Economic Crime Strategy 2025 - final progress report, May 2025
- Introduction
- Our People
- Digital Capability
- Strategic Partnerships
- Casework Quality
- Public Confidence
- Forward Look
Introduction
Economic crime continues to pose a serious and evolving threat, and tackling it remains a priority for the CPS. Building upon the foundations established in our two-year progress report (2023), this final progress report marks the culmination of the CPS Economic Crime Strategy 2025. Together they highlight the progress we have made in tackling economic crime, supporting victims, and recovering criminal assets.
As we now look ahead to developing a new Serious Economic and Organised Crime (SEOC) strategy, we will take forward the insights and experience gained over the past four years. In doing so, we aim to strengthen our ability to respond to the changing nature of economic crime, ensuring we continue to deliver justice, build public confidence, and support wider efforts across the criminal justice system.
This report updates on the actions we set out in our two-year progress report. Highlights include:
- Since the launch of the CPS Economic Crime Strategy 2025, between April 2021 and December 2024, CPS has prosecuted 25,665 defendants where Fraud and Forgery was the principal offence category, leading to 21,717 convictions. We continue to maintain a high conviction rate in this offence category. In Financial Year (FY) 2023/24, the conviction rate was 85.3%, up from 83.9% in FY 2022/23. In the first three quarters of FY 2024/25, the conviction rate was 85.4%. The figures for the full FY 2024/25 will be available on the CPS website on 17th July 2025.
- We have strong performance on asset recovery. In the last five years (2019 to 2024) over £450 million has been recovered from CPS-obtained Confiscation Orders, depriving thousands of criminals of their ill-gotten gains. Of this amount, £88 million has been returned to victims of crime by way of compensation. Since 2023, the CPS has also helped recover over £1.2 billion through civil and criminal enforcement actions, comprising a £652 million settlement with HMRC following a conviction for fraud from a high-profile individual who breached the terms of the Contractual Disclosure Facility (COP9), and a £615 million resolution through the CPS’s first Deferred Prosecution Agreement (DPA) with a global company over historic bribery.
- We actively engaged with Part One of the Independent Review of Disclosure and Fraud Offences, led by Jonathan Fisher KC, to address the complexities of prosecuting economic crime, particularly the challenges faced by investigators and prosecutors in managing, reviewing and disclosing the vast volumes of digital material involved in these cases. We have influenced recommendations to modernise the disclosure regime, ensuring alignment with technological advancements while safeguarding fair trial rights.
- We provided operational insights and data to the Home Office to support the Fraud Strategy (2023) ambition to conduct research into the Lifecycle of a Fraud Case. This work has informed Part Two of the Independent Review led by Jonathan Fisher KC, which is currently underway. The CPS remains closely engaged.
- We engaged extensively with the Home Office to support the development of guidance for organisations for the new Failure to Prevent Fraud offence under the Economic Crime and Corporate Transparency Act, which was published in November 2024, paving the way for the offence to come into force on 1 September 2025.
- The CPS continued engagement with victims’ groups and the voluntary sector to advance our community engagement ambitions and ensure that our economic crime policies are informed by them.
Although progress has been made, economic crime continues to grow in scale and complexity, with criminal networks operating across multiple jurisdictions and rapidly exploiting technological advancements such as cryptoassets and artificial intelligence. Fraud remains the most common crime type in England and Wales, with the latest statistics showing an estimated 4.1 million incidents in the year ending December 2024 – now 43% of all estimated crime, a 33% rise on the previous year (Crime Survey of England and Wales). A significant proportion of frauds are cyber-enabled, serious, and organised, and many incidents go unreported.
Economic crimes such as fraud, money laundering, and corruption cost our society and economy billions of pounds each year. The impact of these crimes can be devastating, ranging from vulnerable people being exploited and left with unaffordable personal losses, to impacting the viability of businesses, all of which leads to significant losses to taxpayers. Tackling this requires a long-term, system-wide approach with commitment from all parts of the criminal justice system and the CPS will continue to play an important role alongside our operational partners.
Baljit Ubhey
Director of Strategy & Policy
Strategy and Policy Directorate
Hannah von Dadelszen
Chief Crown Prosecutor
Head of the Regional and Wales Division
SEOCID
Joanne Jakymec
Chief Crown Prosecutor
Head of the International London and Southeast Division
SEOCID
Adrian Foster
Chief Crown Prosecutor
Head of the CPS Proceeds of Crime Division
SEOCID
Our People
Strategic Aim: Our people will have the skills and tools they need to prosecute increasingly complex economic crime cases
The Failure to Prevent Fraud Offence and Identification Doctrine Reforms
We said we would:
Develop guidance for prosecutors on the new ‘Failure to Prevent Fraud’ offence and reform of the Identification Doctrine, in the Economic Crime and Corporate Transparency Act (ECCTA) 2023.
The CPS has supported the development of guidance for organisations (required under section 204 of ECCTA), which was published on 6 November 2024. This means that the new Failure to Prevent Fraud offence will come into force on 1 September 2025 following an implementation period to allow organisations to develop and implement their fraud prevention procedures. Whilst the new offence is expected to help drive better corporate behaviours and compliance, it should also help enhance public confidence in a criminal justice system, which holds to account both individuals and organisations who have played a part in the commissioning of certain economic crimes.
In light of this, we will be updating our corporate prosecution guidance in the first quarter of Financial Year (FY) 2025/26. It is vital that law enforcement and prosecutors understand the interaction between the new failure to prevent fraud offence (section 199, ECCTA) and identification doctrine reform (section 196, ECCTA). Organisations that do not meet the threshold for the failure to prevent fraud offence can still be investigated and prosecuted for substantive fraud offences under the reformed identification doctrine in ECCTA.
The CPS has supported the proposals being considered under the Crime and Policing Bill (introduced to Parliament in February 2025) to expand the reform of the identification doctrine first introduced in ECCTA, to all crime.
Current ‘failure to prevent’ offences incentivise corporate self-reporting, in particular due to the interaction these offences have with the Deferred Prosecution Agreements (DPAs) regime. The new Failure to Prevent Fraud offence and the statutory reform of the Identification Doctrine may lead to a wider range of self-reporting by corporate bodies. We are working with law enforcement to ensure that the system has the capabilities and a clear approach to dealing with corporate self-reports. We are keen to ensure that further consideration is given to whether a central reporting channel is needed in order to provide clarity for companies who wish to make a self-report as well as in supporting law enforcement to allocate and progress such cases efficiently.
Updated Money Laundering Offences Guidance
We said we would:
Update Legal Guidance for Money Laundering to provide clarity for prosecutors when considering cases involving Money Mules.
The CPS supported the action in the Fraud Strategy for a new cross-sector Money Mules Action Plan (MMAP) to disrupt Money Mule activity and protect the public, which was published in March 2024.
In April 2024, CPS published updated guidance for prosecutors for money laundering offences. This recognises money laundering-linked financial exploitation, culpability of money mules and public interest considerations. The guidance also supported MMAP objectives and law enforcement action which has focused on mule herders and the use of cease-and-desist notices for lower-level offending.
Case Example:
In April 2024, two individuals were sentenced for their role in transporting £104 million of criminal cash from the UK to an overseas destination. One defendant received four years' imprisonment, while the other was sentenced to two years, suspended for two years. The first individual acted as both an organiser and courier, while the second was solely responsible for transporting cash. An National Crime Agency (NCA) investigation uncovered that they smuggled millions of pounds in suitcases on eight flights in 2020, as part of a wider 85-trip operation coordinated by the head of an organised crime group, who was previously sentenced to nine years' imprisonment.
The above case example highlights the significance of criminality involving money mules, illustrating how money laundering facilitates organised crime. The case also raises awareness of ‘money muling’, where individuals unknowingly transfer illicit funds.
Enhanced capabilities for crypto-related crimes
We said we would:
Work with the National Crime Agency and other operational partners, as set out in the Government’s Economic Crime Plan 2, to enhance capabilities to investigate and prosecute the use of cryptoassets to launder illicit finance, by considering joint training opportunities.
Fraudsters exploit evolving technologies, services and products such as cryptoassets, which provide new opportunities for criminals to cloak their activities. Therefore, it is vital that investigators and prosecutors have the capability and agility to keep pace with the changing nature of crime, to tackle criminals operating across multiple jurisdictions and exploiting new technology and services, such as cryptocurrencies and AI.
The CPS Serious Economic, Organised Crime and International Directorate (SEOCID) ensures that we have the resilience, expertise and flexibility in our staff and our organisational structure to best respond to new and changing areas of complex crime, which includes illicit use of cryptocurrencies. The CPS continues to work alongside government and law enforcement to provide a multi-agency response to combat this criminal activity.
The CPS Proceeds of Crime Division (POCD) has appointed two operational leads on cryptoassets, focusing on asset recovery issues. They engage with the National Economic Crime Centre (NECC) at the National Crime Agency (NCA), Home Office and others to identify and address emerging issues both in formal working groups and on an ad hoc basis. For example, as part of CPS POCD’s efforts to normalize freezing a crypto account akin to freezing a bank account, a database has been developed containing contact information for UK FCA-regulated crypto exchange service providers, as well as those outside the jurisdiction.
The CPS has prosecuted several cases in recent years which involved the illicit use of cryptocurrencies, including the conviction of an individual in March 2024 for laundering proceeds linked to a £2 billion Bitcoin seizure, the largest in UK history.
To strengthen and mainstream cryptoassets capabilities, the CPS agreed on a new MoU with the National Crime Agency in March 2025, for the provision of a foundation course on cryptoassets from a law enforcement perspective. This training will be made available to all economic crime prosecutors.
Case Example: UK’s Largest Bitcoin Seizure
A landmark investigation led by the Metropolitan Police and the CPS resulted in the UK’s largest Bitcoin seizure, worth over £2 billion, and the conviction of an individual for money laundering. The defendant, who had previously lived modestly, was found to have laundered cryptocurrency linked to a significant international fraud. She converted Bitcoin into cash and luxury assets, including jewellery, multi-million-pound properties, and private school fees. The investigation uncovered attempts to bypass anti-money laundering regulations, which ultimately helped expose the criminal activities.
This case highlights the increasing use of cryptocurrencies by organised criminals to disguise and transfer illicit funds. By freezing the assets and pursuing both criminal and civil recovery proceedings, authorities demonstrated their commitment to disrupting financial crime and recovering criminal proceeds. The investigation showcases the determination of law enforcement agencies to adapt to the challenges posed by cryptocurrency-related crime and ensure that offenders face justice.
Digital Capability
Strategic Aim: Digital tools are utilised for case management, preparation and presentation in economic crime cases
Enhanced digital case file processes
We said we would:
Conduct a digital discovery project into ‘case materials’, looking at how we receive case files from policing, to ensure that our technology supports the receipt of complex case information, supports data quality improvements, and enables two-way communication throughout each stage of a case.
The CPS has continued to work with the Police Digital Service and force suppliers on the Digital Case File, which will replace the current document-based case file process with a fully digital exchange of case file information between police and CPS. This will streamline case creation by reducing duplication and ensuring information is right the first time, in line with the Leveson principle. Officers will be able to compile case files more efficiently using existing police technology, reducing administrative burden and improving accuracy.
The Digital Case File brings several key benefits, including automation, where fields that are currently duplicated across multiple forms will be auto populated, and enhanced visibility through a Shared Action Plan, allowing both agencies to track progress without unnecessary follow-ups. It also enables two-way engagement on Disclosure schedules, eliminating the need for manual updates by ensuring both agencies always have access to the latest version.
The CPS is undergoing a significant digital transformation over the coming years, and this action is part of CPS’s wider multi-year work and commitment to modernising our processes and enhancing our digital capabilities to develop a casework system that helps us to work with investigators and ensure public confidence in the Criminal Justice System. One of our flagship digital initiatives is the Future Casework Tools Portfolio which was established at the end of 2021 to create a single picture of all the projects and initiatives which will improve our casework tools. This comprehensive portfolio of programmes and projects aims to take a holistic approach to reviewing, improving, updating, and developing our casework tools. This includes key initiatives such as the Replacing CMS Programme, Witness Expenses, and Digital Jury Bundles, among others.
Improved large-case management technology
We said we would:
Conduct a digital discovery project into ‘off-system’ cases, i.e., those too large to be held on the existing CPS Case Management System, to ensure that we deliver technology to support effective management of such cases.
The CPS is undertaking a multi-year programme to replace its current Case Management System (CMS). A key priority has been to accommodate cases with large volumes of material that cannot be held within the CMS, such as some complex economic crime cases. To address this, a Discovery phase was initiated in Q2 24/25 to examine the requirements for supporting these "Off CMS system cases." This phase involved user research and an assessment of the supporting technology to identify pain points and potential solutions.
The Discovery work identified challenges such as manual processes, file management issues, and inefficiencies from using multiple systems, while also highlighting opportunities for automation and improved case management. Initial testing demonstrated early efficiency gains, leading to approval for further development focused on case setup automation in the Central Casework Divisions. Ongoing stakeholder engagement has ensured alignment with requirements, with strong support for the next steps to deliver further efficiency benefits.
Case Example:
In May 2024, we successfully prosecuted members of Britain’s biggest benefit fraud gang. This was an industrial-scale benefit fraud operation, stealing over £50 million. The investigation team had a vast amount of material to analyse from 945 electronic devices. Our prosecutors worked with DWP to create a bespoke digital strategy to manage this material, this included early engagement with the defence seeking their input on which devices should be searched and how, providing detailed disclosure management documents to the defence and providing regular updates, pro-actively providing copies of the primary devices to the defence - not waiting for defence disclosure requests. The result was that the defence did not challenge our digital evidence, and all the gang members pleaded guilty.
Strategic Partnerships
Strategic Aim: CPS operational insights are used by partners to improve the UK’s response to economic crime
Anti-Corruption Strategy
We said we will:
Share our operational insights with the Government to support an ambitious new Anti-Corruption Strategy.
The CPS has continued to engage with the Home Office on the development of a new Anti-Corruption Strategy, both before and after the general elections in July 2024, and shared our operational insights to shape the government’s strategic priorities. As with wider Economic Crime, early engagement between investigators and prosecutors in corruption cases is important in developing strong case strategies around victims and disclosure. We believe a new Strategy provides a real opportunity to build on the progress under the first UK Anti-Corruption Strategy.
Independent Review of Disclosure
We said we will:
Work with the Independent Review to explore how the disclosure process could be improved to make it more manageable in the digital age. This includes the CPS proactively considering and feeding in potential reform proposals.
Economic crime is amongst the most complex work that we undertake as prosecutors. Most notable is the volume of digital material that any one case might generate. The CPS has engaged extensively with the Independent Review on Disclosure, led by Jonathan fisher KC, to share our insights and influence meaningful recommendations which could help address the challenges, while preserving the fundamental right to a fair trial and continuing to recognise the importance of early engagement between investigator and prosecutor, as well as the defence. The CPS will also support the government’s response and work closely with policing and other partners in taking forward the relevant recommendations.
More specifically, we have asked the Independent Review to consider updating the Code of Practice to bring it in line with modern practice, which includes recognising the role technology plays in facilitating this proportionate approach. There is a need to reconcile our obligations under the CPIA and Code of Practice with the pragmatic approach taken in practice – and endorsed by the courts – in relation to large volume of digital material. That pragmatic approach helps us to take a proportionate approach in relation to the identification of relevant digital material, and thereby in fulfilling our disclosure obligations. It is guided by the issues in the case and early engagement with the defence can be crucial in helping to identify reasonable lines of enquiry, as well as narrowing down the case issues.
We have also been engaging with the review to explore how we can bring the criminal justice system together, including the defence and judiciary, to realise the opportunities for using technology, including AI to transform the management of disclosure and evidential material across the Criminal Justice System. To this end, in April 2024, together with the NPCC and NCA we put forward a joint proposal to the Independent Review. Technology, including AI, has the potential to assist in fulfilling disclosure obligations but we recognise that, to be effective, this must have the full confidence of the judiciary and wider Criminal Justice System. That said, there are many skills that are uniquely human and always will be, and therefore, our legal decisions will always be made by expert prosecutors. Technology has a role to play in facilitating those decisions, but not in making them.
Collaborating on AI economic crime threats.
We said we will:
Work with the NECC and other partners to consider the implications of new technology, including Artificial Intelligence, for the way in which economic crimes may be committed in the future and what we need to do to combat the threat effectively.
CPS continues to work closely with the NECC and Criminal Justice System partners, such as HO and the Ministry of Justice, to understand the evolving risks posed by new technologies, including AI, in the commission of economic crimes. We also disseminate NAC threat reports to our prosecutors to help raise awareness of specific areas such as online fraud and ensure that the CPS remains informed on how AI and other technologies are being exploited for economic crime. This collaboration also supports wider efforts to enhance internal capabilities and identify legal and policy considerations necessary to combat AI-enabled economic crime effectively.
CPS has also engaged with the Home Office and legal experts on the legislative implications of wider AI-enabled offending, including Economic Crime. In 2024, the CPS engaged with a HO-led review by Professor David Ormerod KC and Dr Mark De Souza which found that while the current legal framework is largely robust, potential gaps exist—particularly regarding the law of conspiracy, where an individual conspiring with an AI (mistakenly believing it to be human) falls outside the existing statutory definition. CPS will continue to engage with the NPCC AI Board and government officials to monitor the evolving risks of generative AI and assess whether further legal or policy interventions are required.
Interactions between cybercrime and fraud
We said we will:
Work with the NECC to consider the interactions between Cybercrime and Fraud.
We continue to engage with the NECC to understand the overlaps and consider priorities for a new Government Fraud Strategy, which is likely to have a focus on this interaction. Around 80% of fraud is cyber-enabled and therefore it is vital that we understand how we can better tackle this manifestation of the threat. To that end, we have invited relevant leads from cyber and fraud policy to our Cyber Prosecutors Network to explore this further. We recognise that this is just the start of a broader conversation which we will take forward in our Serious Economic and Organised Crime strategy.
Enhanced efficiencies for economic crime cases
We said we will:
Support the Government commitment in the Fraud Strategy to consult on solutions to increase the volume and speed of cases, by providing operational insights to help shape options for enhancing the speed of economic crime cases through the court system.
The CPS shared our operational insights and data with the Home Office to help finalise the first part of this action under the previous government’s Fraud Strategy. Given the scale of the threat, and investment in law enforcement in recent years, it is vital that the criminal justice system as a whole has the capacity to progress cases, and that includes the courts. The CPS continues to encourage and support any plans or pilots for dedicated economic crime courts, with a focus on early guilty pleas and use of virtual case management hearings at earliest stage. The CPS believe that case management could also be enhanced by ensuring that complex economic crime cases go before specialist judges who have the required expertise to effectively deal with such cases. We have also taken the opportunity to share these views with the Independent Review on Criminal Courts, chaired by Sir Brian Leveson, this year.
Advancing confiscation recommendations with partners.
We said we will:
Work with government and operational partners in considering and taking forward appropriate recommendations from the Law Commission’s Review of Confiscation provisions of the Proceeds of Crime Act.
The CPS Proceeds of Crime Division has worked closely with the Home Office and others to develop provisions for legislation. A particular issue of close working is development of a scheme for better interaction of compensation and Confiscation Orders that are reconsidered. We influenced the Home Office to change their policy to better support victims. The provision is included in the Crime and Policing Bill which was introduced in Parliament in February 2025. The CPS has also been providing our expertise and experience to the Criminal Procedure Rules Committee and to the City of London Police in relation to recommendations that do not require amendments of primary legislation.
National Fraud Squad
We said we will:
Work with the NECC and other operational partners to provide our operational insights into the process of establishing the National Fraud Squad and planning for the downstream impact of the additional investigative resource on the CPS.
The National Fraud Squad (NFS) brings together the expanded investigative capacity and capabilities of the NCA’s Complex Financial Crime Team, the COLP economic crime teams, and the Proactive Economic Crime Teams (PECTs) in the Regional Organised Crime Units (ROCUs). The NFS forms the foundation for a broader policing and law enforcement network response, effectively coordinating the efforts of various agencies involved in countering fraud. This network approach is expected to foster a more cohesive local, national, regional, and international response to fraud, enhancing both proactive and reactive measures.
The CPS has engaged with law enforcement on the development of the NFS, including through attendance at the NECC Fraud Strategic Governance Group and the Home Office chaired Fraud Reform Programme Board. While it will take time for the additional investigative capacity to translate into criminal justice outcomes and reverse the current trend, the CPS will look to factor this into our planning.
Engagement with the Asset Recovery Support Unit
We said we will:
Engage with the new Asset Recovery Support Unit, as set out in the Economic Crime Plan2, which looks to bring together subject matter experts to advise on asset recovery to ensure that it is considered early on in economic crime cases.
The CPS has established a robust and collaborative relationship with the City of London Police (CoLP), particularly in supporting the Asset Recovery Support Unit (ARSU), which is a specialised division within CoLP dedicated to the recovery of assets obtained through criminal activities. The CPS’ relationship with CoLP is characterized by close working and proactive problem-solving, enhancing the effectiveness of asset recovery efforts.
One of the key areas of collaboration involves the CPS utilising its powers to obtain restraint orders. These orders are crucial in preventing the dissipation of assets suspected to be proceeds of crime. By securing these assets, the CPS ensures they are preserved for potential confiscation following a successful prosecution. This not only disrupts criminal enterprises but also serves as a strong deterrent against future criminal activities. This proactive and collaborative approach significantly bolsters the UK's ability to tackle serious and organized crime, ensuring that justice is served both domestically and internationally.
In addition to this, the CPS has played a vital role in the UK Asset Management Strategy by providing expertise and prosecutorial support to manage and recover assets more efficiently. Furthermore, CPS has developed a collaborative relationship with the UK Central Authority (UKCA) in the Home Office to handle international requests involving fraud victims' money in UK accounts. By working together, the CPS and UKCA ensure that the UK can effectively cooperate with other countries to combat transnational crime, providing justice for victims and maintaining the integrity of the financial system.
Public Accountability: Evidence to the Home Affairs Select Committee
We said we will:
Provide evidence to the Home Affairs Select Committee Fraud Inquiry, launched in September 2023.
In February 2024, Andrew Penhale, then CCP SEOCID, Regional and Wales Division, and national lead for fraud, appeared before the House of Commons Select Committee on Fraud to provide oral evidence. He highlighted a number of specific challenges which should continue to be addressed through a ‘whole system approach’ to tackle the scale and changing nature of economic crime. This built on the areas we set out in our written evidence to the committee in October 2023, which included the need to ensure that:
- the criminal justice system, including the courts has the capacity to deliver justice; and
- there is a clear focus on supporting victims of economic crime to get the redress they seek but also to raise awareness of the economic crime threat to help prevent people becoming victims; and
- investigators and prosecutors have the capability and agility to keep pace with the changing nature of crime.
Joint International Crime Centre
We said we will:
Support the development of the Joint International Crime Centre, which enhances the UK’s capabilities around international law enforcement cooperation and coordination.
The CPS has supported the Joint International Crime Centre (JICC) by drafting essential guidance for law enforcement. This guidance helps officers make international requests for evidence in civil forfeiture cases and ensures the proper service of judicial processes. This is enabling law enforcement to effectively gather and utilize evidence from foreign jurisdictions, enhancing the success of civil forfeiture proceedings.
Additionally, the CPS is collaborating with the Home Office and other stakeholders to promote the creation of an asset recovery International Intelligence Exchange Hub. This initiative aims to improve international cooperation and coordination in asset recovery, strengthening the global fight against financial crimes.
Tackling Public Sector Fraud
Tackling public sector fraud is a priority for the government and the CPS has a longstanding partnership with public sector investigators, such as HMRC and DWP. We continue to promote early engagement between investigators and prosecutors, which is key to effective case building and successful prosecution outcomes. It is particularly encouraged in serious, sensitive, or complex cases.
In 2024, the CPS engaged with HMT and HMRC in relation to the government’s ambition to close the tax gap through the “use of prosecutions to promote tax compliance and ensure the tax that funds the UK’s vital public services is collected”. We expect an increase in number of cases coming to the CPS for prosecutions in the coming years as a result. The CPS will look to collaborate where we can and continue to highlight the importance of early engagement, particularly for complex cases.
We also engaged with the Public Sector Fraud Authority (PSFA) who are in the process of seeking legislative changes though the Public Authorities (Fraud, Error and Recovery) Bill, allowing them to conduct criminal investigations and assign cases to the CPS.
Case Example
The CPS continues to bring fraudsters to justice, including those who have exploited the Covid-19 pandemic for their own gain. In September 2024, an entrepreneur was sentenced to 18 months in prison for fraudulently securing a £50,000 Bounce Back Loan, which he misused for personal expenses and legal costs.
Casework Quality
Strategic Aim: An innovative approach will ensure our casework delivers improved justice outcomes in a timely manner
Overall Performance
Since the launch of the CPS Economic Crime Strategy 2025, between April 2021 and December 2024, CPS has prosecuted 25,665 defendants in the Fraud & Forgery Principal Offence Category, leading to 21,717 convictions.
The CPS has maintained high rates of charges and convictions where Fraud and Forgery was the principal offence. In FY 2023/24, the conviction rate was 85.3%, up from 83.9% in FY 2022/23. In FY 2023/24, the CPS charged 76.3% of all Fraud and Forgery category cases that were referred to it by law enforcement, which is slightly lower than our overall charge rate (the CPS charged 79.9% of all cases in 2023/24). In the first 3 quarters of FY 2024/25, the conviction rate was 85.4% and the charge rate was 75.3%. Figures for the full FY 2024/25 will be available on the CPS website on 17 July 2025.
The CPS also have strong performance on asset recovery. In the last five years (2019 to 2024) over £450 million has been recovered from CPS-obtained Confiscation Orders, depriving thousands of criminals of their ill-gotten gains. Of this amount, £88m has been returned to victims of crime by way of compensation. These figures will be updated in September, following release of the Home Office’s annual Asset Recovery Statistical Bulletin.
Case Example:
The CPS and NCA worked in close partnership from the outset of an intelligence-led investigation into an Organised Crime Group trafficking Class A drugs into the UK. This collaboration ensured swift legal oversight, enabling the deployment of covert tactics across Europe. The CPS played a pivotal role, drafting letters of request and maintaining continuous liaison with international counterparts, allowing operational activity to proceed seamlessly and at critical moments. This strong relationship helped shape the fraud investigation, ensuring resources were focused on CPIA-compliant evidence gathering. The result was an overwhelming prosecution case, leading to early guilty pleas and convictions for £3 million in fraud offences. The close working relationship between the CPS and the NCA also led to strong working relationships with the international liaison officers, allowing for efficient intelligence gathering and prompt investigative actions. Considerable disruption was also caused to other OCGs committing similar offences at the time, with the stakeholder reporting a noticeable decline in the number of other similar offences being reported at that time.
Learning from case debriefs with partners.
We said we will:
Conduct case debriefs, alongside law enforcement partners, in all relevant cases, to identify trends and learning which can be fed into the SEOCID Casework Quality Board.
SEOCID has continued to conduct case debriefs with investigative stakeholders, such as NCA, HMRC, CoLP and Met Police, as part of its business as usual. These debriefs are instrumental in identifying both good practice and key lessons for future casework. The findings inform the SEOCID Casework Quality Board, helping to strengthen prosecution processes and ensure continuous improvement. Some of the key themes from the debriefs include, early engagement and collaboration, disclosure challenges, use of digital and analytical evidence, international cooperation, timeliness of charging decisions and resourcing and expertise.
Case Example: Early Engagement
Early and effective engagement between investigators and the CPS has been a recurring theme across several debriefs. In cases where prosecutors were involved from an early stage, investigative efforts were more focused, and disclosure strategies were better defined. In one case, early engagement between the CPS and NCA was instrumental in shaping the direction of the investigation and ensuring a strong evidential foundation. A CPS lawyer was appointed at the outset, allowing for clear case parameters to be set and ensuring that investigative efforts remained focused on key lines of enquiry. Regular case conferences and early input from counsel further strengthened the case, helping to refine the disclosure strategy and anticipate potential defence challenges. The structured approach to file submission and disclosure, alongside consistent collaboration between the prosecutor, investigators, and counsel, contributed to a well-managed trial process. As a result, the case proceeded smoothly to conviction, with the court recognising the thorough preparation and clarity of the prosecution’s case.
Case Example: Digital and Analytical Evidence
In another case, the CPS team benefited significantly from the early involvement of a dedicated analyst, who worked alongside the NCA, His Majesty's Revenue and Customs, Regional Organised Crime Units and counsel to compile a comprehensive Sequence of Events (SOE) document. Given the complexity of the digital evidence—including encrypted communications, financial transactions, and surveillance data—the analyst played a crucial role in structuring the material in a clear and accessible format. This was particularly valuable in court, where the SOE helped the jury understand the chronology of key events and the links between defendants. The prosecution also made effective use of digital forensic tools to overlay images from encrypted messaging platforms with forensic photographs, strengthening the attribution of devices to suspects. The clarity of the analytical evidence, combined with the expert input of counsel, contributed to a well-presented case that resulted in convictions, reinforcing the importance of integrating digital and analytical expertise into complex prosecutions.
Moving forward, insights from case debriefs will continue to inform best practice guidance and lessons learnt to enhance the quality and effectiveness of CPS casework. The themes emerging from these debriefs have also informed our inputs into the Independent Review of Disclosure and Fraud Offences.
Deferred Prosecution Agreements
We said we will:
Work with the SFO to consider revisions to the joint CPS-SFO Deferred Prosecution Agreements, Code of Practice, with a view to applying insights from casework.
Following the introduction of the Economic Crime and Corporate Transparency Act 2023, CPS and SFO had jointly considered revisions to the DPA Code of Practice. However, following an initial review of the Code of Practice, the CPS and SFO collectively agreed not to pursue the revisions which were contemplated in December 2023’s Two-Year Progress Report for this Strategy. The decision was based on a variety of factors, including the high time and resources requirements against the limited impact of potential amendments. Both CPS and SFO agreed to continue working within the current framework and to learn from any lessons and future DPAs, with a plan to revisit Code of Practice in due course when there might be stronger grounds for revisions.
Case Example: CPS’s First DPA
In December 2023, the CPS entered into its first Deferred Prosecution Agreement (DPA) with Entain plc, a global online sports betting and gaming business, for £615m. The DPA with Entain was approved by Dame Victoria Sharp DBE at the Royal Courts of Justice.
The conduct which was the subject of this DPA related to the alleged failure by GVC (Entain's predecessor) to prevent bribery contrary to Section 7 of the Bribery Act 2010 between July 2011 and December 2017. The alleged bribery offences occurred primarily in Turkey. GVC disposed of its Turkish business in December 2017.
As a result of the DPA Entain plc has agreed to pay a financial penalty plus disgorgement of profits totalling £585 million, to make a charitable donation of £20 million and to pay a contribution of £10 million to the CPS and HMRC costs.
Updating MOUs with existing investigative stakeholders
We said we will:
Update and agree MOUs with all existing investigative stakeholders to ensure clear casework responsibilities and processes
In 2024, the CPS SEOCID updated its Memoranda of Understanding (MOUs) with the City of London Police (the national lead force for fraud) and the National Crime Agency who are both amongst CPS’ key investigative stakeholders. These updates aim to reflect evolving operational practices and advancements in criminal investigations and prosecutions. The MOUs clarify roles, responsibilities, and expectations, ensuring effective collaboration in tackling complex and high-profile cases. A refreshed MOU with HMRC is also expected to be finalised 2025.
Joint CPS-Policing Disclosure Conference
In January 2025 we held a joint CPS and Policing Disclosure Conference. The conference was fantastic opportunity to bring together practitioners and leaders to share insights, challenges, and best practice on this critical subject. Collaboration between the CPS and policing – at every level – is key to successfully navigating the challenges around disclosure. From our high-volume magistrates’ court cases to the most complex organised crime investigation, the way we work with our colleagues across the system is essential to delivering justice.
Public Confidence
Strategic Aim: Victims and witnesses are at the heart of every case, and we communicate effectively about our role in tackling economic crime
Victims and Witness Guidance
We said we will
Refresh the Economic Crime Victims and Witness Guidance, following the creation of SEOCID as well as the work that is being done to implement the CPS Victim Transformation Programme.
Delivering an improved service to victims requires join-up and co-ordination across the justice system. The CPS is working with its criminal justice partners to explore means of improving information-sharing between agencies. We are also providing our operational insight and legal expertise to support the Ministry of Justice in implementing the Victims and Prisoners Act 2024, updating the Victims’ Code and influencing the development of the Victims, Courts and Public Protection Bill. The Economic Crime Victims and Witnesses guidance will be refreshed to reflect the above changes in due course as part of CPS’s forthcoming SEOC strategy.
The CPS is in the process of engaging with partners to develop a support pack for fraud victims to provide clearer guidance on options for recovering lost funds. This work has been prompted by a large-scale investment fraud case involving 350 victims, where inconsistencies in bank refund decisions have highlighted the need for a more structured approach. The initiative seeks to enhance victim support and improve financial recovery outcomes while cases progress through the justice system.
The CPS is also working with HMCTS in cases where a Compensation Order has been issued to construct a system to support those victims with an interest in cases where confiscation receipts will be directed to them.
As part of a wider programme of work to improve its service to victims of crime, the CPS is piloting direct communication of its charging decisions with victims (rather than relying on the police to do this), giving victims the opportunity to ask any questions and giving the CPS the opportunity to explain what happens next.
Community Engagement and Accountability
We said we will:
Hold another Community Accountability Forum meeting to ensure that our economic crime policies are developed and informed by community engagement, including victims’ groups and the voluntary sector.
The plans to hold another formal Community Accountability Forum meeting were deferred and will be considered as part of the forthcoming SEOC strategy. Nevertheless, CPS has continued engagement with victims’ groups and the third sector to advance our community engagement ambitions, ensuring that our economic crime policies are informed by them. To date since January 2023, SEOCID have been involved in over 100 meetings with our strategic partners, external stakeholders and members of the general public.
In May 2023, our Inclusion and Community Engagement Manager (ICEM) updated the SEOCID Community Engagement Strategy, led by feedback from our community stakeholders which focused on elderly and vulnerable victims of economic crime. There was also an intentional shift to move the role of the CPS community engagement efforts from the saturated ‘prevention’ space to becoming an educator in the experience of going through the criminal justice system as a victim or witness.
In June 2024, one of our SEOCID Chief Crown Prosecutors, Joanne Jakymec, was a guest speaker at the London Access to Justice Group Board. This Board focuses on victims of crime, especially fraud victims with learning disabilities, and was attended by representatives from voluntary organisations, adult social care, victim support, police and the probation service. The CPS recognised that adults with disabilities of any type were more likely to be a victim of fraud than those without a disability. People with a learning disability need more time to learn and process information, and they may need extra support to develop skills, complete tasks and interact with others. In addition, we are ensuring our staff are well equipped to deliver equal opportunities for justice for people with learning disabilities through ongoing training, victim and witness feedback and use of special measures.
Case Study: Age UK
In October 2024, as part of our ongoing commitment to reaching society’s elderly and most vulnerable, we continue to strengthen our relationship with Age UK. As well providing regional managers with case studies of successful fraud convictions to help build public confidence and inviting Age UK to talk to our lawyers about their work in fraud prevention, we also created a video which described a firsthand account from one of our paralegals of a successful fraud case involving several elderly victims. This video was played at an Age UK fraud prevention roadshow and received positive feedback. Thanks to this experience we are now looking into creating more videos of different cases and roles within the CPS to highlight the work we do.
Case Study: NSPCC
In May 2024, our ICEM recognised vulnerable young adults were under-equipped with knowledge about experiencing the criminal justice system and collaborated with NSPCC to provide them with important and understandable content for their website, this included the role of the CPS, ten steps to how a criminal case works and understanding special measures. The aim of this work is to reach a wider audience by collaborating with a trusted and recognised third sector organisation.
More widely, in 2024 CPS expanded its engagement with victims’ groups, members of the HO-Chaired Victims and Witnesses Working Group, Money Mules Action Group and third sector organisations such as The Children’s Society and Love Said (a charity supporting victims of romance fraud). This helped better understand victim experiences of the criminal justice system and how fraudsters exploit vulnerable people financially. Feedback from such engagement informed our updates to prosecution guidance on money laundering offences, addressing the issue of money mules.
Communications Campaigns
We said we will:
Continue to work with the NECC and Home Office, to support a strategic, joined-up approach to public communications, which includes coordinating with our partners in relation to national communication campaigns.
CPS continues to work closely with the NECC and the Home Office to ensure a strategic, joined-up approach to public communications on economic crime. Through proactive communications output, CPS has worked to increase public understanding of its unique role in tackling fraud and economic crime, reinforcing public confidence in prosecutions. This has included highlighting successful prosecutions for money laundering, high-value fraud, cyber-enabled fraud, and public sector fraud and corruption, and efforts to recover criminal assets in our external communication. CPS has also supported wider national campaigns, such as Stop Think Fraud, to raise awareness and prevent economic crime at source.
Ongoing collaboration with the NECC and Home Office ensures that public messaging remains aligned, coordinated, and impactful, reinforcing CPS’s commitment to tackling economic crime and protecting the public.
Forward Look
The CPS Economic Crime Strategy 2025 provided a high-level vision of where we wanted to be by 2025, and we have made significant strides in tackling economic crime over the past four years, strengthening prosecution outcomes, improving digital capabilities, and enhancing our engagement with victims and stakeholders.
However, as economic crime continues to evolve — particularly with the increasing use of technology to facilitate fraud and money laundering — we recognise that our response must continue to adapt. The scale and complexity of economic crime demand a system-wide, long-term approach, and the CPS remains committed to playing a central role in driving this forward.
Aligned with the forthcoming CPS 2030 Strategy, the SEOC strategy, will build on the successes of our Economic Crime Strategy 2025 and ensure that we are well-equipped to meet emerging challenges, such as AI-enabled offending, crypto-related financial crime, and the growing international dimension of fraud and corruption.
Exploring the use of Artificial Intelligence
- Since 2021, when we published the Economic Crime Strategy 2025 - which included exploring the use of AI as an outcome - technology and tools have been developing at pace. That is why we are keen to ensure that we consider how we make the most of the potential opportunities that AI presents. In September 2024, as part of CPS’s wider work, the CPS engaged Kainos for a project to explore AI opportunities and assess its readiness for adoption. This initiative aimed to align AI implementation with CPS’s strategic priorities, including improving casework efficiency, reducing delays, and increasing public trust. The project included an AI Maturity Assessment, which evaluated CPS’s capabilities and identified areas for development. As a result, CPS has established a roadmap for AI adoption, focusing on enhancing prosecution processes, ensuring responsible AI governance, and building internal expertise.
- CPS’s AI ambition is structured around four key priorities: enabling AI-driven prosecutions, embedding responsible AI, developing AI skills and capability, and establishing a robust AI infrastructure. To ensure ethical and transparent AI use, CPS is developing a governance framework and ethical guidelines that will guide deployment. With a phased, incremental approach, AI adoption will begin with targeted use cases before scaling across operations. The goal is to integrate AI to enhance efficiency, fairness, and public confidence in prosecutions, making AI a key enabler of justice while maintaining legal integrity and accountability.
As we look ahead, collaboration will remain at the heart of our approach. We will continue to work closely with our operational partners to ensure effective case-building, to influence policy and legislative developments, and to advocate for a justice system that is equipped to deal with the complexities of economic crime. Through continued investments in our people, digital capabilities and strategic partnerships, we will strengthen our ability to bring criminals to justice, support victims, and recover criminal assets, in line with the Code for Crown Prosecutors.