’I do tend to see a lot of stuff labelled as ghost broking, where it is probably not,’ says director 

Insurance firms have been warned that there is a “load of data” to show there are cases where ghost broking is being confused for other similar crimes.

During Insurance Times’ latest Fraud Charter last month (19 September 2023), Matt Gilham, a director at Whitelk Consulting, claimed there were instances where scams – such as application fraud – were being mislabelled as ghost broking.

Application fraud originates from fraudulent policyholders and can include misrepresentation of information of fronting. 

Gilham also warned, however, that there were instances where ghost broking may take place, but was being mistaken for another type of scam.

Ghost brokers are individuals or organised criminal gangs who sell forged or invalid insurance policies to consumers.

Typically, these policies are obtained fraudulently by using false information in the application process.

“I see a load of data where, say, application fraud is mislabelled as ghost broking,” Gilham said.

“It could be a whole load of stuff that looks like ghost broking, such a criminals taking out policies or a group of customers that are gaming.

“But, I do tend to see a lot of stuff labelled as ghost broking, where it is probably not or sufficiently unclear.”


Ghost brokers are usually unregulated and promote their services under the guise of being legitimate brokers, who can obtain cheaper insurance policies.

This fraudulent activity means that insurance companies lose money and policyholders are unknowingly under or uninsured.

While Gilham said that the crime can sometimes be mislabelled, he also warned that there were instances where it may not be getting enough recognition.

“I have also seen things that are highly indicative of ghost broking that are just generally labelled as identity theft,” he added.

“Maybe not in the insurer space, but in the broker space where there is not that visibility of things linking together when you get to underwriting level.”


This came after the ABI revealed earlier this year (24 August 2023) that the value of an average insurance scam in 2022 increased to £15,000, up 20% on 2021’s figure.

It also revealed that 42,500 motor scams were uncovered last year, representing 59% of total insurance claims fraud.

Detective chief inspector Tom Hill, from the City of London Police’s Insurance Fraud Enforcement Department (Ifed), said at the time that both Ifed and the insurance industry “cannot afford to take our foot off the pedal when it comes to uncovering and disrupting fraudsters”.

”Many victims of insurance fraud are members of the public, from people who have their identities stolen to help facilitate fraud, to people who have unknowingly bought fake motor insurance from ghost brokers,” he added.

To help further ensure scams were being defined in the right way, Mark Allen, assistant director and head of fraud and financial crime at the ABI, said the association would be moving to another system of classification in 2024.

“It is an iterative process and we are constantly looking to improve our statistics,” he added.

“With that in mind, we are moving to a new system of classification next year, whereby we are mirroring the fraud definitions being used by the Insurance Fraud Bureau (IFB).”