Financial Crime: analysis of firms’ 2017-2020 REP-CRIM data

Data Published: 07/10/2021 Last updated: 07/10/2021

Ensuring the firms we regulate are effective in preventing financial crime through sound controls is a key priority for the FCA. This is important as the size and global nature of the UK financial industry mean that both money laundering, and the criminality that creates the need to launder money, present significant risks to the UK.

A key approach of the FCA, as set out in the business plan, is collaboration and partnering with others, such as government and other authorities, including law enforcement, to achieve more in raising standards across the regulated sector.

We supervise approximately 22,000 firms against the requirements in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). These firms vary in business activity, size and complexity. Since 2017 we have required banks, building societies, mortgage lenders and certain other type of firms as defined under SUP 16.23 of the FCA Handbook to provide an annual financial crime data return (REP-CRIM). We use this data to complement our risk-based financial crime supervision.

This publication provides analysis of the REP-CRIM submissions for the 3 reporting periods between 2017-2020. For these periods we received a total of 5,685 REP-CRIM submissions from over 2,300 different firms.

This analysis aims to provide Money Laundering Reporting Officers and industry practitioners insights on trends and developments, which should help inform the arrangements and risks of their respective firms.

The key observations of the analysis include:   

  • Firms reported approximately 89,000 Politically Exposed Persons as customers in 2019/20 and 2018/2019, a substantial decrease from approximately 111,000 PEP customers in 2017/18, in part attributed to the amendment of our guidance in 2017 to exclude the reporting of certain domestic customers as PEPs [see paragraph 3.1]. 
  • Wholesale financial markets firms account for 67% on average of the 180 submissions received reporting non-EEA correspondent banking relationships. This is indicative of the complexity of services this sector provides which spans multiple jurisdictions [see paragraph 3.2]. 
  • Retail banking firms have reported approximately 390,000 high risk customers in 2019/2020 which is almost half the high-risk customers reported by all firms (far exceeding firms from other sectors). This is reflective of the sector’s business models which increase their exposure and vulnerability to being used for the purposes of money laundering, as reflected in the National Risk Assessment 2020 [see paragraph 3.3].
  • The number of SARs reported to the National Crime Agency (NCA) has increased, from 394,048 in 2017/2018 to 480,202 in 2019/2020 (c.22% increase) [see paragraph 3.4].
  • The number of firms reporting automated sanctions screening is increasing year on year, with a 16.5% increase over these 3 reporting periods. However, the investment management sector has the highest number of firms that do not use automatic screening [see paragraph 3.5].
  • For the year 2019/20, firms which submitted the REP-CRIM collectively employed approximately 17,000 full-time equivalent staff in financial crime roles, this compares to approximately 15,700 in 2017/2018 [see paragraph 3.8].
  • A total of 761,437 customers were exited during the 2019/20 reporting period, which has more than doubled in the last 3 years. This was about 0.16% of total customers across all submissions that year. Retail lending and retail banking sectors have exited the most customers for each of those years [see paragraph 3.9].

1. Introduction to the data

We published the first analysis of REP-CRIM data in November 2018 covering the reporting period 2016/17.  We received feedback from the industry, through our money laundering reporting officer (MLRO) forums, that firms found this analysis useful, and requested information about different industry sectors, which is now included in this report.

This publication covers analysis of the data we received for the annual financial crime data return (REP-CRIM) for reporting periods 2017/18, 2018/19 and 2019/20. The sector breakdown shown in this data analysis is in line with our broader supervisory approach.

The responses of individual firms to REP-CRIM are confidential, so only aggregated information is presented.

We use data and technology to complement our risk-based financial crime supervision. Our data strategy, published in 2020, sets out our aim to use data and advanced analytics to transform how we regulate: to better predict, monitor and respond to firm issues.

We introduced the annual financial crime data return (REP-CRIM) obligation in 2016 for certain firms subject to FCA supervision. Since then, approximately 2,500 different firms out of approximately 22,000 firms we supervise under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), have submitted REP-CRIM information at least once in the last four reporting periods.

The scope of REP-CRIM is set out in FCA Handbook SUP 16.23. In summary, the current obligation to provide us with REP-CRIM information is based on:

  • firm type, irrespective of a revenue threshold (e.g. banks, building societies and mortgage lenders)
  • activity type and total annual revenue of £5m or more (for example, intermediaries, e-money institutions and consumer credit firms)

We published a policy statement in March 2021 to extend the REP-CRIM to approximately 4,500 additional firms. This will ensure that a broader subset of firms provide REP-CRIM information, enabling us to better understand the intrinsic financial crime risks within these firms.

The REP-CRIM provides key information that helps us assess the nature of inherent financial crime risks within a firm. This includes firms’ exposure to politically exposed persons (PEPs), their sanction screening controls, jurisdictional risks, suspicious activity reports (SARs), resources to fight financial crime and an insight into fraud risks.

We are also developing new analytical tools to assess the effectiveness of firms’ systems and controls and analyse larger amounts of data. This will enable us to better identify inherent money laundering risks as part of our new proactive data-led AML supervisory approach.

2. Firm submissions

Total Submissions for reporting periods 2017/18, 2018/19 and 2019/20

We received a total of 5,685 REP-CRIM submissions from over 2,300 different firms. On average, submissions are slightly less than 2,000 per year and, as some firms are required to submit a return only if their revenue threshold exceeds £5m a year, that population may vary year to year.

Sector Breakdown

Out of the top 3 sectors that contributed to the submissions over the last 3 reporting periods, on average 36% are from investment management and 21% from wholesale markets. Retail lending, retail banking and retail investments together contributed to about 37% of overall submissions.

Chart tips: hover over data series to view the data values and filter the data categories by clicking on the legend.

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Figure 1 shows the total number of REP-CRIM submissions has increased by about 9% over the past 3 years. Overall, the number of submissions each year has been slowly increasing, but the individual proportions for each sector has remained constant.

Data Quality

REP-CRIM data is essential to our risk-based supervisory approach, so the quality of the data is closely monitored. Despite this, there continues to be data submissions with empty or unusual values.

Examples of inconsistent data submissions we have noticed include:

  • the number of SARs reported externally were greater than the number of SARs reported internally
  • firms stating that the total number of full-time staff dedicated to financial crime exceeded the firm’s total number of customers

We want to remind firms required to submit REP-CRIM data that this is a regulatory obligation. We will continue to follow-up with firms who submit poor-quality data and we note that poor data submissions can, in some instances, be evidence of poor financial crime systems and controls.

Firms should refer to our SUP 16 Annex 42B Guidance notes for completion of the REP-CRIM as appropriate.

In 10 submissions, we noticed incorrect or poor quality data points. These data points have been excluded from the analysis where appropriate, to remove any distortions in statistical observations. This will result in a slight variance in the total number of submissions considered for analysis.

3. Key Observations

3.1. Exposure to Politically Exposed Persons (PEPs)

The definition of ‘Politically Exposed Person’ can be found in Regulation 35(12)(a) of the MLRs and what needs to be reported on REP-CRIM is set out under Section 2 of SUP 16 Annex 42B Guidance notes for completion of the Annual Financial Crime Report.

For the reporting year 2019/20, firms reported a total of 89,437 PEPs as customers. This decrease from 2017/18 to 2018/19 may be attributed to the fact that in 2017, we amended our guidance to exclude the reporting of certain domestic customers as PEPs.

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In Figure 3, more than one-third (40%) of total PEPs reported are concentrated within wholesale financial markets followed by retail banking and retail lending, contributing 31% and 11% of total PEPs respectively.

3.2. Non-European Economic Areas (EEA) correspondent banks

Firms are asked to report the number of correspondent client relationships with a respondent institution from a non-EEA state.

Over the 3 reporting periods, 180  firms have  reported non-EEA correspondent banking relationships at least once. From these, 5 submissions make up almost 50% of the total, with wholesale financial markets making up 67% on average.

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In Figure 4, the overall number of non-EEA correspondent banking relationships have decreased slightly over the 3 reporting periods, with the biggest decline seen in the wholesale financial market sector.

3.3. Other high-risk customers

REP-CRIM requires firms to report customers or clients categorised as being high-risk (other than PEPs and Non-EEA correspondent banks) for the purposes of compliance with Regulation 33(1)(a) of the MLRs and therefore subject to enhanced customer due diligence measures.

There were 1,047,338, 797,416, and 735,967 high-risk customers reported in reporting periods 2017/18, 2018/19 and 2019/20 respectively. Overall, the number of high-risk customers is declining.

The retail banking sector reports more high-risk customers compared to other sectors.

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Figure 5 shows the retail banking sector is reporting more high-risk customers requiring enhanced due diligence compared to other sectors. Overall, there is a declining trend in the total number of such high-risk customers on the books of the firms reporting the data in most sectors. The increase in high risk customers in the Pensions & Retirement Income sector is contributed to by a few firms who have submitted REP-CRIM for the first time in 2019/20.

3.4. Suspicious Activity Reports (SARs)

As part of the annual REP-CRIM submissions, firms are required to report the number of SARs recorded under Part 7 of the Proceeds of Crime Act 2002. This includes reports submitted to the MLRO/Nominated Officer that relate to the staff member’s concerns, suspicions, or knowledge of, money laundering. The reported figures also include reports received by an MLRO generated by a firm’s anti-money laundering or compliance function, or by automated systems. The MLRO/Nominated Officer considers these reports to decide whether a formal submission to the National Crime Agency (NCA) is justified.

Table 1: summarises the data points collected through REP-CRIM

Reporting Year

2017/2018

2018/2019

2019/2020

No. of REP-CRIM Submissions

 1,813

 1,898

 1,974

No. of SARs submitted internally to the MRLO/Nominated Officer, within the firm (Internal SARs).

 887,500

 934,136

 1,028,260

No. of SARs submitted to the NCA (External SARs).

 394,048

 401,012

 480,202

No. of SARs which were consent requests under s. 335 POCA.

 11,850

 16,685

 24,410

No. of SARs disclosed to the NCA under the Terrorism Act 2000.

 1,665

 940

 665

Overall, there is an upward trend in the number of SARs reported internally to MLROs and externally to the NCA and a declining trend on the number of SARs disclosed to the NCA under the Terrorism Act 2000.

For the reporting year 2019/20:

  • Close to half of the 1,028,260 SARs reported internally to MLROs are from 3 firms and the same firms are also contributing to over 60% of the SARs reported to the NCA.
  • Retail banking contributed to over 78% of the SARs internally reported to MLROs and about 85% to SARs reported to the NCA.

Table 2: SARs breakdown per sector for the reporting period 2019/20

Sector

No. of SARs submitted internally to the MRLO/Nominated Officer, within the firm (Internal SARs)

No. of SARs submitted to the NCA (External SARs)

Retail Banking

                        804,105

                        411,931

Retail Lending

                        204,374

                          57,192

Wholesale Financial Markets

                          12,062

                            7,402

Retail Investments

                            3,588

                            2,157

Investment Management

                            2,012

                              625

General Insurance & Protection

                            1,399

                              712

Pensions & Retirement Income

                              720

                              183

Note: External SARs figures are a subset of Internal SARs figures.

The difference between the volume of SARs reported to the NCA and the volume of SARs reported internally to MLROs varies greatly between firms within the sector and this could be reflective of firms’ differing risk appetites.

3.5. Sanctions

About two-thirds of REP-CRIM submissions over the 3 reporting periods indicated that firms undertake automated screening against relevant sanctions lists.

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In Figure 6, overall, the number of firms reporting automated sanctions screening is increasing year on year, with a 16.5% increase over these 3 reporting periods.

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In Figure 7, we see that every sector has firms that do not use automatic screening. The investment management sector has the most, at 271 submissions, while retail banking has 6 firms who reported that they do not use automatic screening.

REP-CRIM requires firms to report the number of confirmed true sanctions alerts that matched against the firm’s customer, client or payment. The numbers reported should relate to any matches against any relevant sanctions lists.

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In Figure 8, the number of true payment sanction matches almost doubled from 2018/19 to 2019/20, from 2,775 to 5,438. In the same period, true customer sanction matches almost halved, from 4,138 to 2,191.

For the reporting year 2019/20:

  • 2,191 customer sanctions matches were reported, coming from 68 submissions. 5 firms contributed to approximately 90% of these matches while retail lending contributed to about 70% of these hits followed by retail banking at about 16%.
  • 5,438 payment matches were reported, coming from 35 submissions. 5 firms contributed to over 90% of these hits with retail banking contributing to about 93% of the total matches.

3.6. Firm relationships with introducers

Firms submit the number of relationships maintained which introduce business. Firms must also report the number of these relationships exited, where financial crime is the driving factor. If applicable, firms must also provide the number of appointed representatives exited.

In the 3 reporting periods, over 1,000 firms have said that they have relationships maintained with natural or corporate persons (excluding group members) which introduce business to the firm. For the reporting period 2019/20, just over 1.17m such relationships were reported across the submissions which was about a 12% increase from 2017/18. 165 firms have said they have exited introducers due to financial crime reasons in the last 3 reporting periods.

61 appointed representatives were exited in 2017/18, with 70 and 73 exited in 2018/19 and 2019/20 respectively.

3.7. Firms’ views on jurisdiction risk

Each firm submits a list of the jurisdictions in which they carry out business and have assessed as being high risk for financial crime. Respondents rated countries based on ‘financial crime’ risk which, in addition to money laundering risk, may also cover a variety of threats, including sanctions breaches, fraud and bribery.

Table 3 aggregates the data received by approximately 1,900 REP-CRIM submissions for the reporting year 2019/20. The table is compiled by aggregating the number of instances a country has been assessed as higher risk by a firm. It is important to note that the position of a country in the table will be influenced by many factors, including firms’ different risk appetites and the countries in which firms carry out business. For example, a country may be considered high risk but due to few firms operating in the country it wouldn’t be included in many firms’ submissions, causing it to appear lower in the table below.

The table does not represent the opinion of the FCA. It is solely an aggregation of data collated through REP-CRIM submissions.

 

Table tip: Click on the headings to sort the table

Table 3: Firms’ views on jurisdiction risk

ISO Country Code Country Frequency
BTN Bhutan 90
JOR Jordan 108
QAT Qatar 108
ESH Western Sahara 107
COK Cook Islands 107
FSM Micronesia, Federated States of 104
GRD Grenada 101
BRN Brunei Darussalam 98
TON Tonga 98
ABW Aruba 98
KIR Kiribati 96
GEO Georgia 93
SXM Sint Maarten (Dutch part) 92
VAT Holy See (Vatican City State) 84
MYS Malaysia 111
MSR Montserrat 83
MLT Malta 80
TUV Tuvalu 80
SMR San Marino 80
VCT Saint Vincent and the Grenadines 79
GIB Gibraltar 77
ISR Israel 76
GBR United Kingdom 70
BES Bonaire, Sint Eustatius and Saba 69
XKX Kosovo 63
NCL New Caledonia 59
EST Estonia 58
FLK Falkland Islands (Malvinas) 58
ZAF South Africa 110
ISL Iceland 113
PYF French Polynesia 57
BRB Barbados 139
RWA Rwanda 154
MCO Monaco 152
LSO Lesotho 150
SUR Suriname 147
STP Sao Tome and Principe 147
GUM Guam 145
CPV Cape Verde 143
ASM American Samoa 143
NRU Nauru 143
BMU Bermuda 142
FJI Fiji 141
TCA Turks and Caicos Islands 141
MUS Mauritius 139
LCA Saint Lucia 114
PLW Palau 139
MAC Macao 136
PRI Puerto Rico 127
LVA Latvia 125
MKD Macedonia, the former Yugoslav Republic of 125
CRI Costa Rica 124
NIU Niue 123
AIA Anguilla 121
CUW Curaçao 119
SLB Solomon Islands 119
AND Andorra 118
DMA Dominica 117
LIE Liechtenstein 117
MNP Northern Mariana Islands 57
IMN Isle of Man 57
SEN Senegal 154
SGP Singapore 7
ATA Antarctica 35
URY Uruguay 34
BLM Saint Barthélemy 33
KOR Korea, Republic of 31
HKG Hong Kong 26
HUN Hungary 26
CHL Chile 18
ITA Italy 15
SVK Slovakia 12
CHE Switzerland 11
POL Poland 8
CZE Czech Republic 7
PRT Portugal 6
HRV Croatia 37
NLD Netherlands 6
USA United States 6
JPN Japan 5
SVN Slovenia 5
LUX Luxembourg 3
DNK Denmark 3
NZL New Zealand 2
BEL Belgium 2
ESP Spain 1
CAN Canada 1
AUS Australia 1
AUT Austria 1
IRL Ireland 1
GRC Greece 36
ALA Aland Islands 38
GGY Guernsey 57
CXR Christmas Island 48
MTQ Martinique 57
SHN Saint Helena, Ascension and Tristan da Cunha 53
WLF Wallis and Futuna 53
PCN Pitcairn 52
JEY Jersey 52
ROU Romania 52
FRO Faroe Islands 52
CCK Cocos (Keeling) Islands 51
GLP Guadeloupe 50
TKL Tokelau 50
MYT Mayotte 50
BVT Bouvet Island 49
MAF Saint Martin (French part) 47
SJM Svalbard and Jan Mayen 39
SPM Saint Pierre and Miquelon 47
TWN Taiwan, Province of China 47
IOT British Indian Ocean Territory 47
UMI United States Minor Outlying Islands 46
LTU Lithuania 46
GUF French Guiana 45
NFK Norfolk Island 45
HMD Heard Island and McDonald Islands 45
SGS South Georgia and the South Sandwich Islands 43
ATF French Southern Territories 43
REU Reunion 42
BGR Bulgaria 42
GRL Greenland 41
MNE Montenegro 154
ATG Antigua and Barbuda 154
PAK Pakistan 385
ERI Eritrea 272
SRB Serbia 293
BIH Bosnia and Herzegovina 293
LBR Liberia 292
CAF Central African Republic 292
HTI Haiti 291
BWA Botswana 288
VUT Vanuatu 286
BDI Burundi 282
SSD South Sudan 280
CHN China 279
TZA Tanzania, United Republic of 272
AGO Angola 272
MLI Mali 272
LAO Lao People's Democratic Republic 295
GNB Guinea-Bissau 271
TJK Tajikistan 270
BOL Bolivia, Plurinational State of 266
BLR Belarus 265
VNM Viet Nam 265
GIN Guinea 265
GUY Guyana 261
CUB Cuba 258
ARE United Arab Emirates 257
MOZ Mozambique 256
SAU Saudi Arabia 256
AZE Azerbaijan 256
GNQ Equatorial Guinea 254
SOM Somalia 295
NIC Nicaragua 302
UZB Uzbekistan 253
LKA Sri Lanka 335
BHS Bahamas 377
PAN Panama 374
RUS Russian Federation 372
YEM Yemen 357
NGA Nigeria 355
IRN Iran, Islamic Republic of 353
ZWE Zimbabwe 352
LBN Lebanon 350
TTO Trinidad and Tobago 349
SYR Syrian Arab Republic 348
IRQ Iraq 345
GHA Ghana 343
LBY Libya 333
TUR Turkey 302
AFG Afghanistan 332
PRK Korea, Democratic People's Republic of 328
TUN Tunisia 328
KHM Cambodia 326
UKR Ukraine 325
ETH Ethiopia 324
MMR Myanmar 324
UGA Uganda 322
KEN Kenya 319
EGY Egypt 319
VEN Venezuela, Bolivarian Republic of 315
COD Congo, the Democratic Republic of the 303
SDN Sudan 302
KAZ Kazakhstan 254
MEX Mexico 252
VIR Virgin Islands, U.S. 157
GMB Gambia 184
MDG Madagascar 208
MRT Mauritania 207
PNG Papua New Guinea 205
PER Peru 203
WSM Samoa 202
DJI Djibouti 201
CYM Cayman Islands 198
SWZ Swaziland 192
MAR Morocco 190
TGO Togo 189
KWT Kuwait 186
ARG Argentina 185
BRA Brazil 178
ZMB Zambia 210
GAB Gabon 177
SLV El Salvador 176
BFA Burkina Faso 175
BHR Bahrain 175
ARM Armenia 174
MHL Marshall Islands 173
MWI Malawi 173
NAM Namibia 164
TLS Timor-Leste 164
SYC Seychelles 163
CYP Cyprus 160
OMN Oman 160
KNA Saint Kitts and Nevis 158
JAM Jamaica 210
CMR Cameroon 213
TKM Turkmenistan 251
MDA Moldova, Republic of 235
MNG Mongolia 247
THA Thailand 246
SLE Sierra Leone 245
ECU Ecuador 245
TCD Chad 245
COG Congo 244
KGZ Kyrgyzstan 243
PHL Philippines 239
HND Honduras 238
ALB Albania 238
BEN Benin 236
COL Colombia 236
GTM Guatemala 234
COM Comoros 213
DZA Algeria 234
BLZ Belize 232
MDV Maldives 231
PSE Palestine, State of 227
CIV Cote d'Ivoire 227
NPL Nepal 222
DOM Dominican Republic 219
BGD Bangladesh 219
PRY Paraguay 219
NER Niger 216
IND India 216
VGB Virgin Islands, British 215
IDN Indonesia 214
FIN Finland 1

3.8. Staff in financial crime roles

Monitoring and addressing the risk that criminals abuse the financial system consumes a significant amount of firms’ time and resources. We ask firms to report total full-time equivalent (FTE) of UK staff within financial crime roles. This should cover staff in roles relating to anti-money laundering, counter-terrorist financing, anti-bribery and corruption, and fraud.

For the year 2019/20, firms which submitted the REP-CRIM collectively employed around 17,403 full-time equivalent staff in financial crime roles, as compared to approximately 18,000 in 2018/19 and roughly 15,700 during the year before.

Based on the FTE reported for 2019/20, we estimate that firms who submitted the REP-CRIM are collectively spending around £1.1b annually in dedicated staff time to combat financial crime.

We do not ask firms to set out their costs. We have estimated cost based on the Office for National Statistics’ publication ‘Employee earnings in the UK: 2019’ which estimates that the UK median full-time earnings for quality assurance and regulatory occupations was £43,545 a year. Adding on 50% for overheads (such as employers’ national insurance contributions, accommodation, power, etc.) assumes an annual cost of £65,319 per FTE. The figure does not include other costs such as those related to information technology systems. Nor does it include time taken by the rest of a firm’s staff on preventing financial crime, for example, branch staff dealing with customers who are at the front line of the sector’s efforts to tackle fraudsters and money launderers.  

3.9. Customers exited and refused for financial crime reasons

We ask firms to report on the number of customer relationships refused or exited from all lines of business for financial crime reasons during the reporting period. This covers any customers or clients with whom the firm ceased to do business where financial crime or criminal behaviour by a customer or client with a financial element was the principle driver behind the decision.

A total of 761,437 customers were exited during the 2019/20 reporting period, which has more than doubled in the last 3 years. This was about 0.16% of total customers across all submissions that year. Retail lending and retail banking sectors exit the most customers each year.

During the 3 reporting periods, the number of customers refused for financial crime reasons totalled 1.46 million in 2017/18 (0.37% of the total relationships reported), 1.48 million in 2018/19 (0.35% of total relationships reported) and 2.05 million in 2019/20 (0.45% of total relationships reported).

3.10. Fraud

The questions around Fraud on REP-CRIM are designed to obtain the firm’s view on the most prevalent frauds relevant to the firm. The data obtained may not be a reflection of the whole industry as REP-CRIM only applies to a section of our supervised population under the MLRs.   

In addition, the firms’ responses to the fraud section of the financial crime return are voluntary and an average of 50% of respondents (less than 1,000 firms) complete this section each year.

Separately, we have also published a summary of our work to tackle consumer harm in the investment market.

Fraud concerns

Firms are asked to submit their top 3 fraud concerns. The data displays only the top concerns reported by firms each year, this is relatively consistent across the reporting periods.

Cyber-crime is shown to be a key concern, with many of the frauds that are most frequently mentioned (such as computer hacking and phishing) related to information technology. However, some long-established crimes (such as account takeover and card fraud) were also highly-cited threats.

The top reported frauds differ by sector, while some are universal (or near-universal) such as identity fraud and theft, and phishing.

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In Figure 9 we see that phishing remains the top fraud concern for each reporting year, with identity fraud, computer hacking and application fraud also being key concerns. Overall, the order of top concerns has not changed.

About 70-80 firms use the option of 'other' as Fraud type for firms to select when specified typologies are not available in the drop-down list. Where 'other' is used, firms are required to provide a description of the fraud. There were over 150 descriptions of various types of fraud provided by the firms (some of them appear to be variants of the similar type of fraud) but there appears to be no themes coming out of these descriptions. Some of these include Authorised Push Payment, Insider Information and Fronting.

Primary victim of Fraud

Firms are asked to submit who they believe the primary victims of fraud are. The chart displays the top reported victim for each fraud type.

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In Figure 11, customers are the highest primary victims of fraud, with the overall proportions of primary victims not changing year on year.

The following chart provides further analysis of primary victim by fraud type for the reporting year 2019/20.

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In Figure 11, the 2 main primary victims are customers and regulated firms. Overall, the primary victim for each fraud type is split evenly between these 2 categories.

Suspected perpetrator

Firms are asked to submit who they believe the top perpetrators of fraud are. The chart displays suspected perpetrators for each fraud concern for the 3 reporting periods.

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Figure 12 shows unknown thirds party and organised crime group have consistently been the top suspected perpetrator of fraud across the last 3 reporting periods.

The following chart shows the suspected perpetrators by fraud type for the latest reporting year 2019/20.

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In Figure 13, a large part of the responses included 'unknown third party' as the suspected fraud perpetrator across the 3 years. For certain fraud types, such as mortgage fraud and insurance fraud, customers are reported as being the top suspected perpetrator.