In brief
- The release of the government's new fraud strategy demonstrates its commitment to tackling fraud, with a promise to invest £250 million over the next 3 years;
- The strategy recognises the importance of global collaboration – across countries, industries and law enforcement agencies;
- Whilst much in the fraud strategy is to be commended, a greater focus on effective mechanisms for victim reimbursement is needed to ensure that where prevention measures have failed, a cure is still possible.
The government's fraud strategy 2026-2029
The government published its new fraud strategy on 9 March, focusing on 3 key strands – disrupt, safeguard and respond. Under the 'disrupt' strand, a new Online Crime Centre will be launched in April, bringing together specialists from UK policing, the UK Intelligence Community, and private sector partners from financial, telecommunications, technology and cyber industries to drive co-ordinated action against fraud. The centre will target operations at source, focusing on organised crime groups that often sit behind online scams. The strategy also pledges support to INTERPOL in establishing a Global Fraud Taskforce by 2029 to coordinate international investigations and dismantle criminal operations.
The strategy emphasises the need for effective sharing of data and intelligence, and partnerships with countries where fraud targeting the UK is rising. Report Fraud (the new service replacing Action Fraud) will be central to the intelligence gathering exercise, feeding the Online Crime Centre with the data it needs to disrupt fraud, identify vulnerabilities exploited by criminals, and drive the adoption of solutions by working with industry partners.
Report Fraud data will also feed into targeted prevention campaigns, a key part of the 'safeguard' strand. A dedicated network of police PROTECT officers will help those most vulnerable to fraud, from providing doorstep advice to installing call-blocking devices. Industry data will be used to identify suspected fraud victims and take appropriate preventive action.
A more consistent approach to victim support is proposed through the 'respond' strand, with a new fraud victims' charter being introduced in 2027. This charter will set out response times, minimum standards of care and consistent advice on reimbursement and recovery, seeking to establish clear national standards for victims.
Analysing the government fraud strategy through the lens of real world examples
The strategy rightly recognises that fraud is not confined within our domestic borders but is a global problem with significant cross-border activity, which can only be effectively tackled through international collaboration.
So-called "pig butchering" scams perfectly illustrate this. This type of fraud is escalating at an alarming rate, with the FBI's 2024 Internet Crime Report revealing that scammers stole over $6.5 billion from 47,919 victims that year. In these scams, fraudsters build a victim's trust over time before manipulating them into investing in purportedly lucrative opportunities, increasingly through cryptocurrency platforms. The scams often originate in Southeast Asia, orchestrated through illegal scam compounds, frequently staffed by trafficked individuals. The ability of the UK government to take meaningful action without global collaboration is limited. The position of an individual victim is even more stark.
The need for global collaboration – both across countries and across industries – is clear. The government references agreements with Nigeria and Vietnam to share intelligence, which have already resulted in arrests and scam compounds being taken down. The US Treasury and the UK have also announced strategic plans to tackle scam compounds, including the imposition of sanctions on the Prince Holding Group, a Cambodian-based enterprise, and its associates.
Collaboration between law enforcement and the private sector has also yielded significant results. Enforcement actions by US authorities, in collaboration with cryptocurrency platforms, have led to asset seizures and sizeable civil forfeiture actions. Tether's "burn and reissue" mechanism illustrates the efficiency of such collaboration: in late 2023, Tether froze 39 wallet addresses containing $225 million in stolen USDT, burned the original tokens on-chain to prevent perpetrators accessing the funds, and enabled law enforcement to take custody of the equivalent value. Further cooperation from Coinbase resulted in the identification of over 130 of its customers as victims of the scam.
The government has rightly recognised global collaboration as a central pillar of its strategy. It is to be hoped that partnerships with countries where fraud is initiated against UK individuals or businesses will be prioritised, and standing frameworks responsive to the speed at which these scams operate – including the necessary data-sharing arrangements – will be established.
Protection for victims – where next?
The new fraud strategy keeps victims at its heart, with the announcement of the new fraud victims' charter and the dedicated network of police PROTECT officers providing targeted fraud prevention. The focus on disrupting scam operations expeditiously at source and the deployment of AI to spot emerging fraud patterns are also aimed at preventing individuals and businesses from becoming victims in the first place.
However, where these preventive steps fail, the primary objective of victims will be to recover the lost assets, and yet this key strand does not receive significant attention in the government's new strategy.
The challenges for victims in seeking redress against fraudsters are well known – identifying the fraudster, the speed at which assets are moved, and the cross-border nature of these frauds all present unique difficulties. In "pig butchering" scams, the pseudonymous nature of cryptocurrency, combined with obfuscating tactics such as currency conversions and use of affiliate networks, create significant practical difficulties when attempting to trace and recover lost funds across multiple platforms and jurisdictions.
Victims have often looked elsewhere to seek redress, for example through the UK's Authorised Push Payment Fraud Mandatory Reimbursement Scheme or civil claims against banks, but these options may not always be available. The Reimbursement Scheme is limited to transfers to UK bank accounts (made via CHAPS or the Faster Payment System), meaning victims who have transferred monies to overseas accounts fall outside its protection. Furthermore, the scheme is available only to individuals, micro-enterprises and smaller charities, with recovery capped at £85,000 - often only a fraction of victims' losses.
Civil claims against banks also pose difficulties; various claims have been brought but have met some obstacles. For example, the court in Santander UK Plc v CCP Graduate School Limited [2025] EWHC 667 (KB) rejected the argument that a receiving bank owes a retrieval duty to the sending bank's customer where they have been a victim of fraud. It is arguable that a sending bank may owe such a duty, but this has not yet been tested at trial.
It is therefore critical that the preventive and disruptive objectives of the fraud strategy sit alongside effective mechanisms for victims to recover their assets. Clear and accessible procedures are needed for the efficient distribution of seized assets to victims without unnecessary delay (balanced, of course, against the risk of fraudulent claims being made within that process itself). The introduction of section 303Z50 of the Proceeds of Crime Act 2002, enabling cryptocurrency fraud victims to seek the return of seized cryptoassets, is a welcome step in this direction, but more is needed. Similarly, it is encouraging to see the government's stated intention to support law enforcement pilots focused on pursuing legal action against criminals and recovering money for victims through civil law by 2028. However, little detail is provided, and reimbursement and recovery does not feature as a central pillar of the strategy.
From disruption to recovery
The government's new fraud strategy marks a significant step forward, and its emphasis on global collaboration and disruption of criminal networks at source is rightly placed. However, prevention and disruption alone are insufficient. For victims of sophisticated schemes such as "pig butchering" scams, the true measure of success will be returning assets to their rightful owners. Building on the collaborative successes already seen – from Tether's freeze mechanisms to coordinated cross-border enforcement – governments, regulators and industry must now turn their attention to establishing streamlined victim recovery frameworks. With the right combination of international collaboration, effective asset recovery procedures and meaningful reforms to compensation frameworks, victims can be given a genuine prospect of recovery, not merely the theoretical possibility of one.