Economic Crime and Corporate Transparency Bill

Written evidence submitted on behalf of the City of London Police (ECCTB11)

Economic Crime and Corporate Transparency Bill 2022
Public Bill Committee

Companies House Reform

1. The City of London Police is f ully supportive of measures in the Bill which would introduce identity verification for all new and existing registered company directors, People with Significant Control, and those delivering documents to the Registrar. This will prevent fraudulent appointments using spoofed and false identities . T he use of these is an enabler to high harm fraud offences such as investment fraud . The application of this measure to existing entities on the register increases the effectiveness of this and is very much welcomed.

2. Measures to bring in tighter controls over the naming of companies registered is supported. Use of spoofed or similar company names (to legitimate companies) is an enabler to fraud whereby victim trust is falsely obtained due to a perceived link to more reliable entities. Again, the application of this to existing entities is welcomed.

3. Increased transparency of registered shareholders, subscribers and guarantors will reduce the opportunity for offenders to hide their involvement in companies . This will prevent bad actors from exploiting the register to commit fraud and economic crime.

4. Improving the financial information on the register so that the register is more reliable, complete and accurate will also enable better and more accurate financial investigation of entities on the register .

5. The City of London Police supports measures in the Bill to p rovid e Companies House with more effective investigation and enforcement powers and introdu ce better cross-checking of data with other public and private sector bodies. Companies House will be able to proactively share information with law enforcement bodies where they have evidence of anomalous filings or suspicious behaviour. This is welcome and creates opportunity for better partnership working, which is a priority in tackling economic crime and fraud .

6. E nhancement s of the protection of personal information is welcome. The use of personal information is a prolific enabler of fraud.

Limited partnership reform

7. The City of London Police support s measures which tackle the misuse of limited partnerships, including Scottish limited partnerships, while modernising the law governing them. Increased transparency and verification in this area will prevent bad actors from using limited partnerships as a vehicle to target victims of fraud in the UK .

Cryptoassets

8. The NPCC Cyber Lead, City of London Police officer Detective Chief Superintendent Andrew Gould, fully supports the Bill’s provisions to give powers to law enforcement so they are able to more quickly and easily seize and recover cryptoassets which are the proceeds of crime or associated with illicit activity , such as money laundering, fraud and ransomware attacks.

9. There has been full engagement with policing in the design of these provisions and this has meant that the resulting Bill fits the needs of law enforcement.

Strengthening anti-money laundering powers

10. The City of London Police fully supports measures to allow for direct, rapid sharing of information between businesses in the anti money laundering (AML) sector. Third party sharing is also supported.

11. It is recognised that increased sharing of information in this area and sector would enable better prevention of fraudulent payments, and restrict opportunities for money laundering and other economic crime . It is hoped that though AML sector businesses are not compelled to share, that they will do so to assist in the prevention and detection of economic crime within the UK.

12. The City of London Police is also f ully supportive of measures to enable proactive intelligence gathering by law enforcement and strengthening the National Crime Agency’s Financial Intelligence Unit’s (FIU) ability to obtain information from businesses relating to money laundering and terrorist financing by removing the requirement for a pre-existing Suspicious Activity Report (SAR) to have been submitted before an Information Order (IO) can be made .

Extension of Serious Fraud Office’s Powers

13. E xtension of the Serious Fraud Office’s powers is also welcomed. Such extension is not perceived to impact on policing.

November 2022