The challenges faced by law enforcement in policing fraud and organised crime are widely known. Whilst organised crime groups (OCGs) have diversified and are able to buy-in the requisite skills and professional services needed to conduct successful operations, operational policing, conversely, suffers from constrained resources and the increasing complexity of investigating fraud that occurs across national, international and virtual borders. As one police fraud investigator summarised, ''we are chasing Formula One cars with tricycles''. This crude juxtaposition of the reach and capability of fraud OCGs on the one hand and the operational policing response on the other highlights the policing problem; yet, that is if we see it as a policing problem. It is increasingly recognised that policing organised fraud extends beyond the remit of ‘the police’. Fighting fraud with multi-agency and multi-sector partnerships is the championed response. Another response which has gained traction in successive government publications is the need to take a closer look at and pursue the facilitators of organised fraud.
Professional enablers (i.e. solicitors, accountants, financial advisers and estate agents) and money launderers are often wittingly or unwittingly involved in facilitating OCGs involved in fraud. Professionals – from an expansive range of professions – can open doors and provide services such as signing off transactions and moving client money; services which are not always knowingly criminal actions, but which can facilitate organised criminality. With constrained police resources and a reluctance of police investigators to go beyond the already stretched, parameters of the case, those positioned ‘upstream’ or higher up the chain, are often overlooked. Money launderers (professionals and not) are needed to launder the proceeds obtained from fraud and/or proceeds from other predicate crimes which are used to facilitate fraud. With a range of known ways in which money can be laundered from cash-based to trade-based, money laundering is an evolving threat. This has been compounded further with the emergence of crypto-currencies; the impact of which is not yet known.
Yet, despite the pivotal roles played by professional enablers and money launderes in the commission of organised fraud, little is known about their position in the OCG, how they are retained and how (if, at all) they are rewarded. Understanding the facilitators of organised fraud is the key to unlocking and developing a joined-up a policing and regulatory response. In order to disrupt OCGs involved in fraud, the traditional enforcement focus on 'following the money' needs to run parallel with the 'follow the facillitators'.