Whistleblowing - the Forgotten Control to Tackle Corporate Crime and Dirty Money

We are happy to host WhistleblowersUK's event, part of their call for evidence to present to the government.

Georgina Halford-Hall, CEO of WhistleblowersUK, says: "The government and law enforcement agencies have increasingly reported that the UK is a hotspot for laundering dirty money, reported as being 2nd in the world behind the US with fraud losses estimated to be at £2.3 billion. The government’s fraud strategy has placed disrupting fraud and serious organised crime as a top priority which aligns to the business strategies of the regulators including the Serious Fraud Office (SFO) and Financial Conduct Authority (FCA). It has increasingly been publicised as a root cause method to tackle the growing epidemic in the UK economy, even with suggestions that successful disclosures be rewarded by OFSI for sanctions matters.

Despite the emphasis on encouraging whistleblowers to step forward, the question remains: is the government, regulators and law enforcement fully appreciative of WB as a critical regulatory control to tackle the issue rather than mistakenly only considering this in the context of the employment relationship?"

During this event, we will take a deep dive around the topics of economic crime as well as fraud, more details can be found below.

Register here

Event date and location

Wednesday 3 July

30 Old Bailey, London, EC4M 7AU (map)

Event timings

12:30 – Registration

13:00 – Welcome and introduction, followed by sessions on:

  • Economic crime focused on non-financial misconduct, the FCA Enforcement Guidance and the latest proposal to introduce or increase Financial Rewards in the UK and globally.
  • Fraud session focused on the Governments’ Fraud Strategy, Covid Bounce Back Loans, implications of financial rewards for whistleblowing disclosure.

17:00 – Finish

Register here

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Detailed agenda

Introduction from keynote speaker, Lee Castleton

Economic crime

  • Non-Financial Misconduct – Given the government focus since July 2023 in the Treasury Select Committee’s “Sexism in the City Inquiry”:
    • Has the FCA adequately addressed the concerns posed through their actions such as assurances to WB and s165 data request to firms?
    • Is this enough for potential victims to feel safe speaking up allowing a comprehensive analysis of non financial misconduct in the market? (especially related to discrimination and sexual harassment)
    • Is there a better way to complete market analysis to understand the scale/extent of the issues?
  • The FCA Enforcement Guidance was updated in February 2024, it stated they intend to name regulated firms under investigation. One reason provided was to encourage WBs and victims to step forward with misconduct/corporate crime disclosures.
    • Is that assumption realistic?
    • Is the current FCA WB framework adequate and effective enough to deal with additional disclosures?
    • What would need to stay the same/change?
  • Following recent announcements and proposals to introduce or increase Financial Rewards in the UK and globally such as the latest statement by the SFO
    • Is this the way forward or a slippery slope?
    • If this is the right way to improve interception of economic crime should the FCA be jumping on this bandwagon?

Break

Fraud

  • The Government's Fraud Strategy in 2023 was noticeably silent on WB as a control to tackle the scale of UK fraud.
    • Was this a detrimental omission to counteract the scale of fraud?
    • Is there a disconnect between the Fraud Strategy and the failure to prevent fraud obligations set out at s199 of the Economic Crime and Corporate Transparency Act 2023?
  • Covid Bounce Back Loans:
    • Was WB the missing component to fraud management by HMRC?
    • 14,000 disclosures were made with many claiming no follow up resulting in £1.7 billion worth of fraudulent loans (confirmed in 2023 by the Department of Business and Trade). Was any of the fraud committed avoidable?
  • Given the financial reward for whistleblowing disclosures that result in a successful prosecution by some regulators/law enforcement agencies:
    • Should there be a mechanism with the UK WB reward framework to address fraudulent/vexatious reports for attempted financial gain?
    • Would this silence some critics who consider reward schemes distasteful/not ethical and provide balance?

About WhistleblowersUK

WhistleblowersUK is a not-for-profit organisation led by CEO Georgina Halford-Hall. It has been the secretariat to the APPG on Whistleblowing since it was formed in July 2018. We have been given assurance and are confident that we will continue in this role, subject to the rules of reinstatement, after the General Election alongside over 600 other APPGs. In this role, WhistleblowersUK will continue to provide an important link between industry professionals and the government through its ongoing call to evidence including events like this one. WhistleblowersUK is an advocate of reforms that will improve protections for whistleblowers across sectors and greatly assist businesses through the reduction of red tape and complex regulations. Our proposals are contained in the Bill below currently going through Parliament and we look forward to hearing your views and taking your questions. A link to the Whistleblowing Bill is detailed below:

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