Policy paper

Cross Government Counter Fraud Functional Strategy 2024-2027 (HTML)

Published 14 March 2024

Ministerial Foreword

Fraud is a pervasive crime that is experienced across all parts of the country. The government and I are committed to tackling fraud because we recognise how it impacts all of us. Every pound of taxpayer money that we can save through fighting fraud against the public sector is money that can be spent on vital public services.

The Government Counter Fraud Function was introduced to provide a framework for collaboration between counter fraud experts within and across organisational boundaries to support efficient and effective delivery of counter fraud work across government. The Function has also been important in driving a culture of innovation and ambition, recognising that the power of our imagination and action is stronger when we work together.

There has been notable progress since the Counter Fraud Function’s inception, thanks to the considerable efforts of counter fraud professionals across government and boosted by additional investment of over £1 billion in the government’s counter fraud response since 2021. We have embraced the use of innovative technology and AI to detect more fraud than ever before, working closely with partners in the private sector to drive positive collaborative change. As we get better at utilising our data and technology, we make it harder and harder for fraudsters to operate successfully. We would not be where we are today without the people working within the Function. The Function has developed the Government Counter Fraud Profession (GCFP), the first in the world dedicated to those working to fight fraud. It provides a structure with common professional standards and competencies for those working in counter fraud roles. This strategy supports the government’s continued professionalisation of the counter fraud response notably through the ambition to develop a new counter fraud apprenticeship.

Fraud affects all countries and all sectors and it is evident that no single government can tackle this challenge in isolation. It requires the power of international cooperation through the pooling of our collective knowledge, expertise, and resources. The UK Government established, and continues to lead, the International Public Sector Fraud Forum, which develops world renowned counter fraud best practice. This international insight is a key component in our mission to understand, find and stop fraud against the public sector.

The Public Sector Fraud Authority (PSFA) plays a critical role in this, including by leading the Counter Fraud Function. Since its launch in August 2022, the PSFA has driven impactful change by supporting the improvement of departmental performance in tackling fraud and by expanding the breadth and depth of counter fraud knowledge across government.

There is still more to do to address the challenge of fraud against the public sector and the Government is intensifying its ambitions in how this challenge is met by investing in counter fraud and fostering innovative approaches across fraud prevention, detection and recovery.

Driven through the work of the Counter Fraud Function, everyone involved in public services must play their part in transforming the way the public sector is protected from fraud. From helping departments to manage fraud risks, to taking effective action and pursuing fraudsters where fraud does occur, we as government will continue to collectively fight fraud against the public purse.

The Counter Fraud Functional Strategy for 2024- 2027 will drive our efforts and set out where the Function will go during that time.

Baroness Neville-Rolfe DBE CMG

Minister of State, Cabinet Office

Head of Function Foreword

As public servants, we all have an important role to play in protecting taxpayers’ money and public services from fraud. Alongside our collective responsibility, we also have a maturing Function of 13,000 public servants in counter fraud roles across government.

Day in, day out, those public servants work to make a difference to the levels of fraud in the public sector and beyond. They seek to take action against those who attack the system and to better understand how those attacks happen and make the government more resilient to them. They work to protect our public services and taxpayers money from those who seek to take advantage of the systems and services put in place to support our society. That effort often goes unseen, but it has a huge impact and that is thanks to the hard work and dedication of those working to counter fraud.

However, the size of the challenge remains significant. Our estimates tell us that the levels of fraud and error in public spending is between £33-£59 billion. Whilst we should be proud of the impact we have, we should be committed to increasing that impact.

We know that fraud and economic crime are complex, diverse and quickly changing. The International Public Sector Fraud Forum’s (IPSFF) principles state ‘there will always be fraud’ and ‘fraud and corruption are ever changing’ - and our experience shows the truth of these. The advent of the digital economy has brought great advances to our society, but the agile and innovative tools and channels have also been used by fraudsters to attack individuals, businesses and the public sector.

We must match this challenge by increasing our own ambition, our focus on innovation and the systematic development of our capability to understand and reduce the impact of fraud and economic crime. We should redouble our efforts, and resolutely seek to have the biggest impact we can have. We have the opportunity to develop our capabilities and harness new techniques and technology to have a bigger impact.

With over 300 departments and public bodies across government, there are inevitably differences in the specifics of the fraud risks and threats we face, the approaches we adopt and the experience we have when it comes to fighting fraud. Despite these differences the Counter Fraud Function gives us the opportunity to work together to tackle this challenge both now and in the future; creating a coherent, consistent and effective response.

The creation of the Public Sector Fraud Authority (PSFA) was a signal of the commitment to increase our ambition on fighting fraud, and for that effort to be steered by the experts. The PSFA has worked with other experts from across the Function and more widely to create this strategy, which provides the framework and focuses for our work over the next three years.

The strategy has five strategic objectives, and three underlying behaviours. I would encourage all those working to combat fraud to familiarise themselves with these and think about how they can play a part in our combined journey as a Function. The themes in the strategy can form part of our own organisational Counter Fraud Strategies, our annual Action Plans and our personal objectives.

The challenge that fraud presents has never been higher. However, we have never had more of an opportunity to make an impact. The Function is putting experts at the heart of the response across government and increasingly giving them the tools, guidance and legislation to take effective action against those who attack our public services for their own gain. This strategy sets out how we should focus in the next three years to make the biggest difference that we can.

Mark Cheeseman OBE

Head of the Government Counter Fraud Function

Chief Executive, Public Sector Fraud Authority

Principles for Public Sector Fraud

The International Public Sector Fraud Forum (IPSFF) is a group that brings together experts working to combat public sector fraud from across the Five Eyes countries (Australia, Canada, New Zealand, the United Kingdom and United States). It was brought together by the Centre of the Counter Fraud Function and continues to work together now under the Public Sector Fraud Authority. It shares experiences and best practice and produces leading practice guides for use in governments, public bodies and more widely where appropriate.

The Forum has established 5 principles for public sector fraud:

1. There is always going to be fraud - it is a fact that some individuals will look to make gains where there is opportunity, and organisations need robust processes in place to prevent, detect and respond to fraud and corruption.
2. Finding fraud is a good thing - if you don’t find fraud you can’t fight it. This requires a change in perspective so the identification of fraud is viewed as a positive and proactive achievement.
3. There is no one solution - addressing fraud needs a holistic response incorporating detection, prevention and redress, underpinned by a strong understanding of risk. It also requires cooperation between organisations under a spirit of collaboration.
4. Fraud and Corruption are ever changing - fraud, and counter fraud practices, evolve very quickly and organisations must be agile and change their approach to deal with these evolutions.
5. Prevention is the most effective way to address fraud and corruption - preventing fraud through effective counter fraud practices reduces loss and reputational damage. It also requires less resources than an approach focused on detection and recovery.

The Government Counter Fraud Function

What is the Counter Fraud Function?

Established in 2018, the Counter Fraud Function is one of government’s fourteen functions ^{[footnote 1]}. Government Functions are aligned groupings of resources that undertake work in the same area of expertise across government. Other examples include Commercial, Human Resource, Finance and Project Management. Functions are embedded in departments and public bodies. The purpose of the Counter Fraud Function is to ensure the effective management of counter fraud, bribery and corruption activity in government. It brings together approximately 13,000 public servants who work to find and tackle fraud, bribery, corruption and wider economic crime across government. 11,200 (84%) work for the Department for Work & Pensions (DWP) or HM Revenue & Customs (HMRC). The remaining 16% of counter fraud staff are spread across the rest of government including dedicated investigation units and specialist teams ^{[footnote 2]}. The Function and this strategy relate to government’s response to fraud committed against it. This includes how we, across the Function, reduce the risk of fraud within and against government and how we increase the capability across government for fighting fraud, whether it is focused on public sector fraud or more widely.

Why does the Function exist?

The functional model of government provides expert-led central leadership of cross-departmental corporate functions, professionalising the public sector and driving efficiency, effectiveness and productivity through:

• Setting cross-government strategies and ensuring consistent delivery across government.
• Setting and assuring functional standards so that expectations for each type of functional work are clear, coherent and consistent, and there is a stable basis for assurance, risk management and capability building.
• Developing functional capability including leadership, skills, resources and capacity (people, equipment, facilities), working closely with government professions to specify the right professional competences, induction and training.
• Giving expert advice on strategy, business planning, compliance with standards and controls, how to drive up efficiency and effectiveness, and specific topics (such as complex commercial transactions or employment issues).
• Developing and delivering commonly required services and products, either directly or through third parties.
• Working across government to drive continuous improvement in the way functional work is done.

With over 300 public bodies in government which vary in scale, size and fraud risk, there is not a ‘one size fits all’ approach to finding and fighting fraud. The benefit of having a dedicated Counter Fraud Function is that it enables collaboration within and across organisations to share practices, address the fraud and error challenge against government and ensure efficient and effective delivery of counter fraud work. The functional model also means this can be done in a way that departments and public bodies can tailor to fit their own areas of responsibility.

By bringing together specialist counter fraud expertise within and across organisations, the Function can help those working in and leading public bodies to understand and manage the risk and impact of fraud and give them an understanding of the tools and capabilities that can be used. This helps ensure that government has the capabilities to fight fraud effectively in the modern world.

The development of Counter Fraud as a distinct function also comes from the need to recognise that the primary role of the traditional business functions is not to find fraud. Organisations increasingly are, and should be, investing in specific counter fraud resource to detect, prevent and recover fraud.

In line with the Declaration on Government Reform made in 2021 ^{[footnote 3]}, the Function provides a platform to develop people, performance and partnerships. It supports the Function’s ambition to have the best people leading and working in counter fraud; to modernise the government’s counter fraud response; and for us to act together as one government team to counter fraud and deliver for citizens.

Where does bribery and corruption fit in?

The Function’s work covers fraud as well as corruption, bribery and associated loss from error within and against the public sector. Corruption is often seen as a precursor to bribery and has been defined by HM Government as the abuse of entrusted power for private benefit that usually breaches laws, regulations, standards of integrity and/ or standards of professional behaviour. Bribery and corruption are also hidden crimes that can facilitate fraudulent activity and cause harm to the public sector. Error is included due to the cost and complexity of determining fraudulent intent.

There are other areas of government who also have a focus on fraud, bribery and corruption in different contexts, and the Function works closely with them to ensure a coordinated response. Fraud, bribery and corruption will therefore be referred to throughout this strategy.

How is the Function governed?

The Head of the Function is the Chief Executive Officer of the PSFA. The Function is governed by the Fraud Functional Leaders Board, which is made up of counter fraud senior civil servant (SCS) leads from across government. The Function is spread across departments and public bodies, made up of those who work to counter fraud within them. When referring to ‘the Function’ throughout this strategy, this relates to the work in counter fraud across government and not solely the PSFA.

What is the role of the PSFA within the Function?

The PSFA ^{[footnote 4]} was launched in 2022 to be the government’s Centre of Expertise for the management of fraud against the public sector. The PSFA works with departments and public bodies to understand and reduce the impact of fraud. It also leads the International Public Sector Fraud Forum (IPSFF), working with counter fraud experts in Australia, Canada, New Zealand and the United States, to support the sharing and development of international counter fraud best practice. Part of the PSFA’s Mandate is to lead and be the centre of the Government Counter Fraud Function ^{[footnote 5]}. Acting as the centre of the Function, the PSFA brings together experts from across public bodies and other sectors to produce guidance and standards to deepen expertise and to deliver greater fraud prevention and recovery outcomes. This is used in central government, and will be used more widely in the public sector and beyond. The Counter Fraud Functional Standard that has been developed defines the minimum standard that departments and public bodies should have in place to effectively deal with fraud ^{[footnote 6]}.

How does the Function support the wider public sector to fight fraud?

The Function has a wide remit over the public sector. However, there are parts of the public sector that have greater freedom to manage and govern themselves. This is provided to the Devolved Administrations through the devolution settlements, and to Local Authorities under the Localism Act 2011. This means they are not subject to the PSFA Mandate or part of the governance of the Counter Fraud Function.

However, the Function and the PSFA will proactively make the standards, expert guidance, data analytics tools, access to counter fraud training and pathways into the Government Counter Fraud Profession available in support of Local Authorities and Devolved Administrations on a voluntary basis.

What is the role of the Government Counter Fraud Profession in supporting the Function?

The Government Counter Fraud Profession (GCFP) was established in October 2018 to develop a common approach and agree best practice for those working in counter fraud, including within the Function. Its goal is to attract, nurture, and retain talent, enhance counter fraud capabilities and position counter fraud as a focal point for those entering the public sector. It currently has over 7000 members across 66 organisations. The Profession published its current strategy in 2023. The strategy focuses on:

• Building deep counter fraud capability with a shift from the focus on investigation and intelligence to fraud prevention.
• Implementing continual development of members to embed a culture and process for ongoing assessment of knowledge and competence.
• Investing in leadership skills now, and for the future, through the Counter Fraud Leadership Programme.
• Increasing marketing and promotion of the Profession to raise the profile of the Profession, enhance the recognition of existing members, and encourage future ones.
• Promoting diversity and inclusion to ensure that it is representative of the public it serves, and the public services and systems it seeks to protect.

Who is the Counter Fraud Function strategy for?

This Functional strategy is for the whole of government, to see where the counter fraud work is going and how they can play their part. Secondly it is for those working in fraud to use it to shape their priorities and challenge them to go further, supported by the PSFA.

Changing Context

It is currently estimated that fraud and error in the public sector is between £33-£59 billion per year (excluding COVID-19 schemes).7 Fraud against the government and public bodies takes money away from vital services and support for citizens. Whilst some fraud against the government is inevitable, all departments and public bodies have a responsibility to reduce it.

COVID-19

The advent of the COVID-19 pandemic changed the nature of the fraud landscape across government. During the pandemic, the government provided unprecedented levels of support to preserve livelihoods, save businesses and protect the UK economy. Its interventions helped millions of people and businesses through the worst effects of the pandemic, directly supporting 14.6 million jobs and self-employed individuals and preventing around a quarter of a million businesses from closing. The schemes helped to accelerate the UK’s recovery from the pandemic having achieved their primary aims of protecting jobs and businesses.

In such emergency situations where there is a need to act quickly, the threat and risk of vulnerabilities to fraud are inherently much higher. As such, levels of fraud increased during this time.

As the health and economic context during the pandemic changed, government adapted its approach to respond to fraud. Rules around support schemes were tightened, existing claims were revisited and investigated, and potentially new fraudulent activity was blocked.

Efforts to investigate fraud from the COVID-19 era are continuing. The lessons learned from the pandemic and the ongoing COVID-19 Inquiry are being integrated into counter fraud activity across government. For instance, the PSFA has developed the Global Fraud Risk Assessment, which provides an assessment of fraud risk across government spending and will help inform a list of cross cutting risks and the areas of highest risk to better target counter fraud activity. In addition, the experiences of operating the COVID-19 Loan Scheme Fraud Analytics Programme and the COVID-19 Fraud Hotline have been directly brought into the development of the PSFA operating model.

Wider government initiatives

As a Function, we are not addressing the challenges of fraud, bribery and corruption in isolation. This strategy seeks to account for and maintain alignment with the wider government fraud and economic crime landscape by factoring-in and aligning to recommendations made by the National Audit Office’s Tackling Fraud and Corruption Against Government report and subsequent Public Account Committee recommendations, as well as the Economic Crime Plan 2 (2023-2026), the Fraud Strategy, and the forthcoming UK Anti-Corruption Strategy. We recognise that the fraud and economic landscape does not remain static and will continue to maintain oversight of it and adapt our ways of working as appropriate, so that we can continue to develop and demonstrate best practice.

There is also recognition that fraudsters are operating across borders and that different countries are all trying to tackle the same challenges. The Function will therefore continue to support international collaboration, seeking opportunities to develop partnerships and good practice, such as through continued engagement with the IPSFF.

Legislative changes and investment in counter fraud are also driving forward positive action across government. The legislative response to fraud, bribery and corruption has been continuing to build with the introduction of the Economic Crime and Corporate Transparency Act (2023) and the Procurement Act (2023).

The Digital Economy Act (DEA) (2017) debt and fraud powers have been retained by Government following an extensive review. The powers provide an innovative pathway for data sharing to combat fraud and reduce debt to the public sector. The DEA drives wider government initiatives to combat fraud through increased data sharing across the public sector, with more pilots being converted into Business as Usual.

The powers have been used to enable more than 100 data sharing pilots across 70 local authorities and 17 government departments or agencies and have saved taxpayers at least £137 million since coming into force in 2018. There is more to be done in this space, including adding new bodies to the DEA Schedules, increasing the reach and impact of the powers in combating fraud.

Changing and evolving nature of fraud threats

Fraud is an ever-present challenge for all countries and sectors. The nature and threat of fraud being committed against government and the public sector is constantly evolving, both from within the UK and internationally. It is an environment that everyone across the Function needs to be able to adapt themselves to.

Advances in technology such as the rapid development of artificial intelligence (AI), and the way we administer our systems on an increasingly digital basis, have brought great advantages in how government delivers public services and support. At the same time, this is creating new opportunities for fraud to be committed, with criminals constantly adapting their approaches, methods and means of attack to make use of these advances.

The way these changes manifest and the way they are responded to across the Function will continue to evolve. The PSFA will continue to publish annual Fraud Landscape Reports and bulletins that include the levels of detected fraud (and corruption) and associated error in departments and public bodies (excluding tax and welfare, as these are published elsewhere).

Our Strategy 2024-2027

We are collectively looking to build on the progress that has already been made across the Function through this 2024-2027 strategy, with a renewed focus on making a step-change to find and fight fraud.

Recognising the diverse experiences of counter fraud activity across government, it will look to build on the individual strengths and expertise of departments and public bodies to collectively strive for better outcomes.

Over the next four years, we want to put government on the best possible footing to meet the fraud challenges we face today as well as those that are emerging in the future.

The strategy sets out the high-level vision for the Function, and it will be supplemented by action plans outlining the specific commitments that we will work on to achieve our shared ambitions.

• Mission: Fraud is a hidden crime and to fight it you have to find it.
• Vision: To work across government to make the UK the world leader in understanding, finding and stopping fraud against the public sector.
• Supporting statement: We will do this by creating a shared and adaptable approach to fighting fraud and economic crime that is innovative, ethical, encourages challenge and promotes collaboration across sectors.

For the strategy period 2024-2027, we will focus on five strategic objectives to drive counter fraud activity across government in order to deliver better outcomes:

1. Support and develop our people.
2. Harness data and technology more effectively.
3. Embed prevention.
4. Drive a targeted, proportionate response against fraudsters.
5. Secure cross-system cultural change.

These will be underpinned by three key enabling behaviours:

1. We will work together.
2. We will focus on making a difference.
3. We will be innovative.

Objectives

Support and develop our people

2027 Outcome: The Function has more people recognised as part of the Counter Fraud Profession, with an increased number of those operating in fraud control roles. There will be programmes in place to recruit and retain future talent, including future leaders in counter fraud, who are representative of those we serve.

Fraud is complex, and countering it relies on us having the appropriate skills and expertise. The Profession will support those in fraud roles in departments to build broad knowledge and competencies. While maintaining the core skills of Investigation and Intelligence for when fraud occurs, more of the future workforce will be centred on fraud control, operating in disciplines including Risk, Measurement, Culture, Detection and Prevention.

The Function will work closely with the Counter Fraud Profession to ensure that we have more qualified in doing counter fraud roles. We want to attract talent and increase capacity, while ensuring that members are developed and supported in their work. We want to develop a dynamic workforce that is better poised to meet evolving fraud threats and which is able to develop deep expertise.

Actions that we will take to support this include:

• Deepening the focus on building counter fraud knowledge, skills and expertise by increasing the number of training opportunities.
• Developing talent pathways for leaders and future leaders.
• Developing an ongoing support offer to retain staff, including cross-sector mentoring.
• Diversifying by introducing support to break down barriers to entry, targeting those starting their career, with intern programmes, applicant coaching and apprenticeships.
• Expanding the International Public Sector Fraud Forum secondment programme.

Harness data and technology more effectively

2027 Outcome: The Function will have the data fundamentals right, ensuring we have more key data sets in accessible and shareable forms. It continues to innovate in the use of technology, including AI, to increase the amount of fraud prevented and detected by data analytics.

Accurate and shareable data is crucial to understand, identify and counter fraud. Departments hold a lot of data, and the Function will work across organisational boundaries to promote data sharing and to minimise the barriers to doing so. Data and analytics will be utilised across the Function to drive increased performance, supported through quality evidence and assurance activity.

The rapid pace of change in technology creates new opportunities for fraudsters, but it also creates new opportunities for us to advance our counter fraud response. Those working in the Function will develop public/ private data partnerships and adopt best in class technology and use of AI to drive more fraud prevention and detection outcomes. As a Function, we will build on our technological innovations, utilising a wide range of technologies, machine learning and AI where they can be most impactful. We will harness cross-sector innovation to drive forward ambitious counter fraud activity.

Actions that we will take to support this include:

• Increasing the delivered benefits derived from data matching and analytical activity across the Function.
• Increasing the number of departments onboarded to the Single Network Analytics Platform (SNAP) and maintaining the National Fraud Initiative (NFI) programme.
• Increasing the number of departmental-led Digital Economy Act 2017 data pilots.
• Developing a common framework for counter fraud data sharing.
• Identifying new opportunities to work in partnership with the private sector.

Embed prevention

2027 Outcome: The Function has embedded robust methodologies for prevention and measurement, and is able to clearly articulate the benefits of both. There is an increase in the number of Initial Fraud Impact Assessments (IFIAs), Fraud Risk Assessments (FRAs), fraud measurement and controls testing activities to better design-out fraud risks from projects and schemes.

The best way to tackle fraud, bribery and corruption is to prevent it from happening. The Function will work to embed an increased range of strong prevention practices, developing enhanced approaches to designing out fraud including controls testing and to measure the benefits of preventative action. More staff will be qualified to complete this work.

We will develop and embed robust prevention activity from the initial stages of scheme and programme design with clear underpinning methodologies. There will also be increased understanding of the risk and threat landscapes. The value of prevention will be recognised across the system, supported by the development of enhanced and consistent measurement, assurance and controls testing approaches.

Actions that we will take to support this include:

• Increasing the number of trained risks assessors across the public sector.
• Increasing the number of quality assured IFIAs and FRAs completed by departments and public bodies.
• Developing the Global Fraud Risk Assessment and High Fraud Risk Portfolio, improving understanding of risk across government.
• Driving increased departmental application of fraud prevention methodologies informed by the HMG Prevention Standard.
• Delivering targeted fraud awareness training within departments and public bodies.

Drive a targeted, proportionate response against fraudsters

2027 Outcome: The Function supports the coordination of a targeted, proportionate response against fraudsters, taking stronger and more impactful action. There is a cohesive approach to counter fraud activity across all departments, with the different counter fraud tools being utilised effectively.

The counter fraud response varies across the public sector as departments and public bodies have differing access to powers and skills. The Function will increase access to enforcement activity, coordinating cross-departmental action to maximise the consequences felt by those who commit fraud, bribery and corruption against and within the public sector. Enforcement will be increasingly professionalised with an increased level of oversight. By facilitating wider feedback loops between prevention and enforcement activity, the effectiveness of counter fraud activity will be enhanced.

Whilst a strong and consistent enforcement response (including investigation, prosecution and recovery) is still an important deterrent, we need to think more broadly. The Function will increase, apply and more effectively coordinate the range of criminal, civil and other counter fraud tools in our toolbox.

Actions that we will take to support this include:

• Maintaining and developing the Internal Fraud Hub to include contractors working in the public sector.
• Piloting an enforcement body for the public sector that can be accessed by departments and public bodies who need it and, if successful, implementing it.
• Mapping the counter fraud powers and sanctions available to the Function and developing a cross-Function coordination model.
• Developing best practice guidance on how departments and public bodies should utilise different approaches in responding to fraudsters.
• Introducing new legislation, when parliamentary time allows, to modernise the counter fraud powers used to support the work of the Function, alongside targeted oversight and assurance of their use.

Secure cross-system cultural change

2027 Outcome: There is a demonstrable increase in engagement from non-counter fraud professionals with the Function as we get better at telling people about what the Function does and why it is important. There is increased advocacy for counter fraud activity throughout the public sector. There are consistent and regular public communications regarding the counter fraud activity that is being undertaken.

It is important that the work of the Function is understood. As such, fraud experts need to do more to be heard. Supported by the PSFA, the Function will use clear and accessible communications to celebrate our successes, ensuring key partners understand the value and impact of our work. This will support broader activity aimed at building the confidence of the public in the government’s handling of fraud through the action it takes. Those working in the Function will also achieve greater cross-system buy-in through increasing fraud awareness across the public sector and making it everyone’s responsibility to protect taxpayers’ money.

Those working in the Function will work to improve recognition of the value and impact of counter fraud work. There will be increased advocacy for it at every level, with the aim of increasing engagement from senior leaders and non-counter fraud professionals across the public sector. Those working in the public sector will understand how to recognise fraud and how to access the necessary support to tackle it from the Function.

Actions that we will take to support this include:

• Developing cross-government communications to increase the recognition of counter fraud work and how its impact is understood.
• Developing the Counter Fraud Function community of practice.
• Bringing international and domestic partners together through the International Public Sector Fraud Forum to develop and share best practice.
• Increasing engagement with cross-government corporate governance structures to embed counter fraud best practice at all levels of decision making.
• Increasing engagement with the Finance, HR, Commercial, Grants and Debt Management Civil Service Functions to further embed counter fraud awareness and activities into their operations and policies.

Enabling Behaviours

We have identified three key enabling behaviours that cut across all of the strategic objectives. Embodying them within all our work will help us achieve success together.

We will work together.

We will collectively prioritise and promote effective collaboration across the Function, the public sector (including Local Authorities and the Devolved Administrations), other sectors and internationally. This is in recognition that fraud is a shared challenge and that effective solutions can only be found by working together.

• Support and develop our people: We shall work with internal and external partners to develop strategic insights on capability requirements, skill gaps and capability development best practice.
• Harness data and technology more effectively: We shall work together to solve issues that lie outside individual departmental and business areas, develop best practice and innovate in partnership with the private sector.
• Embed prevention: We shall work across government, internationally and with the private sector to innovate in developing prevention best practice and measurement approaches.
• Drive a targeted, proportionate response against fraudsters: We shall make the most of the enforcement powers and expertise across the Function by working together to support cross-departmental targeted counter fraud activity.
• Secure cross-system cultural change: We shall create the right environment to work together to harness knowledge and effect change, recognising no one person or body can do this alone. We shall work with other functions and professions to increase buy-in.

We will focus on making a difference

Fraud against the public sector is a crime that impacts us all. It affects the quality and quantity of public services. We will be focused on driving outcomes to maximise the impact of our work.

• Support and develop our people: We shall build our capability in fraud management so that we can understand, measure and respond effectively.
• Harness data and technology more effectively: We shall target our use of data and technology to the areas of greatest risk and challenge in order to make the biggest difference to counter fraud outcomes.
• Embed prevention: We shall agree and achieve ambitious departmental financial impact targets to drive collective action, ensuring we are doing more to find, prevent and recover fraud.
• Drive a targeted, proportionate response against fraudsters: We shall take a broad range of actions to maximise the consequences against those who commit fraud against the public sector.
• Secure cross-system cultural change: We shall get better at communicating the value and importance of our work at every level, increasing engagement and buy-in from senior leaders to drive wider organisational change and better counter fraud outcomes.

We will be innovative

Fraud is ever changing and so we need to be innovative in our ways to find and counter it, developing new methods and approaches and ensuring that we are building the evidence case of how effective our work is. Evaluating the effectiveness of such measures will let us prioritise those that work best and embed a culture of continuous improvement as we strive to achieve the best outcomes.

• Support and develop our people: We shall be innovative in our approaches to recruitment and development so that we can attract and retain the best people. Through the Counter Fraud Profession, we shall develop new standards and training to build knowledge, skills and expertise, using a continuous improvement approach to maximise our impact.
• Harness data and technology more effectively: We shall be innovative in how we use existing data sets, and harness new ones, to maximise their value in countering fraud. As new technologies emerge, we shall be innovative in how we incorporate them to form part of an effective counter fraud response.
• Embed prevention: We shall be innovative in developing strong and consistent prevention methodologies, which will be matched with robust evaluation to understand what works, establish best practice and demonstrate the value of the prevention model.
• Drive a targeted, proportionate response against fraudsters: We shall be innovative in how we utilise a wide range of civil, criminal and other actions to take effective actions against fraudsters, maintaining our integrity whilst recognising that embracing a greater diversity of approaches will result in better outcomes.
• Secure cross-system cultural change: We shall look at new and innovative ways of engaging and communicating across the Function, across government, and externally to have maximum impact. We shall take an iterative approach, building on regular review and evaluation of what is working to ensure that our messaging is clear and understandable.

Next Steps

The Strategy sets out the objectives for the Function and the enabling behaviours that will support them. The Functional Leaders Board and the PSFA will work across the Function to develop the actions, commitments and metrics required to ensure that we can work together to achieve our objectives over the strategy period.

Recognising that fraud is ever changing and the Function needs to be able to react to change accordingly, we will develop three action plans over the strategy period:

1. Action Plan 2024-2025
2. Action Plan 2025-2026
3. Action Plan 2026-2027

These will be produced collaboratively with members of the Function, aligning to the development of organisational action plans as set out in the Counter Fraud Functional Standard. The delivery of these action plans will be the collective responsibility of all members of the Function, and will undergo regular assurance via the Functional Leaders Board.

1. Government Functions ↩

2. Tackling fraud and corruption against government (PDF, 612KB) ↩

3. Declaration on government reform ↩

4. Public Sector Fraud Authority ↩

5. Public Sector Fraud Authority Mandate (PDF, 3.4MB) ↩

6. Government Functional Standard GovS 013: Counter Fraud ↩