3. IMPACT
3.1 As stated above, there were no set targets for the project, beyond generally improving financial investigation in the three forces, by increasing the number of financial investigators in local force divisions with the objective of targeting community level criminal activity.
3.2 The discussion of impact therefore involves different notions of the objectives for the project, and quantitative and qualitative measures of these. These included reports of POCA activity, records of SARs activity, and reports of the number of financial enquiries that were undertaken, and training sessions given.
Proceeds of Crime (POCA) data trends
3.3 Table 1, below, shows some of the performance trends in POCA returns for the three police forces for three reporting periods, the first and second 6 month periods of 2010, and a shorter 4 month period between January and April 2011.
3.4 There are a number of caveats attached to the presentation of these. First, any movement in trends may be caused by a number of factors, unrelated to any financial investigation such as a 'natural' reduction in crime or increased levels of police enforcement; it is difficult to establish the level of additional impact that the additional resourcing may have had on these outputs.
3.5 Second, the recovery of assets through criminal or civil processes may take a long time, possibly several years, and any additional success achieved by the financial investigators who are the subject of this review will not be realised during the two years of the project. Also the true impact of success will be associated with the final results rather than the money/assets identified for recovery; the money recovered from criminals after the criminal/civil processes have concluded. This may sometimes be many years down the line after a financial investigator has made their contribution to the police work.
3.6 Third, the financial measures of recovery are not necessarily good proxies for the actual amount of disruption caused to organised criminals, and the relationship between financial recovery and social harm to communities will not necessarily be linear: a greater financial recovery does not necessarily equate to a parallel reduction in reduced threat or harm to communities. Police tasking is not driven by income generation and some of the smaller recoveries may be more significant than higher ones in terms of the benefits felt by communities, and correspondingly in terms of police performance.
3.7 The following table shows the three forces six-monthly activity reports for the first 18 months of the 2 year project period.
Table 1: Proceeds of crime data trends (source: Lothian and Borders, Strathclyde and Tayside Police)
Lothian and Borders
| Period 1 (1 Jan- 30 June 2010) | Period 2 (1 July- 31 Dec 2010) | Period 3 (1 Jan-30 April [2] 2011) |
|---|
| Value of assets identified and reported to SOCD | £4,287,294 | £3,486,724 | £2,130,356 |
| Value (and number) of cash seizures over £1000 | £72,913 (31 seizures) | £93,881 (27 seizures) | £79,959 (33 seizures) |
| Value of recoverable property identified and reported to CRU | 0 | £3,600,000 | 0 |
Strathclyde
| Period 1 (1 Jan- 30 June 2010) | Period 2 (1 July- 31 Dec 2010) | Period 3 (1 Jan-30 April 2011) |
|---|
| Value of assets identified and reported to SOCD | £5,767,834 | £11,563,451 | £7,904,781 |
| Value (and number) of cash seizures over £1000 | £644,264 (130 seizures) | £761,908 (182 seizures) | £725,948 (199 seizures) |
| Value of recoverable property identified and reported to CRU | £2.4 million | £2.56 million | £535,000 |
Tayside
| Period 1 (1 Jan- 30 June 2010) | Period 2 (1 July- 31 Dec 2010) | Period 3 (1 Jan-30 April 2011) |
|---|
| Value of assets identified and reported to SOCD | £376,300 | £177,416 | £763,955 |
| Value (and number) of cash seizures over £1000 | £69,798 (25 seizures) | £172,508 (26 seizures) | £58,890 (21 seizures) |
| Value of recoverable property identified and reported to CRU | £607,000 | £92,000 | 0 |
3.8 These data do not show clear patterns in changes across the period of the analysis and highlight large variations in reporting periods, this can be seen in the difference between the number and value of cash seizures, where for example there were similar numbers of seizures in periods 1 and 2 in Tayside, but where the value in period 2 was over twice as high as period 1. Similar effects can be seen in Lothian and Borders police force area. Quantitative data on its own mask the real value of financial investigation work by over-playing or under-playing its true contribution to outcomes.
3.9 The outcome of 'proceeds of crime' work and how this is reflected in qualitative performance measures is clearly contingent on events, and opportunities for police to take further action on their work. These data do not necessarily correlate with the quantity or quality of police work supporting these outcomes, and this poses challenges for an analysis of the added value of these posts.
Other measures of impact
3.10 This review included information from the three forces on trends in some of the other benefits that financial investigators may have provided to them. These include the amount of financial intelligence that is currently being recorded, the amount of proactive work that is being done on money laundering enquiries identified through the suspicious activity report system and the amount of training and advertising of financial investigation support that financial investigators are providing to colleagues working at the front-end of policing. It also included the outputs that financial investigators have on non-financial crime outcomes.
3.11 Table 2 shows the trends in a number of these areas, including trends in the amount of financial intelligence collected, the number of SARs dealt with, the number of training sessions given, to show the impact of the financial investigators on education and awareness among front line officers, and, the number of non-financial investigations with financial investigators' input. These provide an indication of the amount of additional support the project has provided for increased financial focus in the 3 forces.
Table 2: Other measures of impact (source: Lothian and Borders, Strathclyde and Tayside Police)
Lothian and Borders
| Period 1 (1 Jan- 30 June 2010) | Period 2 (1 July- 31 Dec 2010) | Period 3 (1 Jan-30 April 2011) |
|---|
| Number of financial investigation enquiries dealt with | 170 | 260 | 271 |
| Number of SARs reviewed and actioned | 0 | 0 | 58 |
| Number of training inputs given [3] | 80 | 142 | 365 |
Strathclyde
| Period 1 (1 Jan- 30 June 2010) | Period 2 (1 July- 31 Dec 2010) | Period 3 (1 Jan-30 April 2011) |
|---|
| Number of financial investigation enquiries dealt with | 257 | 416 | 286 |
| Number of SARs reviewed and actioned | 169 | 122 | 174 |
| Number of training inputs given | 73 | 68 | 19 |
Tayside
| Period 1 (1 Jan- 30 June 2010) | Period 2 (1 July- 31 Dec 2010) | Period 3 (1 Jan-30 April 2011) |
|---|
| Number of financial investigation enquiries dealt with | 110 (approx) | 110 (approx) | 145 |
| Number of SARs reviewed and actioned | 37 | 160 | 275 |
| Number of training inputs given | 6 | 7 | 5 |
3.12 These data give an impression of some of the ways in which the reinvestment funding has enabled greater outputs for investigations to make greater use of financial intelligence. All forces have seen an increase in the number of investigation enquiries for proceeds of crime and other investigations. The increase in the number of suspicious activity reports also shows a new emphasis on proactive investigation, looking beyond police prioritisation towards information from external financial institutions.
Serious Organised Crime Division and Civil Recovery Unit
3.13 Representatives from the Serious Organised Crime Division (SOCD), and Civil Recovery Unit (CRU) participated in the research to provide their views on perceptions of the project and if they had felt any extra impact from the 3 forces as a result of the reinvestment.
3.14 One of the main points from these interviews echoed the view of police about the length of POCA investigations and the inherent difficulties in isolating the various elements which lead to the final results and financial recoveries. The SOCD/CRU said that there is a long delay between the time when a lot of the POCA work is done, and the resolution in the case resulting in assets being finally recovered. This can be a number of years and therefore any positive impact made by the extra investment in financial investigation would not be expected to be felt for a number of years.
3.15 Data from COPFS show however a growing trend in the number and amount of confiscation orders, civil recoveries and cash seizures which reinforce the perceptions of police that financial investigation and financial intelligence is playing an ever more central role within policing and having a corresponding impact on financial recoveries. [4] The amount recovered by the Civil Recovery Unit has increased each year since 2003-04, and was over £9m in 2009-10.
3.16 Data provided by the Civil Recovery Unit (shown in table 3) shows that there has been a year on year increase in the number of asset recovery referrals that they have received nationally in the last five years, from 44 referrals in 2005-06 financial year to 125 in 2010-11. This includes referrals from the territorial police forces, DWP, SCDEA and HMRC. These increases are also reflected to a smaller extent in the 3 forces which have received funding for financial investigation.
Table 3 - Number of asset recovery referrals received by Civil Recovery Unit 2005-2011 (source: Civil Recovery Unit)
| Year to 31 March | Lothian & Borders | Strathclyde | Tayside | Number of Referrals to CRU |
|---|
| 2005/06 | 9 | 22 | 1 | 44 |
| 2006/07 | 11 | 30 | - | 72 |
| 2007/08 | 11 | 31 | 1 | 73 |
| 2008/09 | 13 | 29 | 2 | 79 |
| 2009/10 | 6 | 37 | 1 | 106 |
| 2010/11 | 15 | 49 | 4 | 125 |
| Total | 65 | 198 | 9 | 499 |
3.17 These trends are also mirrored in the number of cash referrals received by the Civil Recovery Unit. These have increased each year since 2007-08 and grown by over 50%, from 443 in 2007-08 to 679 in 2010-11.
Table 4 - Number of cash referrals per Force (source: Civil Recovery Unit)
| 2007-08 | 2008-09 | 2009-10 | 2010-11 |
|---|
| Lothian and Borders | 54 | 71 | 75 | 71 |
| Strathclyde | 209 | 296 | 317 | 403 |
| Tayside | 46 | 59 | 55 | 63 |
| Nationally | 443 | 571 | 629 | 679 |
3.18 These statistics are not presented to show a connection between the reinvestment funding project, but to show the national trends in POCA referrals over the last few years and to give an indication of the change in outputs for the relevant forces. These figures will also provide a baseline for any further analysis of the development of financial investigation.
Other benefits
3.19 Interviewees, police officers, support staff and others, were asked about other benefits that may have resulted from the funding project that may not have been captured in the above sections.
3.20 One of the most noticeable changes mentioned in research interviews was the changing culture of police investigation; the gradual centre of gravity shifting towards financial information.
3.21 This is represented in Strathclyde and Lothian and Borders by the use of POCA champions, senior officers within divisions who supported financial aspects to criminal investigations. It is also shown in the recording of financial recoveries from stop and searches, alongside other information about weapons and knives recovered, and in the marketing and advertising campaigns, such as Lothian and Borders' 'made from crime' campaign, designed to highlight the new financial emphasis within police investigation.
3.22 Generally there was a sense that the landscape is changing quickly, reflected in a number of ways including the emphasis on more cash seizures and assets restrained, a different approach to force knowledge about financial investigation, the different pro-active approach towards SARs development.
3.23 Forces gave examples of where financial investigators had made an impact on non-POCA and financial crime investigations, mainly missing persons, murders and sex offending cases where offenders, victims and witnesses had been identified by previously unknown bank accounts and the geographical locations of financial transactions. Financial investigators give a specialised contribution to these enquiries, and these functions were much valued by research participants.