The Directors National Fraud Authority Third Floor Fry Building 2 Marsham Street London SW1P 4DF BY EMAIL

Dear Sirs FAO:

FROM: UK Fraud Specialists - see below for details

10th November 2011

Stephen Harrison, Chief Executive, National Fraud Authority

We the undersigned share a common concern that elements of the NFAs recent Fighting Fraud Together document, outlining the governments strategy to combat fraud, may create an impression that all is well in the fight against fraud. In fact, a number of significant areas of concern are raised by the documents publication. The questions we should like answered urgently are: With the NFA now firmly under the wing of the Home Office, what percentage of its employees have hands-on fraud experience in either commercial or government departments? Whilst it is important to include civil servants, should they be in the majority? With much fraud now international and or cyber fraud from unknown overseas criminal groups, why does the document and the nature of those included only relate to the UK? Should there be figures incorporated in the document for the percentage of the UK fraud that either originates from or terminates in overseas territories? If these are unknown, then this too should be stated. As the development of stronger working relationships between public and private sector, and charities is a deliverable of the NFA, what hands-on experience does it have in either commerce or the charity sector? Why are the NFAs best practice standards / goals something that many organisations e.g. CIFAS already assume as normal practice? Why are some key and long standing anti-fraud organisations (like CIFAS and Transparency International, Association of Certified Fraud Examiners, LFIG etc.) and in particular non-government organisations not party to the Fighting Fraud Together document? A significant part of any fraud strategy should be prevention/deterrence of fraud and within this, a wide-ranging plan of action to change the ethos/ethics/morals of those who are or are considering becoming fraudsters. Is there an NFA plan. What funding beyond staff costs has been allocated to the NFA for anti-fraud work, and how will future funding be split between the NFA and the separate Action Fraud Cyber Crime Agenda? There are many industry sector sponsors listed in the document but when will the NFA start to drive the development of specific fraud strategies across other individual industry sectors such as cards, mortgages, DWP, LAs, insurance, banking, etc.

Within this, should this document have provided a pro-forma framework for individual industries to develop their own sector specific strategies?

Why is the document missing details on data-sharing (and real time data use for fraud detection efforts), which had been an earlier NFA objective? The document continues to consider the estimation of fraud levels and fraud reporting as priorities. (The report estimates UK fraud as 38bn, with previous estimates as 30bn, 20bn and 13bn). Should the NFA start then to measure fraud savings in addition to losses and therein place a greater emphasis on successes and drive positive actions?

Will this document lead towards the early publication of a quantifiable (financial) savings targets in each and all sectors?

These questions are posed as a starting point for the type of challenges that should be addressed, as there are significant additional strategic projects that need to be urgently initiated to drive fraud thinking forward across multiple sectors. Yours faithfully, Signed by: Bill Trueman, CEO UKFraud.co.uk Malcolm Gardner, Managing Director, Visionary Network Ltd Paul Lucraft, Managing Director, Paul Lucraft Associates David Cole, CEO, Chelgate Systems Alan Sambridge, MD, Apat Fraud Consultancy Kevin Smith, Director, Kevin Smith Consulting Carol Quainton, Investigations Manager, Oxford City Council Other recipients of this letter are: 1. James Brokenshire, MP, Parliamentary Undersecretary of State for Crime and Security, Home Office 2. The Rt Hon Francis Maude MP, Minister for the Cabinet Office and Paymaster General 3. The Rt Hon Dominic Grieve QC MP, Attorney General for England and Wales 4. Lord Freud, Parliamentary Undersecretary of State (Minister for Welfare Reform) and Government Spokesperson, Department for Work and Pensions 5. David Gauke MP, Exchequer Secretary to the Treasury 6. Baroness Hanham CBE, Parliamentary Undersecretary of State and Government Spokesperson, Department for Communities and Local Government