On Monday 3rd September I am attending the 30th Anniversary of the Cambridge International Symposium on Economic Crime.
I have been fortunate to have been associated with the Symposium for 29 years and I have been invited to present many papers and chair a number of breakout sessions.
The brainchild of a brilliant Cambridge law Don, Dr Barry Rider, the Symposium has been the best possible sounding board for international law enforcers and financial and economic crime policy makers to meet in the delightful surroundings of Jesus College, Cambridge, and to discuss issues of mutual concern.
I want to quote from the invitation letter written by Dr Rider to explain the significance of this important, indeed unique event.
"...The annual Cambridge International Symposium on Economic Crime is not just another conference!
It would not be celebrating its thirtieth year if it were! Over the years, the Cambridge Symposium has established itself as a unique vehicle for promoting, at a truly international level, greater understanding of the real and practical issues involved in preventing and controlling economic crime, corruption and abuse, and thereby facilitating meaningful co-operation...It seeks to involve speakers and panellists with practical knowledge and experience from around the world who can not only share their expertise, but also act as catalysts in promoting awareness and discussion at all levels within the Symposium.
The primary theme of the Conference addresses some of the myths and realities in terms of risk and its management, of the consequences – both direct and indirect, of the international financial crisis and the near collapse in confidence as to the integrity of many of our financial institutions. At a time when many agencies that have been criticized for failing to act sufficiently robustly are being restructured or replaced, there are profound uncertainties not only for those in the regulatory and enforcement sectors, but also for those in the regulated communities.
We are not, however, concerned only with the identification of such risks, but also their management and containment. During the week we will address a host of issues that threaten stability and integrity and in particular the insidious threats presented by organized crime, fraud, corruption and money laundering...Consequently the programme is of very real relevance not only to those involved in law enforcement and supervision, but all those who are concerned to maintain integrity and protect business whether in the public or private sector.
For me, it is a matter of some considerable concern that Dr Rider has opened the doors of Jesus College for 30 years, and the great and the good, as well as a lot of rough-hewn and hardened cops have walked through to debate the phenomenon of international economic crime.
When we started, Financial Crime was not an issue for debate in the UK, there were no financial regulations to speak of, the City was regulated by the City, subject always to the dubious effectiveness of the Prevention of Fraud Act 1953, implemented largely by the ineffectual Department of Trade and Industry (DTI).
The rest of the Fraud regime was largely investigated and prosecuted by Police from the Fraud Squad. There were certain frauds in the VAT and Tax sector which were investigated by Customs and Excise or the Inland Revenue, but the vast majority of fraud prosecutions were brought by Police.
The City of London would have been deeply affronted to have been invited to come and discuss the issue of crime within their hallowed walls. It was not an issue it wished to discuss and the whole place was governed by an arcane set of rules imposed by the City fathers, and overseen by the rebuke of last resort, the height of the Governor of the Bank of England's eyebrow! If any activities needed the attention of the Police, the City fathers used to rely on the services of their own fraud officers, who, while theoretically being a part of the joint unit of the Metropolitan and City Police Company Fraud Department, tended largely to look after things inside the City walls without overly bothering their Met colleagues!
The major issue for debate in those early years was the difficulty we Fraud Squad officers faced in acquiring evidence from certain unwilling persons who did not want to cooperate in our enquiries.
We desperately wanted to be given powers similar to those possessed by the DTI to demand access to the books and records of a company under investigation, and to require them to answer questions about their accounting methods.
Some of us even gave evidence before the Roskill Commission which enquired into the way that Fraud Trials were conducted and how improvements could be made in 1986.
From those early days, and following the proposed reforms in the Roskill Report, the investigation and the management of Fraud has now proliferated into a rash of initials and departments, among whom it is hard to determine any meaningful cooperative activity.
Among the many agencies which now exist to deal with fraud in the UK and in Europe are the following;
An analysis of reported fraud in Government Departments together with anti-fraud guidance produced by the Treasury.
The Fraud Advisory Panel is an independent body of volunteers drawn from the public and private sectors. Members include representatives from the law and accountancy professions, industry associations, financial institutions, government agencies, law enforcement, regulatory authorities and academia.
SOCA was created by the British government in April 2006. It has taken over the functions of the National Crime Squad (NCS), the National Criminal Intelligence Service (NCIS), the role of HMRC in investigating drug trafficking and related criminal finance and some of the functions of the UK Immigration Service (UKIS) in dealing with organised immigration crime. In addition it now includes the function of asset recovery.
The aim of the SFO is to investigate and prosecute serious and complex fraud and so deter fraud and maintain confidence in the probity of business and financial services in the United Kingdom.
This website is published by the National Working Group on Fraud on behalf of the UK Association of Chief Police Officers (ACPO). The website deals primarily with commercial fraud in a policing context.
The Committee on Standards in Public Life was set up in October, 1994. Its terms of reference are: To examine current concerns about standards of conduct of all holders of public office, including arrangements relating to financial and commercial activities, and make recommendations as to any changes in present arrangements which might be required to ensure the highest standards of propriety in public life.
IBAS is an organisation for helping people in disputes with British banks.
Describes the functions of the British banking ombudsman and gives information on how to submit complaints. Various publications including the annual reviews are available online.
Among its many services the BBA provides information about the prevention of fraud and money laundering.
The FSA regulates the financial services industry and has four objectives: maintaining market confidence; promoting public understanding of the financial system; the protection of consumers; and fighting financial crime.
A website produced by the British Government in cooperation with HSBC, Microsoft, the Serious Organised Crime Agency and other organisations to give advice on problems ranging from computer viruses and spam to online rip-offs and identity fraud.
A website produced by the Home Office Identity Fraud Steering Committee, a collaboration between UK financial bodies, government and the police to combat the threat of identity theft.
Advice on how to recognise and avoid scams, from Consumer Direct, a telephone and online consumer advice service, supported by the (UK) Department of Trade and Industry.
Press releases and reports from OLAF, the European Commission's anti-fraud office.
It describes itself as "the financial conscience of the European Union.
The Metropolitan Police Fraud Squad.
The City Police Fraud Squad.
The various Fraud and Commercial departments of the other police constabularies in the British Isles.
Her Majesty's Revenue and Customs.
The Office of Fair Trading.
I am certain there may be others whom I have overlooked, but my point is this.
In the attempts to reduce the incidence of fraud, financial crime and money laundering, have we not been guilty of creating a massive 'talk shop' in which more time is spent debating and discussing the relative merits of individual agencies in dealing with crime, as opposed to getting on with the job of dealing with it?
The Cambridge Symposium on Economic Crime cannot be blamed for the development of this cat's cradle of competing agencies. Repeatedly the Symposium has called for a greater degree of clarity and cooperation in the interdiction and prosecution of major fraud.
Sadly, these eminently sensible requests have not been heeded, and we have now ended up with an edifice which has become more convoluted than a Mandarin Chinese Court.
But no-one can say we didn't try!