In May of this year the Government announced that the Insolvency Service (“IS”) would be taking over NATIS’s ongoing fraud investigations into COVID loan fraud. This is a sudden turnaround because it was only in March 2025 that the Department of Business of Trade (“DBT”) renewed its contract with NATIS. The new agreement was to last a further 3 years, and with a maximum contract value of £45million. The reversal was following a Government review of NATIS’s performance that concluded that public money was not being used effectively.
NATIS: central but obscure
NATIS was the government’s primary investigative partner in tackling Bounce Back Loan Scheme-related fraud (“BBLS”). However its background was highly unusual, it being an organisation that evolved from Thurrock Borough Council’s Counter Fraud team in 2018. Since 2020, NATIS’s operations focused almost exclusively on pandemic-related fraud, funded by central government via DBT.
As of July 2024, NATIS employed over 100 staff and was described by Thurrock Council as “unique in the public sector outside of law enforcement organisations”. Yet, despite being charged with tackling high profile fraud, NATIS maintained a low public profile. Even before its disbandment its website was defunct, and its LinkedIn profile was blank – a surprising choice for an entity charged with recovering public money and deterring future fraud.
While NATIS emerged as a key investigatory body, comparisons with traditional agencies such as the Serious Fraud Office (SFO) and National Crime Agency (NCA) highlight important differences. Both the SFO and NCA publish regular updates on case progress and outcomes, reinforcing public confidence in enforcement activity. NATIS, by contrast, lacked a clear reporting structure, and its achievements were often embedded within Thurrock Borough Council documents, limiting broader visibility.
Arrests and investigations: what the data shows
Finding consistent data about NATIS’s case numbers and results was always tricky and were located in Government reports, FOI responses, and parliamentary correspondence. These collectively painted a fragmented picture of progress:
- As of July 2022, NATIS had opened 273 BBLS investigations, worth £160 million, with 49 arrests reported.
- A 2023 Cabinet Office letter indicated 217 BBLS cases and 74 arrests, along with only four criminal prosecutions across BBLS and Business Support Grant cases combined.
- The recent Government announcement indicated the National Investigation Service (“NATIS”) has only secured 14 convictions with the overall amount recovered by NATIS remaining unclear.” This latter revelation must be of concern as recovery was a key metric for NATIS.
Transparency and public confidence
The principle of justice being seen to be done is especially relevant in cases involving public funds. Publicising prosecutions — not just arrests — plays a crucial role in deterrence and reassuring taxpayers that fraud is being taken seriously. In the absence of regular reporting and clearly defined outcomes, it becomes difficult to evaluate whether the government’s enforcement strategy is succeeding.
This lack of transparency is particularly problematic when contrasted with the scale of the abuse and the resources allocated to the National Investigation Service (“NATIS”). Public confidence depends not only on results, but on the visibility of those results.
What next for BBLS cases?
Estimates on the value of BBLS fraud cases vary. The Government recently reported there have been over 100,000 cases of loss to fraud and error. On 30 June 2024 the Government reported that lenders had flagged £1.88 billion of loans as being suspected fraud.
When justifying the transfer of cases from NATIS to IS, the Government reported on IS’s track record dealing with COVID-19 financial support scheme abuse:
- 2000 director qualifications
- 62 criminal convictions
- £6million in compensation recovered
If the reported case numbers are accurate then these represent the tip of the iceberg when it comes to bringing fraudsters to justice. It remains to be seen whether the money set aside for NATIS will be given to IS instead to bolster the investigative resources dedicated to COVID loan fraud. Or whether this money will be used to find different ways of dealing with or prioritising high volume fraud like this. With many of these cases having standard data points and following a similar pattern, certainly the use of AI would seem plausible to collate and compare data points and retrieve and read and assimilate publicly available documents.
This approach would require a public/private partnership to ensure the AI was modelled to the requirements of the task in hand and whilst there would be upfront costs, in the medium term it should put the Government in a better position to tackle what was a national scandal.
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