Interview with Alan Bryce

Last updated: February 25, 2022
Categories: Interviews

Interview with Alan Bryce

Last updated: February 25, 2022
Categories: Interviews

Tell us a little bit about yourself, the roles you have held in countering fraud and your current position?

I am currently a non-executive director of the Tenancy Fraud Forum; a not-for-profit organisation bringing together social housing providers to identify and share best practice in tackling tenancy fraud.

My previous roles have been primarily in relation to tackling public and charity sector fraud. From 2011, I was Head of Counter Fraud at the Charity Commission, focusing on local government fraud in England. I held that role up until late 2014. It was during this time I first became interested in tenancy fraud, then a little-known fraud threat. At the Audit Commission I led the team that researched and published the annual series of reports on local government fraud, called Protecting the Public Purse. It wase, and as far as I am aware still is, the only publication for any sector in the UK which included information on 100% of all detected frauds by that sector. I would argue this brought a degree of transparency and accountability not available elsewhere. It was also during this time that I helped establish, along with a few colleagues, the Tenancy Fraud Forum. I am proud to say that the TFF is celebrating its’ 10-year anniversary this year.

During this time, I also studied for an MSc in Counter Fraud & Counter Corruption at the University of Portsmouth. My dissertation on the Nature and Scale of Tenancy Fraud, was the first and still is, the only academic study of its kind researching tenancy fraud in the UK.

At the Audit Commission, I was also the national lead for the Changing Organisational Cultures toolkit, a product designed to help organisations increase fraud awareness and raise ethical standards in the public sector. The toolkit was subsequently recommended for UK wide use in the 10th report by the Committee on Standards in Public Life.

From 2015 to 2020 I was employed by the Charity Commission for England & Wales, later becoming Head of Counter Fraud & Cybercrime. This also included a period as Head of Intelligence. I established and chaired the Charities Against Fraud group and, in partnership with Fraud Advisory Panel, created and delivered the award-winning International Charity Fraud Awareness Week.

In addition to the above, I had 2 secondments to the National Fraud Authority; was a member of assorted working and an external advisory for groups including the Cabinet Offices’ National Fraud Initiative, the Government Counter Fraud Profession, and the British Standards Institute code of practice on whistleblowing and anti-money laundering.

Before joining the Audit Commission, I served 3 years as a police officer in Glasgow, moving to London in the early 90’s to train as an auditor with the Audit Commission.

What originally drew you to the counter-fraud industry?

I first became involved in the counter-fraud industry while training as an auditor with the Audit Commission. At the time they employed some former police officers, but none as auditors. The Commission viewed my police experience as providing a different perspective on fraud related issues and thus encouraged me to focus increasingly on counter fraud related activities and initiatives. During this process, I was very lucky to have been mentored by a District Auditor, who himself had a strong interest in counter fraud.

How has the industry changed since you started?

Cyber is the big change. The vast majority of fraud, especially in my later years, tended to be cyber enabled in one way or another.

What do you see as the single biggest fraud threat to the UK economy and why?

Complacency, mixed with still relatively low levels of fraud awareness. Unfortunately, both members of the public and many organisations still do not deploy sufficient “scepticism” in their everyday activities and transactions to minimise the threat they face from fraudsters.

In relation to social housing fraud, the issue is potentially even more stark. Although many of the councils and housing associations I deal with are very effective in tackling this type of fraud, I would argue that many social housing providers, perhaps even the majority, do little if anything to effectively tackle tenancy fraud. This is due to a level of complacency about the threat that, in some cases, borders on wilful blindness.

If you could introduce one new policy to the TFF’s counter fraud role, what would it be and why?

What I think would make the biggest immediate difference, which we at the Tenancy Fraud Forum champion that we ourselves are not set up to deliver, is to collect and publish tenancy fraud detection performance by all social housing providers – councils and housing associations. Both the government and the housing regulator have a key role in achieving this goal. Sadly, despite government assurances at the time the Audit Commission was closed down, since 2014, no organisation collects and publishes information on 100% of tenancy fraud detected by councils. Perhaps even more incredibly, such information on tenancy fraud detection has never been collected and published in relation to housing associations. Increasing transparency in relation to detection acts as a spur to greater action and helps hold accountable those responsible for poor performance.

What has been your greatest achievement when countering fraud?

Probably helping put the scale and harm caused by tenancy fraud into context with other fraud types. When I first looked at the issue in 2009, there had been no academic or professional research ever undertaken to identify the level of tenancy fraud. The National Fraud Authority later accepted my dissertation findings that “at least 100,000 social homes in England are subject to some form of tenancy fraud”. By the time the National Fraud Authority published its’ final Annual Fraud Indicator in 2013, tenancy fraud was accepted as the second highest area of fraud loss in the public sector, even exceeding housing benefit at that time.

Looking ahead, what do you see as the greatest challenges facing the counter fraud community in their fight against fraud?

If there is one area of counter fraud that we as a community should look to focus on more, it is finding an agreed way to value fraud prevention. Time and again I hear about organisations not investing sufficiently in prevention activities. Switching some counter fraud resources towards prevention activities has the potential to achieve significant savings and reduce harm, we just need an agreed way to quantify that.

With the benefit of hindsight, is there anything you wish you could have done differently when implementing counter fraud strategy/procedures?

For tenancy fraud, I wish all detection data by social housing providers is made publicly available. When the Audit Commission was closed down nearly 7 years ago, the government did not provide the necessary powers to any organisation to continue the requirement of councils to provide all information on fraud detection by their respective organisations. As a result, today, barely a fifth of councils volunteer such information, meaning the poor performers are not being effectively held to account. Although I argued at the time for such powers to be provided, I greatly regret not doing so more forcibly or persuasively. I believe that potentially tens of thousands more families are in temporary accommodation now than would otherwise be the case because tenancy fraudsters continue to occupy properties they should not be in. Those families in temporary accommodation are the real victims, and social housing providers who do not play their part in tackling tenancy fraud are not being held accountable.