Safeguarding Adults at Risk from Scams: A collaborative approach

Brunel University London
Safeguarding Adults at Risk from
Scams: A collaborative approach
28th September 2015
Newton Room, Hamilton Centre, Brunel University London
Hosted by Professor Priscilla Harries and Mr Brian Smith
Safeguarding Adults at Risk from Scams: A collaborative approach

Sponsored by:

Hosts
Professor Priscilla Harries
Head of Clinical Sciences Department
Priscilla.harries@brunel.ac.uk
Mr Brian Smith
Lead Officer for Crime and Disorder
Trading Standards Institute
smithb1@angus.gov.uk

Welcome
Professor Priscilla Harries
Head of Clinical Sciences Department

Morning Chair
Nick Ellender
Care Act Implementation Officer
Worcestershire County Council

Overview of the Care Act in
Safeguarding Adults
Nick Ellender
Care Act Implementation Officer
Worcestershire County Council

www.worcestershire.gov.uk
The Care Act 2014
Nick Ellender
Care Act 2014 Implementation Lead
nellender@worcestershire.gov.uk

Adult Social Care law – the need for change
“The legal framework for adult social care consists of an often incoherent
patchwork of legislation, which makes interpretation and application of the
law complex and time consuming. In our view, consolidation and
simplification would be best achieved by establishing a unified adult social
care statute.” (Law Commission report 2011)

The Care Act 2014
“Until now it’s been almost impossible for people who need care, carers, and
even those who manage the care system, to understand how the previous law
affecting them worked. Over nearly 70 years it has been added to again and
again and is out of date and confusing. The Care Act has created a single,
modern law that makes it clear what kind of care people should expect.”
Care Minister Norman Lamb

Structure of the Care Act legislation
The statute sets out the core duties and powers of local social services
authorities, which are not be subject to further directions or approvals.
Regulations made by the Secretary of State to provide more detail where
necessary and to allow for developments of policy in the future.
Consolidated practice guidance on the new statute, which can be updated

Underlying principles of the Care Act
 Make care and support clearer and fairer
 Promote “well-being”
 Prevent and delay the need for care and support
 Support carers in maintaining their caring role
 Support people in controlling their own lives and achieving the
outcomes important to them - “person centred approach”.

How these are translated in to the Care Act
 A single national eligibility threshold for care and support for adults
and their carers
 Charging and financial assessment framework
 Local authority requirements to provide all local people with
information and advice related to care and support, including
financial advice and advocacy, to enable them to understand and
plan for future needs
 Statutory safeguarding of adults from abuse or neglect

(Continued)
 Promoting the diversity and quality of the “care market” and
protecting people from market failure.
 Clarity on local responsibilities for people e.g. people in prison who
have care and support needs, those that move between Local
Authorities and ordinary residence status.
 Better integration and partnership working
 Strengthening support to carers

Definition of the principle of “well being”
 Personal dignity (including treatment of the individual with respect)
 Physical and mental health and emotional wellbeing
 Protection from abuse and neglect
 Control by the individual over day-to-day life (including over care
and support provided and the way it is provided)
 Participation in work, education, training or recreation
 Social and economic wellbeing
 Domestic, family and personal relationships
 Suitability of living accommodation
 Individual’s contribution to society

Principle – Key duties – Key processes
Well being
Prevention
Integration and
partnerships
Information,
advice and
advocacy
Diversity of
provision and
market oversight
Safeguarding
Ordinary
residence
Assessment and
eligibility
Charging and
financial assessment
Care and support
planning
Personal budgets and
direct payments
Review

Statutory safeguarding duty
Duty applies to an adult who:
“has needs for care and support (whether or not the Authority is
meeting those needs), is experiencing or is at risk of abuse or neglect
and, as a result of those needs for care and support, is unable to
protect himself or herself against the abuse or neglect or the risk of it.”
Section 42 (1) Care Act 2014
Abuse or neglect not defined in the Act but financial abuse is:
“Financial abuse includes having money or other property stolen, being
defrauded, being put under pressure in relation to money or other
property, and having money or other property misused.”
Section 42 (3) Care Act 2014

Statutory safeguarding duty
 Duty to make or cause to make “enquiries”, statutory safeguarding
boards and Local Authority lead responsibility for SA.
 Updated types of abuse – e.g. modern slavery and self neglect
 Underpinning principles of empowerment, prevention,
proportionality, protection, partnership and accountability
 Less process driven and focus now on outcomes the person wants.
 Statutory criteria for case reviews (formerly serious case reviews)
 Duty of “candour” amendment to regulated activities.

‘Only the Tip of the Iceberg’:
Scams and older people
Phil Mawhinney
Policy Officer
28 September 2015

Information and Advice (I&A)
• Avoiding Scams guide
• 48,000 copies, 3,000 downloads.
• Raising awareness – home visits,
flyers, lunches/events.
Our work on scams

Research, policy
• Report – Only the Tip of the Iceberg.
• I&A queries, real life cases.
• Workshops.
Poll, March 2015
• Over half (53%) of people 65+ believe they
have been targeted.
• An estimated 0.5 million older people have
lost money.
Our work on scams

1. What scams? Targeting older people
2. Older people’s circumstances
3. Impacts on people’s lives
4. Improving protection and care
5. Conclusions

1. What scams?
Pension scams
• People under 55 ‘liberating’ their pension.
• £4.7m lost to pension liberation fraud in May 2015 –
more than x3 from April. (CoLP, 2015)
Investment scams
• Many people aged 55+ now access large pension pots –
targeted re investment scams.
Doorstep scams
• 85% of victims were 65+
• 1 in 5 were 80-84 (NST, 2014)

1. Older people as victims
Vishing
‘Older consumers were disproportionately represented in the
complaints we reviewed….
Most were over 65 and many were over 75.’
(FOS, 2015)
Postal scams
‘The average age of victims is 74, showing that these
criminals tend to prey on older – and often more vulnerable
– members of society.’

1. Doorstep scams
‘Ellen’s Uncle John* was a victim over 9 months. The
conman was part of a group, targeting older people in
the area.
Uncle John was a trusting older man and this made him
particularly vulnerable.
He purchased things he didn’t need – mattress, new
windows. A bath had been delivered with a hole in it, so
instead of returning it he bought a new one!
He used to take out £250 from his local bank branch in
cash every month to get by on food, bills etc.
However, once conned, he was withdrawing thousands
of pounds. In total he lost £33,000.
(*names changed)

1. Pension and investment scams
I&A query
‘My elderly father seems to have been scammed by a
boiler room outfit.
How do I progress an investigation?’

1. Postal scams, mass marketing fraud
I&A query
Caller's father lives alone since his wife died 4 years ago.
He has mental capacity. However, he has a compulsion
to partake in scams that involve competitions and prizes.
He has parted with quite a lot of money this way.
His family have spoken with him at length but he replies
that it is his money.
He tries to hide this from family.

2. Older people’s circumstances/risks
Living alone, lonely, bereaved
 >60% lived alone
 4 in 10 were lonely
 1 in 3 had experienced bereavement
in past 2 years
Physical health
 >60% had a physical
impairment
Mental and cognitive health
 1 in 7 had a cognitive impairment
 1 in 4 had concerns about their memory
(or family/carers did)
Diversity
 English not as first
language
Doorstep crime victims
•National Trading Standards working group report, 2014

2. Trust
Lack of evidence – but strong theme
‘Offenders could be targeting [older people] as they perceive
them to be more trusting of calls from “authority” figures.’
(NFIB, 2015)
‘…surely human nature is to be trusting? How do you protect yourself
without becoming a horribly sceptical shrew?’
(Gransnet comment, July 2015)
Presents a dilemma

2. Growing risks?
1. Ageing population
• People 85+ to double in next 20 years
3. More older people online
• Risk among those newly online but low
confidence/skills.
2. Dementia
• 850,000 people – 1 million by 2025
4. Pensions reforms
• Since April 2015, access to cash pots

3. Financial impacts
16%
8%
7%
16%
14%
8%
20%
6%
3% 1%
Vishing victims' financial loss
<£1k
£1k - £2k
£2k - £5k
£5k - £10k
£10k - £15k
£15k - £20k
£20k - £50k
£50k - £75k
£75k - £100k
£100k+
• Postal scams – average loss is £1,184.
• Any amount – relatively small – can have severe impacts.

3. Health and independence
Real example: raised by client of a local Age UK
Client’s neighbour lived alone and was the victim of
a scam [doorstep] trader.
As a consequence, she wouldn’t open the door to
anyone, leaving her to struggle to look after herself.
She had vascular dementia and needed help with
washing, dressing, preparing food, etc.
She deteriorated to such a degree that another
neighbour became concerned, and called an
ambulance.
She spent 6 weeks in hospital and is now in a care
home.’

1. What scams? Targeting older people
2. Older people’s risks/circumstances
3. Impacts on people’s lives
5. Conclusions

Awareness raising
• Essential, we do it – but not sufficient
• Complex, hard to spot scams
• Not understood by people
• Not reaching the most isolated

Call blocking
• ‘One of the technologies used during the trial blocked
over 95% of the nuisance calls’
(Angus Council, 2013)
‘No Cold Calling Zones’
• <10% of households in Wales covered by NCCZs.
• Residents support NCCZs.
• Residents look out for each other and report.
• Age Cyrmu calling for streamlining of LA process, less
costly to establish zones.

4. Financial institutions
Delayed payments
• Realise quickly they have been scammed:
‘You feel it in your gut – you feel uneasy within seconds.’
• Delay payment by hours – chance to cancel.
• Appreciation of duty to carry out customer instructions.
Warnings in the right place
‘Mrs S didn’t access telephone banking… since warnings have been in
place. She also didn’t have internet banking facilities.
So she wouldn’t have been exposed to repeated warnings about this scam.’
(FOS, 2015)
Workshop participants –
‘More eye-catching warnings on statements.’

4. Improving victim care
Blaming yourself
‘The incident has had a profound effect on my mother.
She is shaky, no longer answers the phone unless she knows who is
calling…
[she] blames herself for losing such a huge sum of money.’
(FOS, 2015)
Age Cymru
• Same care and understanding for scam victims as other
serious crimes
• Stigma of blame must be removed

5. Conclusions
1. Older people are at particular risk
• Especially the most vulnerable
3. Don’t just educate
•More blocking and care
4. Co-ordinate, lead and measure
• Scams task force
• New fraud indicator
2. The problem could escalate
•Need action now

Thank you
Get in touch with questions or comments:
Phil Mawhinney
Policy Officer
Age UK
phil.mawhinney@ageuk.org.uk
020 303 31391

The Psychology of Scams: or
What Thomas Hardy knew
about internet dating
Mark Fenton-O’Creevy
True Potential Centre for the Public Understanding of Finance

Overview
• The psychology of victims: how we are complicit in our
own deception
• Why poorly executed scams can still work
• The supply of motivated offenders

Thomas Hardy and internet
dating
Boldwood and Bathsheba (in Far from the Madding Crowd)
The great aids to idealization in love were present here: occasional
observation of her from a distance, and the absence of social intercourse with
her - visual familiarity, oral strangeness. The smaller human elements were
kept out of sight; the pettinesses that enter so largely into all earthly living
and doing were disguised by the accident of lover and loved-one not being on
visiting terms; and there was hardly awakened a thought in Boldwood that
sorry household realities appertained to her, or that she, like all others, had
moments of commonplace, when to be least plainly seen was to be most
prettily remembered.

Rosantonietta Scramaglia’s
research
• Face to face dating
- relationships move from an initial encounter in a physical
location and based on physical attractiveness, to the
discovery of common interests and self-disclosure.
•Online dating
- Internet relationships proceed in the opposite direction;
the physical encounter comes last.Often much earlier self
disclosure and mutual exchange of highly personal
information

‘It creates ‘mystery’, ‘the unknown’, ‘the
excitement of something you’ve never experienced
before’,
‘it lets you dream’. It is ‘more fun because you can
discover the other person gradually’.
‘the fascination of novelty’…
‘the worse thing is that you get your expectations
up’, and tend to ‘idealize the partner more’.

Monica Whitty’s research
• Most victims of dating fraud have been told by a friend or
relative that they are being scammed but have ignored
them.
• No one age group or gender more prone –not just about
middle aged women
• Very significant underreporting because of the sense of
shame
• Very significant harm not just financially but to
confidence, sense of self worth and identity and ability to
trust in relationships, in some cases suicide risk
• Intelligence and education are not a protection

The key issue – how we are
complicit in our own deception
• Hedonic goals and comforting lies
• The case against Father Christmas being real
• Illusions of control (e.g. Investment bank traders)
• Scammers sketch a story and motivate us to fill in the
gaps (our memories and ideas are not stored but
storied)
• Fear, greed and loneliness are powerful motives for
self deception
• High intelligence = more cognitive capacity to devote
to fooling yourself

The supply of motivated offenders
• The psychological costs of harming others
• Narcissistic and sociopathic personalities
• Distancing strategies
• Dehumanisation
• They deserve it
• The internet as a ready made distancing strategy
• Getting distance through (innocent) intermediaries
• Professional pride

The marketing science of fraud
• Prequalification: only commit resources to high probability
victims
– the value of stories with holes
– assessing vulnerability
– lightning does strike twice
• Escalating commitment
• Post-purchase rationalisation: the psychological costs of
admitting you have been fooled

Brunel University London Safeguarding Adults at Risk from Scams: A collaborative approach
Coffee and Tea Break
11.00am – 11.15am

Tackling Financial Abuse in
North Yorkshire
Ruth Andrews
Head of Investigations & Safeguarding
North Yorkshire Trading Standards

Tackling financial abuse in North
Yorkshire:
Ruth Andrews, Head of Investigations &
Safeguarding, Trading Standards

The scale of Doorstep Crime:
• What is the scale of the problem?
• Who are the victims?
• Who are the offenders?
• What is the current response, and what needs
to improve?

The scale of Doorstep Crime:
17,000 reports per year to TS.
Estimated to be between 5 & 10% reporting
rates.
Likely to be at least 170,000 incidents a year,
possibly as many as 340,000.

What do we know about the
victims?:
• Age
• Gender
• Housing type
• State of property / adaptations
• Loneliness and isolation
• Dementia & other health conditions
• Impact

Doorstep Crime Offenders:
3 offender types:
• Legitimate guise
• Chancers / apprentices
• OCGs / professional & career offenders

Multi-Agency Team – Operation
Gauntlet:
• Joint-funding
• Partners: Adult Services, Public Health, NY Police, City of
York, Veritau Ltd
• Other partners – third sector, financial sector, district
councils
• Pursue, Prepare, Prevent, Protect
• Other additional funding

Other forms of financial abuse:
• Scam mail – “Gwen”, “John”
• “Boiler room” / investment frauds – “John &
Barbara”, Mr & Mrs S
• Abuse by family members, carers and POAs –
“Mr A”
• Other vulnerable adults – Miss E
• Abuse by those in a position of trust
• Romance frauds – Miss B
• Land banking, courier frauds, on-line frauds
• Scale of the problem?

Measuring performance / success
etc:
• How do we measure the success of the team?
• Repeat victimisation prevention?
• Addressing vulnerability factors?
• Capacity?
• Risk assessing vulnerability?

Questions?
Ruth Andrews
01609 534855 / 07816 813418
ruth.andrews@northyorks.gov.uk

Current Research with CTSI
Professor Keith Brown
Director of the National Centre for Post Qualifying Social Work
Bournemouth University

Morning Speakers’ Questions
and Answers Panel

Lunch
12.45pm – 1.30pm

Afternoon Chair
Professor Mary Gilhooly
Theme Lead, Ageing Studies and Professor of Gerontology
and Health Studies

From Call Blocking to Holistic
Partnership Working, a Local
Authority Experience
Paul Holland
Principal Prevention Officer
East Renfrewshire Council

“The team’s vision is to work in collaboration to empower and
protect residents from financial and personal harm, particularly
those in challenging situations.
We develop creative prevention initiatives to compliment
intelligence led enforcement . “
- Paul Holland (Principal Prevention Officer)

DATA
COMMUNITY ENGAGEMENT
PREVENTION TEAM – THE 5 CAPABILITIES 2014/15 HIGHLIGHTS
OUR VISION
To work in collaboration to
empower our residents to
avoid unnecessary
personal and financial
harm.
PREVENTION
DIGITAL
•Number Of Prevention Packs We Issued = 6453
•Number Of People In Community We Directly Engaged With= 3951
•Number Of Bespoke Prevention Packages Introduced = 94
•Number Of Collaborative Partners= 47
•COST BENEFIT ANALYSIS= clear evidence shows prevention work is resulting in
substantial financial savings for residents and public spending Toolkit For
Calculating The Savings Is Currently Being Developed)
•Current Estimated Resident Saving=£843,747
•Public Spending Saving= £1,699,413 TOTAL SAVE (after costs) =£2,453,160
•Averaged Customer Evaluation – How Do They Rate Our Service?
•Do You Feel Safer At Home = 9.6/10
•Relevance And Value Of Our Prevention Work = 9.7/10
•How Successful Have We Been At Blocking Nuisance Calls= 99%
•Do You Think The Prevention Team Are Helping Residents In Challenging
Situation To Maintain Independent Living= 9.7/10
MODERNISATION
OUR TARGETS &
OUTCOMES
OUR FOCUS
•EARLY YEARS
•LEARNING LIFE & WORK
•ECONOMY & ENVIRONMENT
•SAFER, SUPPORTED
COMMUNITIES
•OLDER PEOPLE EMPOWERED
•Created web page for easy access to Prevention Resources and
Referral forms.
•Community councils contacted – prevention talks
•Numerous community events attended
•Pop up prevention various locations
•3rd sector engagement/volunteers
•Extensive evaluation and feedback – quantitative/qualitative
•Savings & targets (see targets and outcomes)
•Caps database updated to record & report on prevention &
engagement work – quick access to data & stats
•Follow model for improvement where relevant
•Links with creative funding – sustainability
•Paperless where practical
•Technology linked prevention
•Total shift in approach to prevention, empowerment & community
engagement
FEEDBACK HIGHLIGHTS
“The team and the call blocker have enabled my mum to live an
independent life at home. Without this I’m sure she would be living
in a care home”
“Have nothing but praise for East Renfrewshire Councils Prevention
Team”
“Your team are superb”
“I cant thank you for all the help you do good things for us old
people”
“I feel what you guys are doing is really helpful and good for
everyone especially babies and kids.
•See our website for details of our wide ranging innovative projects
designed with and for our residents.
• WWW.EASTRENFREWSHIRE.GOV.UK/PREVENTION

Royal Mail & Trading Standards
Benefits of a
Collaborative Approach
Katherine Hart
Fife Council Trading Standards Service
Steve Welch
Royal Mail Group Security

Introduction
• Background
• Fife Trial
• Ongoing Initiative

Identifying Serial Victims of
Scam Mail

Objective of the Fife trial
• To utilise the knowledge of local postal workers and
Trading Standards to identify potential serial victims of
scam mail
• To enable victims to be provided with advice on how to get
help and support from appropriate agencies
• To educate postal workers on scams
80

What is Scam Mail?
• Mail items aimed at tricking recipients into sending money
through bogus schemes such as prize draws, fake lotteries,
sweepstakes or other tempting goods and services
• Scam mail is not the large body of advertising mail that is
carried and delivered for genuine commercial customers
81

What is Scam Mail?
Examples of ‘Prize Draw’
envelopes
Example of a ‘Psychic’
envelope
82

Cycle of victimisation: Scam Mail
83

A Victim’s story
• ELLIE
• Identified by her Postal
worker
• Paying £1000 each month
to scammers
• Victim for years
84

Ellie 10 days mail
• As a result of her Postal
Worker’s identification
• Support needed from
• Social Work
• Trading Standards
• Victim support
• Police
Now reduced mail..
= money in her bank account
85

Types of goods
Types of goods people order include :-
• Vitamins
• Chocolates
• Caviar
• Tooth whitening kits
• Slimming aids
• Bicarbonate soda
ALL AT INFLATED PRICES and sometimes unsolicited
86

Consequences
• Some Consumers sent money off and received nothing
• Others were then subjected to mass marketing
• After cancelling bank cards and stopping responding, some
people then got persistent and threatening phone
calls from companies desperate to take money
• One elderly lady who was of sound mind and ability was
repeatedly called at 3:00 in the morning, she became
frightened to answer the phone to even her relatives
It could be argued that as a result of this worry and paranoia, she lost
all confidence in living alone
88

Royal Mail
• History
• Scam Mail Training & Education
• Scam Mail Reports & Samples
89

History
• 1516 Appointment of Brian Tuke
as first Master of the Posts by
Cardinal Wolsey
• 1533 Letter from Master of Posts
to Thomas Cromwell “There
could never be any excuse for
delaying the King's Posts”
• 1793 Post Office Investigations
formed
• 1840 Penny Black introduced 6th
May - over 68 million were used
in first year
• Current Legislation - Postal
Services Act, RIPA
90

Scam Mail Training & Education
• Training material agreed with NST and Scottish TS to help
delivery staff identify potential scam mail victims
• Arrangements made each month for Trading Standards to
deliver training at agreed offices – with RM support
• Details of addresses to which suspected scam mail is being
delivered passed to RM Scams Team
• Suspected victims written to advising that scam mail is
being delivered in their area and enabling them to opt out
of having their details shared with the NST
• Regular communications to our workforce via Royal Mail
channels
• Purpose is to enable Royal Mail staff to identify victims
• Royal Mail staff cannot interfere with the mail
91

Scam Mail Training & Education
92
• Fife Trial – May 2013
• Roll Out of Training May 2014
• 54 Delivery Offices in UK received training
• Over 2800 Delivery personnel
• 927 Addresses identified as receiving scam mail
• 659 suspected victim details passed to National Trading
Standards Scams Team and Convention of Scottish Local
Authorities (COSLA)
• 46 opt outs

Scam Mail Reports & Samples
• Initial contact received via Scam Mail channels
• Scam Mail Report and Freepost envelope sent
• Reports and / or Samples received
• Details recorded
• Analysis / Research
• Intelligence shared with National Trading Standards Scams
Team (NTSST) as appropriate
• Samples to NTSST for opinions re legitimacy of the mail
• Action taken coordinated with the NTSST
93

Scam Mail Reports & Samples
2015/16 2014/15
Number of Individuals Making Reports 955 342
Total Scam Line Victim Referrals to NST (including
COSLA)
148 101
Total RM employee Victim Referrals to NST (including
COSLA)
62 9
• Over 9000 samples received in the last six months alone
• 52% of the samples received bore indicia from foreign countries
• 34% had Downstream Access indicia (C9 prefix)
• 12% had a Royal Mail HQ PPI indicia (including Spring)
94

Royal Mail Actions
95
• Nine accounts associated with scam mail closed by Royal
Mail
• Further four currently on a warning
• Have written to the Universal Postal Union (UPU) for cross
border joint actions
• Several companies associated with the distribution of
scam mail have had Royal Mail posting facilities closed
down
• Assisted in identifying victims & returning mail to senders
which has been seized in TS/Police operations

Katherine Hart
Fife Council Trading Standards Service
Email: Katherine.Hart@fife.gov.uk
Steve Welch
Royal Mail Group Security
Email: stephen.welch@royalmail.com

National Trading Standards Scams Team

 Highlight the current work of National
Trading Standards Scams Team
 Encourage the sharing of concerns where
they relate to the safeguarding of adults
 Collaborative working to improve the quality
of lives of victims who have been victim of
the scammers

SERIOUSLY – WOULD YOU REALLY FALL FOR THIS ?

226 pcs of mail in last5 weeks
Week 1- Replied to one letter
Week 2 – Received 20 letters
Week 3 – Received 55 letters
Week 5 – 33 items in one day

 “I am so glad my cat has passed on , I would
not have had enough money last month to
feed her”
 Why are they doing this, I don’t have any
more money”
 “they promised me I had won, I'm hoping the
cheque will come soon, I need to pay the
electric”

 “I lost my wife 10 years ago I was lonely”
 ”I get up, I wait for the post, I sort it, I go to bed,
what else have I got I might as well be dead”
 “I want the money so I can move to a home, I
want some company”
 They ring me every day - I'm the big winner”
 I don’t get out, because I'm frightened, the
letters are all the company I ever get”

 Victim Focus
 Education of Partners
 Intelligence gathering
 Multi Agency approach
 Global liaison
 Disruption
 Prosecution

Mailings
Chain
Intelligence
Sharing
FinancialUK PLC
Supply and
Demand
CURRENT DISRUPTION ACTIVITY

NTSST
International
Working
Australia
USA
Holland
Belgium
Canada
Ireland
IT’S A GLOBAL BUSINESS – WHICH NEEDS GLOBAL ATTENTION

NTSST
Media
awareness
Government
Action
Secondary
Enablers
Legislation
Change
Prosecutions
Education
Charities/
Associations
ANYTHING ELSE?

First they came for the socialists, and I did not speak out
- Because I was not a socialist
Then they came for the Trade Unionists, and I did not
speak out – Because I was not a Trade Unionist
Then they came for the Jews, and I did not speak out –
because I was not a Jew
Then they came for me - And there was no one left to
speak for me!
Martin Miemoller, Pastor 1892-1984

Coffee and Tea Break
2.45pm – 3.00pm

Operation Broadway
Teresa Russell
Detective Inspector, City of London Police
Andy Henderson
Trading Standards Investigator
City of London

File classification: NOT
PROTECTIVELY MARKED

Detective Inspector Teresa Russell
Fraud Operations
Operation Broadway
PROTECTIVELY MARKED

What is Operation Broadway?
Operation Broadway is an initiative led by
the Economic Crime Department, working
in collaboration with law enforcement &
regulatory bodies, aimed at mitigating the
prevalence of 'boiler rooms' operating
within the City of London.

PROTECTIVELY MARKED
What is a ‘boiler room’?
The term ‘boiler room’ is
referred to the high
pressurised sales tactics
employed by operators who
cold call victims to invest in
worthless shares &
commodities.

So what is the impact of
investment fraud….?

• AF received 5,252 reports relating to
investment fraud
• Losses - £1.7 billion ( figure likely to be
substantially higher)
• Highest concentration business districts
effected: Mayfair, city and Canary Wharf

Location, Location, Location…

• Most victims of investment fraud aged
between 60-69 (22%)
• 233 people repeat victims within a 12 month
period
• Many are vulnerable

Purpose
•Deter
•Disrupt
•Displace

Our Aim
To make the City of London an
hostile environment for those
seeking to use the global brand that
is the City of London, to legitimise
their fraudulent activity.

• Legislation
• Hallmarks of a scam
• Reporting concerns
Andy Henderson
Port Health &
Public Protection
Trading
Standards

• London Local Authorities Act 2007 (LLA)
• Money Laundering Regulations 2007
(MLR)
• Proceeds of Crime Act 2002 (PoCA)
Legislation
Trading
Standards

London Local Authorities Act 2007
Trading
Standards

Only applies to Mail Forwarding and
Mail Holding clients
Trading
Standards

• Section 75 relates to mail forwarding and mail holding
• Subsection 6:
• (a) The full name, address & Tel No of every person for
whom any post is received, or who has requested the
postal packets may be held or forwarded to that person
• (b) The nature of the business carried out by that person
• (c) Any instructions received as to the delivery or
forwarding of postal packets
• (d) Copies of the originals of 2 approved ID documents.
Trading
Standards

• Subsection 7:
• In subsection 6(a) above, the name and address must not
be the name and address of another MFB and is:
• (a) In the case of an individual, his private address
• (b) In the case of a body corporate or partnership-
• The registered or principle address
• The names and private addresses of the directors,
partners or anyone directly/indirectly responsible for
management
• The principle place of business, if different from the above
Trading
Standards

Money Laundering Regulations 2007
Trading
Standards

• Section 6, Risk-based approach states:
• MLR 2007 requires firms to adopt a risk-based approach
to application of measures to prevent money laundering.
• Sec 7, Enhanced due diligence (EDD):
• MLR 2007 regulation 14 requires businesses to apply
EDD measures on a risk-sensitive basis:
• When the customer has not been physically present for
identification purposes
• In any other situation which, by it’s nature presents a
higher risk of money laundering.
MLR Guidlines
Trading
Standards

• Section 9, Ongoing monitoring:
• Businesses must conduct ongoing monitoring of their
business relationships with their customers.
MLR Guidlines
Trading
Standards

Proceeds of Crime Act 2002 (PoCA)
Trading
Standards

Applies to ALL clients!
Trading
Standards

• If you know or Suspect the you are receiving the proceeds of
crime, and you take the money, even as rent, you are guilty of
an offence
• Maximum 14 years imprisonment!
• ‘Tipping Off’ a client regarding a MLR investigation is an
offence subject to a maximum of 6 months imprisonment.
Trading
Standards

Hallmarks of a Scam
Trading
Standards

• Investment Brokers, in particular dealing in:
• Carbon Credits
• Wine
• Rare Earth and Precious Metals incl’ Gold
• Diamonds (Coloured) and other precious stones
• Land
• Alternative Energy
• Graphene
• Storage/Car parks
• Art.
Hallmarks of a scam
Trading
Standards

• Mail forwarding clients:
• Company names with ‘commodities’ in title
• ‘Global’ companies that are recently incorporated
• Pester for post constantly
• Will collect even just one letter
• Collect post rather than have it forwarded
• Collect soon after calling
• Multiple company names or ‘phoenixing’
• Avoid declaring trading address.
Hallmarks of a scam
Trading
Standards

• Serviced office clients (Boiler room):
• Young males (Normally)
• Very well groomed, smart suits, ties, shoes, hair-cuts
• Arrogant, loud, abusive
• Flash cars and watches etc
• Extravagant lifestyle, clubs, champagne, meals
• Push hard for deals, bad at paying
Hallmarks of a scam
Trading
Standards

• Serviced office clients (Boiler room):
• Work off scripts
• TV/Radio playing in office
• Use various/false (Trading) names
• Too familiar with receptionists
• “Once you have seen them you will never forget them!”
Hallmarks of a scam
Trading
Standards

REPORTING CONCERNS
Action Fraud 0300 123 2040
Trading
Standards

•Turning up the heat
on boiler rooms!
•Any Questions?
Trading
Standards

Nick Talbot – Head of Customers In Vulnerable Situations Programme
September 2015
Customers In Vulnerable Situations
– spotlight on Frauds & Scams

How have we defined vulnerable situations?
 We have identified 16 situations where customers may experience varying degrees of vulnerability – these
situations can contribute to those customers ending up in financial hardship
 These have been grouped under 3 key headings: Accessibility, Cognitive and Life Changing Events
 Vulnerable situations may be permanent or
situational and any / all of these can become
further complicated by a customer in financial
hardship
 We are now empowering our people to think
about vulnerable customers more holistically:
─ Understanding how personal
circumstances could make a customer
vulnerable
─ Being able to identify vulnerable
customers and establish how best to
help them
─ Access appropriate support for both
vulnerable customers and themselves
─ Understand their responsibility with
regard to supporting vulnerable
customers
1

We are fully committed to helping our
customers when they need us the most
1
Nearly £24m was lost to phone scams in
2014, which was treble the amount in 2013
(Financial Fraud Action UK)

• The Customers in Vulnerable Situation Programme commenced in April 2014 as the result of
a scoping programme highlighting opportunities to improve the overall proposition, experience
and outcome for customers who may be permanently or situationally vulnerable.
• The Programme has delivered success in key areas:
– Visual Impairments: the launch of specially designed debit and savings cards with RNIB approved
status
– Lack of Mobility: Increased access to banking services through mobile branch banking and Post Office
counters
– Bereavement: Specialist team introduced and working to improve further with BBA
– Mental capacity / health: Specialist team introduced re Power of Attorney; relationship with the Office of
the Public Guardian; upskilling of staff as Dementia Friends and signatory of Dementia Charter
– Financial Difficulty arising from particular vulnerabilities: Specialised teams introduced within Debt
Management Operations with specific training from Money Advice Trust and Samaritans
– Partnerships: Continuing to build good relationships with relevant external parties
– Staff Training: Support training being rolled out to all staff covering understanding and identifying
vulnerability, having effective conversations and making reasonable adjustments to ensure we deliver
good customer outcomes
We have made progress to improve the
customer experience and understand the
areas that matter
1

The Information Classification of this document is CONFIDENTIAL 1
Our Community Protection Advisors
Trading Standards
Police Service
Social
Services Office of
Public Guardian
CPA

Afternoon Speakers’
Questions and Answers Panel

Thank you for coming
Drinks reception - 4.15pm

Safeguarding Adults at Risk from Scams: A collaborative approach

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