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Clifford Chance

Regulatory Investigations and Financial Crime Insights

Cyber-enabled crime highlighted as key risk area for financial and economic crime in the NCA's 2019/20 Annual Plan

The recently published Annual Plan for 2019/20 sets out the National Crime Agency's operational priorities for the year ahead and how it will lead a whole-system response to serious and organised crime.

The plan highlights particular risks in the 'Prosperity' category of threats identified in the National Strategic Assessment (NSA) of Serious and Organised Crime, which category covers cyber crime, high end money laundering and other economic crime, including corruption and sanctions evasion.

It is clear from these that organised crime groups (OCGs) are using increasingly complex methods, including the use of cyber tools, to carry out this activity.

Money laundering

The Annual Plan identifies that some OCGs are using more complex methods to launder money, hamper law enforcement detection and reduce transparency. Cash and non-cash based money laundering methods are intrinsically linked. Cash generated by criminal activity is moved overseas or paid into the UK banking sector from where various methods are used to transfer and distance it from its origins.

Fraud and other economic crime

The Annual Plan states that illicit finance is estimated to cost the UK economy at least £160 billion annually. There were 3.3 million fraud incidents reported in England and Wales in the year to June 2018 and a 32% increase in the financial loss reported between April and September 2018 compared with the previous year. It is estimated that 84% of fraud reported nationally is cyber-enabled – the use of cyber tools allows criminals to target the UK from almost anywhere in the world.

International bribery, corruption and sanctions evasion

The Annual Plan identifies that UK businesses operating in jurisdictions with poor anti-corruption controls are at risk of being corrupted, or actively corrupting in order to retain business advantage. During 2017/18, 122 reports of suspected financial sanctions breaches had a value of £1.35 billion.

Cyber crime

The Annual Plan identifies Russian-language OCGs as representing the biggest cyber crime threat to the UK. Malware crossovers appear to indicate that cyber criminals from different OCGs are working more closely together than previously thought. The tools and techniques used by the most competent OCGs can be as sophisticated as those used by nation-state actors.

Given the amount of cyber-enabled crime identified in the Annual Plan, it follows that the Annual Plan also includes specific operational priorities in the area of cyber crime. In particular, priorities include to:

  • grow and embed a single UK response to cyber crime at local, regional and national levels; and
  • deliver, with law enforcement partners and the National Cyber Security Centre (the body launched in October 2016 to provide a single point of contact on cyber crime), a comprehensive, joined up UK response to critical cyber incidents.