Origins and implementation of 2014 College of Policing - Fraud Investigation Model (FIM)

Joel M Benjamin made this Freedom of Information request to City of London Police

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Dear City of London Police,

Please provide information including documents, internal and external emails and communications regarding the origins and implementation 2014 College of Policing - Fraud Investigation Model (FIM).

Please provide the following regarding the FIM:

1) Information regarding the origins of the 2014 FIM and explanation as to how the approach differs from Police previous fraud investigation and prosecution models for complex financial frauds, implemented by CoLP.

2) Correspondence with the Financial Conduct Authority, SFO and other partner agencies between 2013 and 2015, regarding how the 2014 FIM and complex financial fraud investigation duties were to be implemented and roles allocated between partner organisations.

3) Information regarding how the breakdown of inter-agency roles and responsibilities vis a vis complex fraud investigations is clearly communicated to fraud victims, to avoid instances of circular referrals - where no agency takes responsibility for investigating and prosecuting financial fraud?

4) Impact assessment(s) undertaken before the 2014 change in complex crime enforcement (FIM) policy and any results of monitoring of prosecutions/ settlements of complex financial crimes both before and after the 2014 policy change.

Yours faithfully,

Joel M Benjamin

FOI, City of London Police

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Holmes Michela, City of London Police

1 Attachment

Classification: NOT PROTECTIVELY MARKED

Hello Mr Benjamin

 

In order to process your request I need some further clarification so I
know where to locate any information City of London Police hold.

 

I have carried out a google search for “2014 College of Policing - Fraud
Investigation Model (FIM)” but I am unable to locate anything. Can you
provide me with a web link regarding this please?

 

Q1; You are asking for “explanation as to how the approach differs from
Police” Unfortunately under the freedom of information act we can only
supply you with information that has already been created. We do not have
to answer questions or explanations unless they are already created.

 

Q2; (and initial paragraph) Can you specify who you wish me to obtain this
correspondence from? It would be disproportionate to email every officer/
staff who deal with fraud

 

Q3; Could you please re-phrase this question as I do not understand what
you need

 

I apologise for the query’s but I want to ensure that I am supplying you
with the correct information.

 

Regards

 

 

Michela Holmes

Senior Information Access Officer

 

Information Management Services | City of London Police

 

Email: [1][email address]

 

Bishopsgate Police Station | 4th Floor | 182 Bishopsgate | London | EC2M
4NP

[2]cid:image001.png@01D23464.DFF7D220

 

 

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References

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Dear Holmes Michela,

Points of clarification regarding my original request:

The 2014 College of Policing "Fraud Investigation Model" (FIM) appears to be a new internal policy & flowchart for investigating & prosecuting complex financial crime, adopted across police forces in the last several years.

As such, like any new policy, I would expect the College of Policing and/or CoLP to have produced guidance for Police officers and internal staff, explaining how, and where the 2014 FIM differs to existing/ previous models for investigating complex financial frauds and explaining these changes to internal staff expected to implement the new policy.

In addition, where the FIM calls for a "partnership" approach with other regulators such as the FCA, FOS and SFO, it would be normal to expect external communication and liaison to occur between CoLP and these partner orgs to discuss how the new approach to fraud policing and regulatory referrals would be implemented in practice, and its results appraised or reviewed over time.

I am aware of several financial fraud victims contacting CoLP in recent years, who have been provided with copies of the FIM document and flowchart, as part of an explanation as to why CoLP are deciding not to take enforcement action, and instead are referring cases back to the FCA.

I am somewhat surprised to hear you are having difficulty locating a copy of the policy internally. May I suggest you contact DCI Dave Manley - within CoLP, who may be able to shed further light on this matter.

Response to specific questions, requests for clarification:

Re: - Weblink to FIM policy - I believe the FIM is an internal policy, and has not been externally communicated - thus I suspect you will not locate the College of Policing FIM 2014 policy using an external google search

1) As explained above, rather than "requesting an explanation" of how the 2014 College of Policing FIM differs to prior fraud enforcement policies, I am requesting copies of internal information/ communications/ policy guidance/ provided to staff, explaining the new policy, and how it would be implemented and reviewed.

2) Senior CoLP Officers expected to investigate and enforce complex financial frauds should hold this information. DCI Dave Manley should be able to further assist your inquiries.

3) Rephrased Question 3

Where cases of complex financial fraud require inter-agency cooperation (i.e between FOS, CoLP, FCA, SFO) - please provide information produced for the benefit of complex financial fraud victims - explaining the exact remit of the CoLP and each partner organisation/regulator, and explaining why the victims issue(s) cannot be taken up by CoLP and instead needs to be transferred to another org/ regulator.

For e.g. this could be a case management flow chart or issue based table, explaining the remit and scope of each organisation/ regulator.

Yours sincerely,

Joel M Benjamin

Holmes Michela, City of London Police

Hello

 

I am out of the office and shall return on 12/10/2017.

 

Please send any urgent queries to [1][email address]

 

Regards

 

Michela Holmes

 

Senior Information Access Officer

 

 

Please consider the environment before printing my email

References

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2. http://www.cityoflondon.police.uk/

Holmes Michela, City of London Police

2 Attachments

Classification: NOT PROTECTIVELY MARKED

Hello Mr Benjamin

 

Please find our response to your Freedom of Information request,

 

Thank you for your interest in the City of London Police

 

 

Michela Holmes

Senior Information Access Officer

 

Information Management Services | City of London Police

Email: [1][email address]

 

Bishopsgate Police Station | 4th Floor | 182 Bishopsgate | London | EC2M
4NP

[2]cid:image001.png@01D23464.DFF7D220

 

 

 

Please consider the environment before printing my email

References

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3. http://www.cityoflondon.police.uk/

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