Detective chief inspector Tom Hill, head of the City of London Police’s Insurance Fraud Enforcement Department, discusses how the unit has sought to tackle ghost broking

Illegal insurance intermediaries - more commonly known as ghost brokers - continue to be a blight on the motor insurance industry.

They are a risk to members of the public seeking a good value motor policy – especially in this challenging economic climate.

By manipulating customer details with false information to lower premiums, or - in more serious cases - creating fraudulent documents in support of applications, the City of London Police’s Insurance Fraud Enforcement Department (IFED) continues to receive a large number of ghost broking-related crime reports from the insurance industry.

Tom Hill High Res

Tom Hill

In fact, over 30% of our current investigations involve an element associated with illegal insurance intermediaries.

So, what is IFED doing to tackle this issue?

Eliminating online threats

Firstly, we are addressing the online threat.

Operation Mirage is IFED’s online disruptions initiative, which was first established in March 2021.

Working with the National Fraud Intelligence Bureau (NFIB), the Insurance Fraud Bureau (IFB), social media companies and internet hosting domains, Operation Mirage takes down websites and online profiles where there is a clear, unambiguous breach of the law, or breach of the terms and conditions agreed with the host platform.

Following the launch of Operation Mirage, in July 2021, IFED led a two-week period of focused action against ghost brokers, removing 78 online entities used by fraudsters. This project was called Operation Ironclad.

Working with our partners is crucial to tackling ghost broking in the future.


Ghost brokers can be challenging to prosecute.

There are sometimes legitimate questions raised by prosecutors as to whether victims knowingly turned a blind eye to misrepresentation, as well as challenges for IFED to identify exactly who has committed the misrepresentation to the insurer.

IFED is therefore working closely with specialist fraud prosecutors within the Crown Prosecution Service to discuss these issues and find a way forward.

An example of this was the use of money laundering legislation to send ghost broker Marek Complak to prison for two and a half years in October 2021 or using the Financial Services and Markets Act 2000 to prosecute ghost brokers for acting as unauthorised insurance intermediaries.

IFED has additionally adopted the practice of serving hand delivered cease and desist notices to lower level insurance fraud offenders, including ghost brokers, from July 2021. This followed a trial period of this approach between September 2020 and July 2021.

Using cease and desist notices has allowed us to take on more cases, diverted lower level fraudsters from the criminal justice system and can provide evidence of bad character in future prosecutions.

In 2022, 30 notices were served to ghost brokers - working with the IFB to monitor these offenders, only 4.8% of them were found to have subsequently reoffended. These reoffenders were – and are - being dealt with robustly.

Public awareness

Raising awareness with the public is also key.

IFED sits on the General Insurance Fraud Committee’s application fraud working group. Some excellent work was completed by this body in 2022 through a social media campaign run by the IFB, which was supported by funding and input from IFED.

This initiative used paid-for advertising to target members of the public most at risk of falling victim to ghost brokers.

The campaign, which ran for six weeks from October 2022, achieved some really impressive coverage, including an interview on ITV News with both myself and IFB director Ursula Jallow.

Finally, we continue to speak about ghost broking to European and international colleagues to identify whether ghost broking is an issue in other countries and what their response is.

In parts of Scandinavia, for example, it seems that national identity cards and centrally held address databases can restrict the impact that ghost brokers can have.

This is an interesting finding, however any similar developments in the UK will face fierce debate before being considered.