Service Provision
The CFEU reports directly to Audit Committees across the partnership. The Head of Service meets quarterly with the Chief Finance Officer (S151) and Internal Audit to discuss activities and internal control risks. This ensures Councillors, corporate management and governance officers are briefed in relation to fraud risk and current activities. By having a dedicated team collecting and recording this data, the partnership is ensuring a well-rounded risk management approach that is working to continuously review and improve internal controls.
The CFEU have developed a fraud risk strategy that sets the direction and desired outcomes for the partnership. An important part of this approach is the anti-fraud culture and practices which are adopted to advise and guide members and staff on the approach to fraud and corruption.
The fraud risk work stream includes service specific fraud risk registers, which are to be reviewed annually to help identify new and emerging risks, as well as high-risk areas that require more resource. This process will, in turn, inform the CFEU annual work plans, which together comprise the CFEU fraud response plan.
Externally the CFEU belongs to the local MAAF (Multi Agency Approach to Fraud) Group, working with Gloucestershire Constabulary Economic Crime Team, Trading Standards, Victim Support, Crime Stoppers, the NHS, the OPCC (Office of the Police and Crime Commissioner) and Gloucestershire County Council. The MAAF has been set up to discuss fraud trends, victim care and communication of fraud scams. For more information see the GLASSJAR tab.
The CFEU works across its partners and the wider criminal enforcement community to share good practice, develop knowledge and improve detection and prevention.
The CFEU is also responsible for the collection and publication of Fraud Transparency Data for the partnership. Data can be collated and provided for this purpose.
The CFEU has responsibility for the following policies:
- Counter Fraud and Anti-Corruption Policy
- Corporate Enforcement Policy
- Council Tax, Council Tax Reduction Scheme, Housing Benefit Penalty and Prosecution Policy
- Proceeds of Crime & Anti-Money Laundering Policy
- Whistle-Blowing Policy
- Regulation of Investigatory Powers Act (RIPA) 2000 (Surveillance & CHIS)
- Investigatory Powers Act (IPA) 2016 (Acquisition of Communications Data)
- Use of the Internet and Social Media in Investigations and Enforcement
This includes drafting, consultation and presentation to the appropriate Committee for adoption. Policies are reviewed regularly to ensure they are relevant, in line with best practice and legislatively up to date.
The CFEU Head of Service is the RIPA Co-Ordinating Officer for all Partner Councils. This role entails policy management, maintaining the Register of RIPA/Non-RIPA activity at each site, registering the Senior Responsible Officers (SRO)/Authorised Officers (AO) with the Investigatory Powers Commissioners Office (IPCO), providing information and managing IPCO inspections, reviewing and advising on all RIPA/Non-RIPA applications submitted by officers prior to authorisation by the SRO/AO, and reporting activity to Councillors and corporate management.
The CFEU Head of Service is also the nominated contact for the National Anti-Fraud Network (NAFN) in respect of IPA 2016 requests for communications data. The CFEU provides advice and assistance to other service areas when making IPA application requests and monitors activity to ensure compliance.
The CFEU provide in-house training to staff and Councillors in relation to CFEU policies and procedures, including the following:
- General Fraud Awareness
- Whistleblowing
- Housing and Tenancy Fraud – for all Housing Officers, and also for support staff such as repairs and maintenance teams
- Procurement Fraud
- Proceeds of Crime and Money Laundering
- Criminal Investigation and Enforcement Training – to include CPIA and PACE
- Witness Statement Training
- Regulation of Investigatory Powers Act (RIPA) / Investigatory Powers Act (IPA)
The CFEU provide trained and dedicated resource for departments in the following high-risk areas:-
Council Tax Discounts: Assistance with processing NFI data matches and other specific fraud drives and reviews, sanctions and penalty application.
Council Tax Reduction Scheme (CTRS): Authorised Officers under the Council Tax Reduction Schemes (Detection of Fraud and Enforcement) (England) Regulations 2013 to investigate cases of fraud, to prosecute and apply criminal sanctions, and work jointly with the DWP. From 2023/2024, the CFEU is commencing a proactive rolling programme of CTRS reviews to identify overpayments and ensure correct discounts are applied.
Housing Benefit: The CFEU are the DWP Single Point of Contact (SPoC) for its partner Councils and undertake all liaison work with DWP regarding referrals, exchange of information, joint working, overpayment calculations and provision of witness statements.
National Non-Domestic Rates (NNDR): Assist with reviewing specific exemptions and reliefs, visit high-risk properties and business types, assist with tracing and crosschecking data.
Housing Allocation, Housing and Tenancy Fraud Investigations: Authorised Officers under the Prevention of Social Housing Fraud Regulations 2014, prepare cases for both criminal and civil action when required. Verification of housing applications at point of sign-up, homeless claim verification, checks in relation to Right to Buy and Shared Ownership applications to include advice on Money Laundering regulations.
In addition, the CFEU belong to the national Tenancy Fraud Forum and attend two local Tenancy Fraud Forum groups covering the partnership area. These are used to promote collaborative working, share good practice, develop policy and improve learning.
Disciplinary / Code of Conduct Investigations: Undertake disciplinary investigations involving allegations of staff or Councillor corruption, fraud, or other serious misconduct. Manage sensitive whistleblowing referrals with full confidentiality and conduct discreet enquiries with minimal notification. The CFEU are experienced in preparing paperwork and presenting at Disciplinary and Tribunal Hearings in relation to employee matters, as well as Standards Panel/Committee Hearings in relation to allegations involving Councillors.
Regulatory Enforcement: The team assist regulatory enforcement officers in investigation and criminal enforcement/prosecution in relation to:
- Planning Breaches
- Heritage and Conservation (Listed Building / Tree Preservation Orders)
- Housing (Housing Standards / HMO Licensing)
- Environmental Services (environmental crime / health and safety / food standards)
- Licensing (taxis / unlicensed breeders / unlicensed establishments / animal welfare)
- Any other criminal legislation within the Council’s remit
The CFEU have extensive experience with regard to compliance with criminal investigation legislation, obtaining evidence in accordance with the Criminal Procedure and Investigations Act 1996 (CPIA) and interviewing under caution in accordance with the Police and Criminal Evidence Act 1984 (PACE). The team work with the in-house legal provision across the partnership, submitting prosecution paperwork, adhering to disclosure procedures and attending Court to present evidence.
The CFEU has successful used the Fraud Act 2006 to bring charges in relation to regulatory enforcement in areas such as Licensing and Animal Welfare.
The CFEU carries out proactive work in a number of areas to detect fraud and anomalies and provide assurance. This not only promotes good practice and exposes areas of weakness, but also provides valuable loss avoidance figures for the Councils. Examples include:
- Housing Waiting List Review: Regular reviews of all emergency, gold and silver band applications
- National Fraud Initiative (NFI) Match Reviews: Revenues, benefits, housing, payroll (staff and Councillors) matches are the responsibility of the CFEU to review, make recommendations to the relevant department, and process all results. Any that require further investigation are opened as an active investigation
- Business Rates Reviews: Self-Catering accommodation, empty premises, small business rates
- Staff Mileage/Expense Claims: Reviews and procedures.
- Council Tax Reduction Scheme: Proactive fraud drives (high risk claims), reviews
- Council Tax Discount / Exemption reviews
- Aged Debt Review
- Grant Schemes: Assurance and enforcement activities
The CFEU supports social housing providers in tackling housing and tenancy fraud. The overall remit is to prevent, detect and deter abuse of social housing and public funds.
Housing and tenancy fraud remains one of the top four areas of fraud and abuse within the public sector. This takes many forms, but the two most significant areas are right to buy and illegal subletting.
We work with housing officers to provide intelligence and investigate abandoned or illegally sublet properties, general tenancy fraud allegations, and any suspicious housing applications. Our goal is to prevent the loss of housing stock and recover properties obtained by fraud. Our areas of work include:
- Housing and Tenancy Fraud investigations
- Preparation of cases for both criminal and civil action
- Verification of housing applications at point of sign-up and homeless claim verification
- Checks related to right to buy and shared ownership applications, including advice on money laundering regulations
CFEU Officers are authorised under the Prevention of Social Housing Fraud (Power to Require Information) (England) Regulations 2014, allowing them to obtain information about an individual from organisations such as financial institutions and utility companies. The Act also created new offences in relation to housing fraud that can be prosecuted by Local Authorities acting on behalf of social landlords.
The CFEU can provide policies and advice in relation to Counter Fraud and Anti-Corruption, Housing and Tenancy Fraud, Whistleblowing and Money Laundering.
Additionally, the CFEU belong to the national Tenancy Fraud Forum and participates in two local Tenancy Fraud Forum groups within the partnership area. The forums are used to promote collaborative working, share best practices, develop policies, and improve learning.
Charities have a duty to protect funds from fraud in line with Charity Commission guidance. Failure to do so exposes them to a greater risk of fraud and/or corruption.
In general terms, the existence and application of an effective fraud risk management regime assists a charity in maintaining effective financial governance, making it less susceptible to legal challenges.
The focus of CFEU support is prevention, raising awareness, strategic support and policy review. This can include:
- Counter Fraud and Anti-Corruption Policy
- Whistleblowing Policy
- Proceeds of Crime and Anti-Money Laundering Policy
- Fraud Awareness and Whistleblowing training for all staff
The payment schedule will include the cost of strategic delivery, case management contribution, service support costs and a daily rate or fixed fee for operational delivery.
As an indicator, our current daily rate fee for 2025 / 26 is £350.
Please contact us at CFEU.enquiries@cotswold.gov.uk to arrange a discussion about your requirements.