Of 48 notices issues over the first year of employing this strategy, only one fraudster reoffended. Temporary detective chief inspector Tom Hill, head of the City of London Police’s Insurance Fraud Enforcement Department, explains the approach in more detail

This year began with a bang for the City of London Police’s Insurance Fraud Enforcement Department (IFED), as the suspect in a high value life insurance fraud case was found to be in breach of his bail conditions in January 2022.

The 42-year-old from Surrey had originally been arrested in September 2021 in connection with a number of fraudulent life and critical illness insurance claims, totalling around £1.3m.

Tom Hill High Res

Tom Hill

After receiving information that he had become a flight risk, IFED officers descended on the suspect and arrested him once again at a property in Staines. He has since been remanded in custody and pleaded guilty to 10 counts of fraud.

His sentencing has been scheduled for late April and IFED hopes to see a proportionate prison sentence for this shameless fraudster.

Cease and desist

While complex investigations into serious or high value offences, like the aforementioned example, are an integral part of IFED’s work, it is also important that we explore alternative methods for lower level offenders.

By tackling fraud at the root, we can stop it from spiralling into a bigger case and prevent further victim losses.

A tactic that we have explored over the past 18 months with positive results is the use of ‘cease and desist’ notices.

This method is suitable for cases involving first-time offenders where there is unlikely to be a charge or conviction at court because it aims to educate the individual and deter them from committing further criminality.

The first step in this process is a thorough review of intelligence around the subject. Once this has been completed, a consultation is held with the insurance company or organisation that referred the case for investigation, to explain the decision behind using the cease and desist method.

Two police officers will then attend the offender’s residence to serve the notice. This document outlines the crime which the individual is believed to be involved in and requests that they cease and desist from any future offending.

The document also explains that if they do continue to offend, they may find themselves to be the subject of a criminal investigation.

The cease and desist notice being served is not the end of the story, however, as the individual is then subject to intelligence checks every six months, to ensure they have not reoffended.

Not a ‘soft’ option

While some people may mistake this approach as a ‘soft’ option, the figures indicate otherwise.

Out of 48 cease and desist notices served within the first year of trialling this method - between September 2020 and September 2021 - just one individual reoffended. Clearly, having the police knock on your door is a sobering experience and is enough to shock first-time offenders into sense.

Besides the positive numbers we have seen, there are additional benefits to using this method.

Firstly, it allows IFED to accept low level cases that would usually be rejected, while still dedicating ample resources to more serious cases.

The notice also helps at court if the individual does continue to offend because it can be produced as evidence of previous bad character, which can then be considered by the Crown Prosecution Service.

More specifically, the notice can overcome issues when ghost broking cases reach court.

To avoid prosecution, defendants often claim that they are unaware of FCA accreditation, or that they only provided a ‘translation service’. The cease and desists notice, however, proves that the ghost broker was aware of their actions being criminal and therefore cuts off these avenues for sidestepping justice.

The employment of any new method is always a risk - in this case, it was one that paid off.

Other units within the police force have recognised the benefits of cease and desist notices and have also incorporated this into their operational activity.

We are confident that, with the continued support of the insurance industry, we can maintain this as an effective means of disrupting low level insurance fraud.