Interim CCO Freya Grimwood at Cambridge International Symposium
The SFO's interim Chief Capability Officer, Freya Grimwood, delivered a keynote speech at the Cambridge International Symposium 2024.
On Monday 2nd September 2024, Interim Chief Capability Officer Freya Grimwood delivered a keynote speech at the Cambridge International Symposium on Economic Crime.
Freya Grimwood speaking
I am delighted to be here at Jesus College for my first Cambridge International Symposium on Economic Crime. I am Freya Grimwood, currently serving as Interim Chief Capability Officer at the Serious Fraud Office, which means I am responsible for strategy, skills, resourcing and systems.
I expect many of you are familiar with the SFO and our work. So I would like to start by setting out a few highlights of what we have been doing since the last Symposium.
- In March, we secured the conviction of a former Ministry of Defence employee for misconduct in public office following a complex investigation into Saudi Arabian defence contracts. This case also resulted in recovery of c. £30m from the defence firm that subsequently employed him.
- In May, an SFO prosecution resulted in the conviction of an investment manager for his role in a £100m no-win no-fee fraud. He was sentenced to eight years’ imprisonment.
- In August, the Director charged five people with conspiring to make corrupt payments to benefit the business of FTSE 100 company Glencore. This comes just under two years after Glencore itself paid the UK’s largest ever corporate penalty for bribery. That sentence alone accounted for over half of all the dirty money confiscated by all UK public authorities that year.
As the theme of this year’s Symposium is ‘suspect assets’, I also want to mention some of our recent proceeds of crime work and how we continue to ensure criminals do not benefit from their crimes.
- We continue to investigate £30m worth of suspected criminal properties belonging to the daughter of the former President of Uzbekistan.
- We are using a novel legal argument – used only once before – to present claims in the High Court on behalf of the victims of a fraudster, so that recovered funds can be paid directly to those victims.
- Last year, we ‘revisited’ a confiscation order to recover a further £250,000 held in a tennis club debenture from the mastermind behind the UK’s largest mortgage fraud, ten years after his conviction.
The SFO’s live casework covers fraud worth hundreds of millions of pounds, and the penalties given out in SFO cases are often so large that the SFO’s return on investment to the taxpayer is over 3 to 1.
- But the SFO’s role is more important than statistics alone can convey. As well as providing justice to thousands of victims, the SFO’s mission is to protect the UK’s reputation as a safe place to do business. How do we do this?By investigating complex investment frauds, we demonstrate to foreign investors that their money is safe in the UK.
- By investigating bribery and corruption, we ensure UK companies abide by the rule of law and conduct business cleanly and fairly in the UK and abroad.
The UK Government has made clear that economic growth is a top priority. Our role in both the pursuit and prevention of economic crime is a critical component in delivering that growth.
Last September, our new Director, Nick Ephgrave QPM, joined the SFO from the Metropolitan Police Service, where he ran previously frontline operations as Assistant Commissioner.
Since then, we have launched a new five-year strategy setting out how we will improve case progression, enhance our use of technology, and strengthen our ability to recruit and retain the best people to deliver our mission.
The economic crime landscape is always evolving and we must use new tactics and techniques to fight back. These techniques include embracing machine learning and making better use of our best sources: including whistleblowers and offenders themselves.
I would like to take a minute to explain how important these techniques are.
First, machine learning. We are currently trialling using machine learning to support teams to review material in our cases. The average SFO case involves five million documents, and the largest currently around 48 million. So, perhaps unsurprisingly, meeting this disclosure burden costs 25% of our operational budget. Machine learning is critical to reducing that cost in the long term and providing better value for money.
Next, whistleblowers. Whistleblowers offer powerful evidence from the scene of the crime – something rare and valuable to us as prosecutors of such complex economic crime cases. The Ministry of Defence misconduct case I mentioned earlier stemmed from two whistleblower sources. We want to make better use of whistleblowers, and we think a critical part of this is incentivising them to come forward.
Finally, assisting offenders. We want to incentivise those complicit in criminality to work with us. The Director already has the power to offer immunity in the right circumstances.
As well as whistleblowers and assisting offenders, another vital source of information to us is companies themselves. We are updating our guidance to companies to provide more clarity on how we expect them to cooperate if they suspect wrongdoing in their ranks, and what assistance we expect to consider when opening Deferred Prosecution Agreement negotiations. We hope that this guidance will help companies to make better informed decisions.
In addition to these techniques, we continue to rely on some age-old approaches: most importantly for this audience, our domestic and international relationships. This kind of collaboration is central to continued success. For example:
- All of the 15 sites we searched in the last year were secured in collaboration with the National Crime Agency or local police forces, but it’s not just operations on the ground that require support from partners.
- All of our cases have some kind of international angle, from intelligence requests and mutual legal assistance requests to tandem investigations, Joint Investigation Teams and global settlements.
So – to those of you here who continue to work with us in the fight against economic crime – thank you.
And to those who are interested in finding out more about the SFO and our work – I would encourage you to read our new five-year strategy and would be happy to talk to you later today.