secure the return of £570,000 forfeited in domestic forfeiture proceedings in the USA so that these funds can be used to pay a Compensation Order to the victims whose financial details had been stolen from the accounts of Just Eat.

The CPS has also established a Proceeds of Crime Country Leads Network which covers 13 priority countries, and the Crown Dependencies. This network enables improved communication between front line lawyers in CPS POCD and our overseas counterparts who have extensive knowledge and expertise in Asset Recovery. This has allowed us to overcome unnecessary delays which hinder our ability to achieve the best outcome, enhance the UK’s reputation and increase the recovery rate of proceeds of crime internationally.

Future Work

Whilst we have made significant progress, at this mid-point stage, towards the aims of our CPS Economic Crime Strategy 2025, there is more to do through a joined-up, coordinated approach with our domestic as well as our international partners to effectively address the threat from economic crime. The scale and complexity of economic crime continues to evolve and cannot be underestimated. It requires a sophisticated multi-agency and whole-system approach, and the CPS will continue to play a vital part.

The following is a high-level outline of some actions that the CPS will focus on in delivering the CPS Economic Crime Strategy through to 2025:

Our People

We will...

• Develop new guidance and update existing guidance for prosecutors on the new ‘failure to prevent’ Fraud Offence and reform of the Identification Doctrine, in the Economic Crime and Corporate Transparency Act.
• Update our Legal Guidance for Money Laundering to provide clarity for prosecutors when considering cases involving Money Mules. 
• Work with the National Crime Agency and other operational partners, as set out in the Government’s Economic Crime Plan 2, to enhance capabilities to investigate and prosecute the use of crypto assets to launder illicit finance, by considering joint training opportunities. 

Digital Capability

We will...

• Conduct a digital discovery project into ‘case materials’, looking at how we receive case files from policing, to ensure that our technology supports the receipt of complex case information, supports data quality improvements, and enables two-way communication throughout each stage of a case.
• Conduct a digital discovery project into ‘off-system’ cases, i.e., those too large to be held on the existing CPS Case Management System, to ensure that we deliver technology to support effective management of such cases.

Strategic Partnerships

We will...

• Share our operational insights with the Government to support an ambitious new Anti-Corruption Strategy. 
• Work with the Independent Review to explore how the disclosure process could be improved to make it more manageable in the digital age. This includes the CPS proactively considering and feeding in potential reform proposals. 
• Work with the NECC and other partners to consider the implications of new technology, including Artificial Intelligence, for the way in which economic crimes may be committed in the future and what we need to do to combat the threat effectively.  
• Work with the NECC to consider the interactions between Cybercrime and Fraud.
• Support the Government commitment in the Fraud Strategy to consult on solutions to increase the volume and speed of cases, by providing operational insights to help shape options for enhancing the speed of economic crime cases through the court system. 
• Work with government and operational partners in considering and taking forward appropriate recommendations from the Law Commission’s Review of Confiscation provisions of the Proceeds of Crime Act. 
• Work with the NECC and other operational partners to provide our operational insights into the process of establishing the National Fraud Squad and planning for the downstream impact of the additional investigative resource on the CPS. 
• Engage with the new Asset Recovery Support Unit, as set out in the Economic Crime Plan 2, which looks to bring together subject matter experts to advise on asset recovery to ensure that it is considered early on in economic crime cases. 
• Provide evidence to the Home Affairs Select Committee Fraud Inquiry, launched in September 2023. 
• Support the development of the Joint International Crime Centre, which enhances the UK’s capabilities around international law enforcement cooperation and coordination. 

Casework Quality

We will…

• Conduct case debriefs, alongside law enforcement partners, in all relevant cases, to identify trends and learning which can be fed into the SEOCID Casework Quality Board.
• Work with the SFO to consider revisions to the joint CPS-SFO Deferred Prosecution Agreements, Code of Practice, with a view to applying insights from casework.
• Update and agree MOUs with all existing investigative stakeholders to ensure clear casework responsibilities and processes. 

Public Confidence

We will…

• Refresh the Economic Crime Victims and Witness Guidance, following the creation of SEOCID as well as the work that is being done to implement the CPS Victim Transformation Programme. 
• Hold another Community Accountability Forum meeting to ensure that our economic crime policies are developed and informed by community engagement, including victims’ groups and the voluntary sector.
• Continue to work with the NECC and Home Office, to support a strategic, joined-up approach to public communications, which includes coordinating with our partners in relation to national communication campaigns.

CPS 2030

We will continue our close working with the Ministry of Justice to develop a vision for the Criminal Justice System. We are providing operational insights to support the identification of system-wide priorities and shared objectives.

The current CPS organisational 2025 five-year strategy was launched on 1 April 2020, which set out the CPS strategic aims and outcomes under five themes, which are: Our People, Digital Capability, Strategic Partnerships, Casework Quality and Public Confidence. This Economic Crime Strategy aligns with the CPS 2025 strategy. Planning for the next organisational five-year strategy, CPS 2030, is already underway, with an intended launch date of 1 April 2025. Our aim is to ensure that our next strategy reflects the needs, priorities and lessons learnt from across the organisation, including in helping to tackle the changing nature of economic crime.

List of Abbreviations

CPS - Crown Prosecution Service
EC - Economic Crime
HMCTS - His Majesty’s Courts and Tribunals Service
HMG - His Majesty’s Government
HO - Home Office
MLA - Mutual Legal Assistance
NCA - National Crime Agency
NECC - National Economic Crime Centre
POCA - Proceeds of Crime Act
POCD - Proceeds of Crime Division 
SEOCID - Serious Economic and Organised Crime and International Directorate
TaCA - EU-UK Trade and Cooperation Agreement