Edition 003 / October 2012
PAYING THE PRICE HSBC is paying $1.9 billion in US money laundering penalties. The figure was reached under a Deferred Prosecution Agreement – something that is set to become increasingly common in the UK. There was plenty of eyebrow-raising information to digest in the reports of HSBC’s massive money laundering case. The UK-based bank confirmed it would pay £1.2 billion ($1.9 billion) in what is the largest ever settlement for money laundering. Its settlement came after it admitted poor money laundering controls, accepted full responsibility for its mistakes and stated that it had spent $290M on improving its systems to prevent money laundering in the future. When the evidence is considered, HSBC had little option but to hold its hands up and admit wrongdoing. A report by the US Senate had alleged that HSBC in the US had not treated its Mexican affiliate as high risk, despite Mexico’s extensive track record of money laundering and drug trafficking. The Mexican bank had transferred $7 billion in US bank notes to HSBC in the US. It had circumvented US safeguards designed to block transactions involving terrorists, drug lords and rogue states – including allowing 25,000 transactions over seven years without disclosing their links to Iran, providing US dollars and banking services to banks in Saudi Arabia despite their links to terrorist financing and clearing $290M in “obviously
suspicious’’ travellers cheques that benefited Russians claiming to be used car dealers. The tale is a colourful one for the reader and a cautionary one for anyone involved in banking. But it is also gives us a glimpse into the future of regulation in the UK – not simply because it involves a British bank but because it involves a device that is set to become part of British prosecutors’ armoury. The HSBC settlement was reached after it entered into a Deferred Prosecution Agreement (DPA). Although they have been used in the US for some time, it was only three months ago that the UK government announced that it would be legislating to make it possible to use them in this country. So what is commonplace in the US and was seen so spectacularly in the HSBC case will soon be reality in the UK. - -
A DPA involves the authorities coming to an arrangement with a company that involves any criminal prosecution being deferred on condition that the company makes changes and agrees certain terms. In the case of HSBC
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and its DPA, it has agreed to introduce stronger internal controls. The bank has appointed Bob Werner, previously the head of the US Treasury’s Office of Foreign Assets Control, to work as its head of financial crime compliance as part of its undertaking. A DPA effectively means that a company has a prosecution against it deferred while it meets such terms as, for example, paying a fine, removing staff that committed the offences or agreeing to have its activity monitored while it introduces anticorruption measures to avoid repeat offending. DPA’s have helped the US Department of Justice weed out bad practice and illegal behaviour in companies. At the same time, the UK’s Serious Fraud Office has spent time and money prosecuting companies for similar behaviour but has had only limited success. When this is considered, it becomes clear why the UK government has decided to go down the DPA route. Companies that would be likely to deny all allegations of wrongdoing if a UK trial was looming may be more likely to admit any illegal behaviour if they are able to undertake a DPA. A DPA will mean less cost and less reputation damage than a trial. Supporters of DPA’s say they offer a company a chance to take supervised action to put right its wrongs. This, they say, is more attractive to a company than risking crashing out of business beneath a growing pile of allegations of wrongdoing.
having done wrong will not be treated any differently to the way they are now. The main difference the UK will see with the introduction of DPA’s is that companies can face less severe consequences under them. This is based on the DPA principle that there has to be an admission of guilt and a genuine will - backed with action - to put right past wrongs. If wrongdoing is discovered and the SFO considers a DPA the right course of action, it is likely that a judge will be involved in overseeing any potential agreement. In the US, there is practically a sliding scale of punishments that can be consulted prior to entering into a DPA. The UK offers no such opportunity. It is likely, however, that DPA outcomes will be attractive because of their negotiated nature. After years of expecting the arrival of DPA’s in the UK, the government has finally signalled that they are coming. When they do arrive, the UK will have to ensure that they are not merely a cop out option for companies hoping to avoid the full force of the law for their illegal activity. The DPA in the UK could become both a hugely important way
In agreeing to enter a DPA, a company has to admit any criminal behaviour. This means that individuals guilty of criminality can still be prosecuted. Critics have accused DPA’s of giving guilty executives a chance to escape prosecution but the argument against this states that anyone identified as - -
of making companies clean up their act and a means of gathering the evidence needed to prosecute those to blame for wrongdoing. But one issue that has to be addressed is when does negligence become criminal activity? A company may freely admit to certain instances of wrongdoing. But will it openly admit they did them with criminal intent? And how can a DPA be framed if such a company will only admit to being careless or sloppy rather than calculating and criminal? The DPA will change the rules of the game in the UK. But it cannot be seen as an easy way out. In fact, they could well make it even more vitally important that a company under investigation gets the right expert legal help. Experience has shown that whenever a new aspect is introduced to corporate law only the right legal advice can guarantee that anyone under investigation is not wrong-footed. Commentators seem to agree that HSBC could have faced heavier penalties if it had not entered into a DPA. Even the most fervent of DPA detractors could not claim that HSBC was let off lightly under its agreement. In future years, it will be interesting to see how many companies that come under investigation in the UK have paid heed to what DPA’s have achieved in the US – and how it affects their response to possible prosecution.
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OUCH!! DENTISTS UNDER EXAMINATION AS DENTAL FRAUD BECOMES A PAINFUL TRUTH Here, Rahman Ravelli examines the true situation regarding dentists and fraud and suggests ways practices can give themselves a check up. AN ESTIMATED £70M-plus is being lost each year to dental fraud. It is thought that an even larger amount than that will fall victim to fraud in dentistry before the problem is put right. The figures come from watchdog NHS Protect, which says it uncovered appalling levels of fraud. In the year it reviewed (2009-10), it discovered that £73.1M was paid out for fraudulent claims by dentists for work that was never carried out. NHS Protect warns that with new dental contracts not expected to be in place until 2014, there is scope for almost two years’ further fraud on a similar scale. The Office of Fair Trading (OFT) wants new NHS dental contracts introduced as soon as possible to ensure more patient choice, greater ease of entry into the market by new dental practices and the chance for better performing practices to expand. Now, it seems, the dentists are coming under as close a scrutiny as their patients. Much of the blame for the alleged fraud is placed on changes made to the NHS dentistry contract system in 2006. The changes were intended to improve patient access to dental services, following concerns that millions of people were unable to register with NHS dentists. These changes meant that payment for NHS dentistry was not tied to one particular course of treatment, such as a filling or crown. Under the changes, treatment was categorised into three groups. The problem that this caused, according to NHS Protect, was that it gave dentists scope for fraudulent claims. Instead of claiming for a specific filling or crown, dentists simply had to state which group of treatment they were claiming payment for. And NHS
Protect’s review of a random 5,000 bills submitted by dentists showed that many were claiming for having done more expensive work than they had actually carried out. NHS Protect believes 3% of the annual 37.5 million claims made each year could be fraudulent – more than a million a year.
suggests that NHS commissioning bodies and the General Dental Council (GDC) need to be far more proactive in identifying and pursuing formal, robust and timely enforcement action against such instances of misconduct where appropriate.’’
Last year, the Office of Fair Trading (OFT) called for changes to the £5.73 billion-a-year UK dentistry market after its study found that patients have insufficient information to make informed decisions about their choice of dentist and the dental treatment they receive.
The OFT wants the GDC to take “more robust and timely disciplinary action’’ against instances of misconduct by dentists and calls on the British Dental Association (BDA) to develop an effective code of practice to ensure dentists’ selling of dental payment plans does not breach consumer protection law. According to the OFT, there needs to be a simpler, quicker complaints process that can be used by dental patients.
In its report, the OFT says: “We are particularly concerned to find that around 500,000 patients each year may be provided with inaccurate information by their dentist regarding their entitlement to receive particular dental treatments on the NHS and, as a result, be required to pay more to receive private dental treatment unnecessarily. ’’ Evidence gathered by the OFT - -
In response to fears of fraud, the UK government has said it will introduce a new contract system that will not only improve people’s access to good dental treatment – it is also aimed at reducing the risk of dental fraud. Under the new proposals, there will be more
www.rahmanravelli.co.uk scope for analysing dental contracts to detect irregular, suspect or otherwise unaccounted-for activity much earlier. According to the government, it plans to alter the way dental treatment is recorded in a way that will remove the potential for fraudulent claims while promoting awareness of the risks of such fraud. It intends to promote a more uniform way of working for all NHS dentistry services.
NHS Protect has said it will continue to monitor the risks of fraud within the NHS’ dentistry sector. The upshot of all this is that dentists, their staff and practice managers are all now likely to be scrutinised in a much closer way than they ever have been before. Whether the government is following the old argument that “one bad apple spoils the whole barrel’’ or simply believes that a few rogue dentists are tarnishing the reputation of thousands of honest ones has not been made expressly clear. But what we do now know is that there is fraud in dental circles and the authorities are out to eradicate it. It is because of this new awareness that even the most honest dentists now have to be especially careful about how they do business. At Rahman Ravelli, we have been involved in cases where dentists have acted in good faith in carrying out first-class treatment and have billed for the work accordingly – and yet they have still found themselves under investigation.
practice was hampered and patient treatment was disrupted. More than two years later, when it came to trial, the judge said the prosecution case was ill conceived and stayed the charge of conspiracy to defraud the primary care trust. This case was the one that was named Operation Groat by police. We believe that from day one the prosecution showed a lack of judgement and an inability to understand the nature of the 2006 dental contract. As a result, a contractual dispute over payments to the practice under the national dental contract was allowed to mutate into a criminal prosecution. In our arguments, we pointed to the proceedings being an abuse of the court’s process. We highlighted the fact that not only had no fraud been perpetrated but that the PCT had raised no concerns about the operation of the dental practice. The practice was saving the PCT money and by offering what it called “private options’’ it was giving the maximum possible amount of patients the best treatment given the limits on what it could provide under its NHS dental contract. Most NHS dental fraud involves a practice charging for patients that were never treated or, if they were, sees the practice inflating the amount of treatment supplied to gain extra money from the PCT. The practice we represented was actually being prosecuted for devising a way of costing the PCT less money. Our arguments and those of our fellow defence team solicitors were accepted by the court, leading to the prosecution coming to an end. But it could only be
We were recently involved in a case where a complex conspiracy by a dental practice to defraud an NHS trust was alleged. These allegations centred on how the practice was run under the dental contract and the way it treated patients. The practice and other related properties were raided, our client’s ability to continue managing the - -
stayed because we were able to back up our arguments with solid, documentary evidence and testimony. With this in mind, it is important that dental practices remember a few essential points when carrying out their day-today duties. Firstly, comprehensive records of work booked, carried out and billed for must be kept contemporaneously. There can be no lag in completing the paperwork – and all records must be kept in duplicate and filed away. If practices are worried about what they should be doing to pre-empt any investigation, then having an up-to-date, accurate and contemporaneous record-keeping system is the essential activity they should be carrying out. Secondly, they need to look at the potential for fraud in the operation of the practice, regardless of whether they believe or suspect that it is happening. All aspects of the way the practice operates should be examined closely. In some cases, it will be advisable for them to enlist the help of legal experts in the field of compliance. Such experts can help the practice ensure it is run in a way that means it could show anyone that it offers absolutely no potential for fraud. Such legal expertise could advise a practice on how it should react if it should come under investigation for fraud. But first and foremost a practice has to make sure it is operating in a manner that allows little or no scope for fraud and, if fraud did ever occur, it could be flagged up and acted upon immediately.
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TALKING TOUGH The SFO Director has been outlining his determination to take on those doing wrong, regardless of the cost. But Aziz Rahman of Rahman Ravelli wonders if he has the money to back up his stance. investigations.
The SFO Director has been outlining his determination to take on those doing wrong, regardless of the cost. But Aziz Rahman of Rahman Ravelli wonders if he has the money to back up his stance. Money isn’t everything, as the old saying goes. But it is certainly a formidable something in most people’s lives. There are very few of us who can honestly say that it isn’t a factor in what we do. Which is why it is perhaps a little surprising to hear the Serious Fraud Office’s (SFO) Director David Green stating that money would not be a factor when it comes to carrying out
As far as we know, the SFO is not rolling in money. And yet Mr Green sounded quite confident in his pronouncement. Speaking to the House of Commons Justice Committee he said: “Of course, the SFO can never refuse to conduct an investigation on the ground that we cannot afford it, nor will I do that.’’ He later added: “…If I am short of resources, I will say so. The bottom line for me is that, as I said earlier, the SFO cannot refuse to take on an investigation because we cannot afford it. That would be completely unacceptable. I believe that it would be unacceptable to Ministers; it would certainly be unacceptable to me and, I am sure, to the public…” As statements go, it’s pretty bold and very clear. It also contradicts what a lot of people have thought about the SFO in recent years, not least because
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its funding has dropped from £53M in 2008-09 ago to nearer £30M for this coming year. According to Mr Green, the high funding figure for 2008-09 was never intended to be a permanent level. He also states that SFO has benefited from the Asset Recovery Incentivisation Scheme (ARIS), although he makes it clear that he does not want the annual £2.3M it currently provides to be considered part of “our bottom line’’. He argues this on the grounds that the SFO does a small number of cases and, therefore, does not have the rate of turnover for confiscation to make ARIS a big earner for his outfit, especially as much of the money that is recovered is paid out in compensation to victims. To his credit, he also points out that people may perceive there to be a conflict of interest when a prosecutor receives money from confiscated assets. Which is very noble. But it does not answer the question of how the SFO could afford to never turn down a case.
www.rahmanravelli.co.uk In addressing the Justice Committee, Mr Green added: “When I took on the job, and as of today, I am happy and content that the existing resource is sufficient for what I might call our day-to-day work. That does not mean to belittle any of our cases, all of which are extremely challenging.
and required immediate and in-depth attention. Yet, how many times will the Director feel he has the need to ask for such extra funding to investigate a matter? And, perhaps more to the point, what will be the response from the government each time he goes to it cap in hand?
“The existing resource is sufficient, as well, to maintain, as it were, a core staff of around 300. The problem comes when one or more exceptional cases come along. LIBOR is a very good example… “We therefore need what I suppose would fashionably be called a surge capacity. LIBOR is a good example of that. I am very grateful that the Treasury has underwritten us up to £3.5 million, should we fail to absorb those costs, in order to cover LIBOR. That is in a sense, I hope, the new model—obviously, to be developed. If you like, it is a return to what used to be called blockbuster funding or something like it…”
Prior to Mr Green going before the Justice Committee, the Attorney General had made his own appearance in front of it. During his appearance, the Attorney General stated that the government had indicated that more funds would be available if they are required by the SFO. He added: “If the Director of the SFO feels that the time has come, or he needs it, he will come and see me about it.’’. However, when quizzed further on this point, the Attorney General stated that his response would be to go to see the Treasury and discuss the matter with them. In answering the Committee’s questions, he stressed London’s immense importance to the UK as a financial centre and the resulting need “to show that the regulators and the criminal justice system have teeth’’.
In short, it seems Mr Green is putting his faith in the ability to go calling on the Treasury for extra funding when he feels he needs it. Yes, LIBOR has been an instance where the SFO has gained the extra funding required to carry out a thorough investigation into a major issue that suddenly came into view
Noone doubts that such organisations need teeth. Mr Green has stated that he does not want people to think that the SFO does not have the stomach for prosecutions and would prefer to
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do deals. He admits that the SFO’s purpose had become “a bit woolly and a bit blurred over time, for all sorts of reasons’’. Now he wants to restate and demonstrate its purpose as a body set up to investigate and prosecute serious complex fraud, bribery and corruption. If the AG was talking about teeth, it seems as if Mr Green is out to bare the SFO’s fangs to anyone watching. Such impressive dental work, however, does not come cheap. And if Mr Green is hoping that he will get all the extra funding he asks for whenever the AG takes his request to the Treasury, it may not be as straightforward as he believes. Mr Green clearly wants the SFO to be an aggressive prosecutor. But without guaranteed extra resources it could end up with a bark much worse than its actual bite.right and the rewards will follow. Get it wrong and it has to all go back to the drawing board.
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POINTING THE FINGER HMRC has been voicing its concerns on tax avoidance. Here we look at the issue and examine the role of COP9 in the tax man’s attempts to chase revenue. HMRC has been voicing its concerns on tax avoidance. Here we look at the issue and examine the role of COP9 in the tax man’s attempts to chase revenue. Tax avoidance seems to be on the news agenda with increasing frequency. Some of the largest foreign-owned companies have been before the Public Accounts Committee to answer questions about their tax affairs. And one of them, Starbucks, has now come out and said it will voluntarily pay more tax in the UK. Certainly, the climate regarding tax avoidance seems to be hotting up. HMRC has said that foreign-owned companies are responsible for almost half of the tax being underpaid by large corporations – a total of £11 billion. This £11 billion is 44% of the £25 billion of tax “under consideration’’ by HMRC, which means any tax that has been potentially underpaid and the amounts of tax at risk to the Exchequer because companies are in legal dispute over the amounts of tax they have overpaid. The chances of HMRC ever seeing all or even most of that £11 billion headline figure are remote. Another figure that has been put out by HMRC is the £400M in underpaid taxes
it believes are owed by directors and senior executives of some of the UK’s largest companies. As executive pay has risen faster than that in any other sector, it could be argued that it makes sense for the tax man to take a closer look at the mega-rich big earners who seem to be doing so well while many others are enduring hard times. But again, the question has to be asked: how much, if any, of this cash will HMRC ever recover? Certainly, HMRC has identified its targets. But whether we talk about the foreign-owned companies and their £11 billion or the business big hitters
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and their £400 million, the issue is not a straightforward one. In both cases, it will prove to be the case that any payments or earnings have been structured and arranged so that they are liable for only the minimum tax. What we are talking about may not break the law even if it tramples all over the spirit of it. Yes, some cases may prove to be illegal and give the tax man an easy conviction and a welcome cash windfall if all goes to plan. Others may clearly be legal, while a third group may occupy a rather vague legal area. Such distinctions not only make HMRC’s work more time consuming, they also offer few guarantees regarding any likely outcome. For example, looking at how Starbucks sold nearly £400 million of goods in the UK last year, we see how it legitimately avoided paying any corporation tax at all. It transferred money to a sister company in the Netherlands in the form of royalty payments, bought its coffee beans in Switzerland and paid high interest rates to borrow money from other parts of the business. Such elaborate schemes ensure that tax avoidance is not only legal but also difficult for HMRC to “get to the bottom of’’.
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Things, however, may change. The Treasury has said it will give HMRC £77M to help it track down wealthy individuals and companies that are doing their utmost to avoid paying tax. The Chancellor has also talked of introducing an anti-avoidance rule and of teaming up with other G8 countries to stop the practice. And, of course, there is now the COP9. COP9 is the letter sent to a person to let them know that their tax payments are being investigated. Its name comes from the fact that the letter indicates that the investigation is being carried out under Code of Practice 9. When writing to someone, HMRC offers them three options: Disclosure – where someone can accept that they have committed a tax fraud and can state that they want to enter into a Contractual Disclosure Facility (CDF) contractual agreement with HMRC, whereby they disclose the full extent of their tax wrongdoing. Denial – where a person can deny they have committed tax fraud but states that they will co-operate with the HMRC investigation.
Non-co-operation – where a person denies committing tax fraud and refuses to co-operate with the COP9 investigation. For HMRC, COP9 could become an increasingly useful weapon against the suspected tax avoiders mentioned earlier in this article. This is because it gives both hunter and the hunted a degree of lee way. If an individual or company agrees to go down the disclosure route, HMRC will give an undertaking that it will not pursue a criminal tax investigation with a view to prosecuting over the tax frauds disclosed. A civil monetary settlement is agreed instead of a criminal penalty. By offering such an option, a COP9 can be a useful negotiating tool for any HMRC investigator looking to gain a full and frank picture of someone’s tax affairs. For the person under suspicion, it offers the chance to avoid a criminal punishment and a lengthy investigation while also allowing them to make a clean breast of things. If a person chooses the denial option then HMRC can still begin a criminal investigation into the taxpayer’s affairs, with every possibility that it could lead to a prosecution. It is not obliged to tell the person that it has begun such an investigation – the person’s denial letter - -
can even be used in evidence against them. By choosing the non-co-operation option, HMRC begins a criminal investigation, obtains information about the person’s financial affairs from third parties, raises tax assessments and is likely to charge much higher penalties than those likely to be imposed under the disclosure option. As HMRC decides how to target those it suspects of underpaying tax in 2013, it will surely see the COP9 as one of its best weapons. COP9 investigations are usually carried out by HMRC specialist investigations staff, who are the ones used when it is believed that large amounts of tax have gone unpaid. With HMRC itself now coming out and saying who it suspects of not paying the tax it must surely only be a matter of time before the COP9 becomes the weapon of choice for the tax man in this coming year.
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NOT SO SECRET AGENTS It has been announced with great fanfare that the National Crime Agency is to swing into action in 2013. But what will it mean for the investigation of economic crime? And will it lead to any changes in the way prosecutions are brought?
There cannot be any doubt that the arrival of the National Crime Agency (NCA) is a major event. Home Secretary Theresa May has called it a landmark moment in British law enforcement. The NCA will oversee economic crime, as well as organised crime, border policing and child exploitation. To say it will have a lot on its plate is a major understatement. It is being created to police four of the biggest, most highprofile areas of crime in the UK and will also house an intelligence hub that will gather, store, process and analyse mountains of operational intelligence. Fraud alone is estimated to cost the UK £73 billion each year, which gives you an indication of the scale of the economic crime quarter of the NCA’s workload. If all goes to plan, the NCA will be fully operational by December this year. Its supporters point to the value of having
a single national intelligence snapshot of organised criminals, a national coordinated response to various threats and an organisation capable of working with a variety of law enforcement partners. The emphasis seems to be on the NCA building two-way relationships with police forces, law enforcement agencies and other partners who have knowledge that could be of use in the aforementioned four crime areas that the NCA will focus on. The intelligence hub and a national cyber crime centre – that will provide expertise, support, intelligence and guidance to police forces and the NCA – are expected to boost serious crime investigation in the UK. Keith Bristow, who has been appointed as first NCA Director General, has spoken in the strongest terms of bringing people to justice and of - -
disrupting their behaviour and taking their assets off them. As solicitors specialising in economic crime, Rahman Ravelli awaits with interest to see how the NCA works with existing organisations that operate in this field. It is known that the functions of SOCA (the Serious Organised Crime Agency) are being merged with the NCA. The emphasis is being put on less fragmentation between and within crime-fighting organisations. This is based on the argument that a more “joined up’’ approach will enable specialist agencies to take on more and larger cases; with the NCA providing the extra support they may need. Much of the thinking behind the NCA is based on the strong links between the four sectors of crime that it will investigate. In making the link between economic crime and organised crime, NCA believes it can make best use of co-ordinated resources
www.rahmanravelli.co.uk The NCA is a grand-sounding step into the future. It is the government’s attempt to grasp the nettle presented by some of the most serious criminal issues affecting the UK. Keith Bristow is making rousing statements about its intentions and its goals. It looks like plenty of resources are to be poured into it to make it an effective weapon in the government’s on-going battle against serious crime. But while December 2013 may seem a long time in the future, in reality it is only 12 short months for the government and all other interested parties to put into place everything that needs to be absolutely spot-on before the NCA opens for business. to ensure all relevant agencies work with it rather than to their own agenda. The Serious Fraud Office (SFO), Financial Services Authority (FSA), Office of Fair Trading (OFT) and the National Fraud Intelligence Bureau of the City of London Police will all work alongside the NCA. What has not really been explained, however, is what difference there will be on a day-to-day basis. So far, the talk and the briefing documents have centred on the reasons for the NCA: why it is needed, why it will be better than what has gone before, who it will work with. There has been little information published openly about exactly how everyone will work together and with this impressive new organisation. Such a point is an important one. In creating
the NCA, there has been an admission that organisations have often worked in isolation rather than in tandem, which has not always been the most productive approach. The NCA is supposed to be about strong, two-way links between it and other law enforcement agencies but there has been little explanation beyond such phrases. In such relationships, the devil is very often in the detail. For example, the SFO works in a different way to many other agencies in economic crime. So will it have to tailor its working methods to dovetail with what the NCA will be trying to achieve? Or will it be able to carry on working in the same manner that it does currently? And, if the latter is the case, then what exactly is the point in creating the NCA, after all?
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If the NCA is set up, funded and aligned with its partners in the right way, it could well become a major winner in the war in crime. But if it arrives having not been fully thought out, unsure of its standing among its partners and with the partners themselves not clear of their responsibilities, it could lead to even greater fragmentation of the government’s approach to tackling crime. At present, the NCA is a plan for a bold, all-encompassing attempt to lay waste to the serious criminal activity that exists in the UK. Between now and December, that blueprint has to be taken off the printed page and made a reality. Get it right and the rewards will follow. Get it wrong and it has to all go back to the drawing board.
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