An inspection of the London regional response to serious and organised crime

Introduction

About our inspection

As part of our police effectiveness, efficiency and legitimacy (PEEL) inspections, we inspected how well police forces tackle serious and organised crime (SOC). In 2022, we changed how we inspect this aspect of policing, to incorporate inspections of the ten regions, as well as the nine regional organised crime units (ROCUs) throughout England and Wales, and the 43 police forces. This improves our understanding of how well forces and ROCUs work together to tackle SOC.

About us

His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) independently assesses the effectiveness and efficiency of police forces and fire and rescue services, in the public interest. In preparing our reports, we ask the questions that the public would ask, and publish the answers in an accessible form. We use our expertise to interpret the evidence and make recommendations for improvement.

About our report

This report includes sections on the following:

• Regional findings – a summary of inspection evidence that identifies good or poor performance within the region; in other words, involving or relating to the ROCU and constituent forces. The performance of the region is not given a graded judgement. Instead, we highlight areas for improvement, causes of concern, good practice and innovations in this section, where applicable.
• The ROCU and individual forces – the ROCU and each individual force are given a graded judgment, with a summary of the findings from our inspection and highlighted sections for areas for improvement, causes of concern, and innovative and promising practice.

About ROCUs

Each ROCU serves between three and seven constituent forces (see map in Appendix 1).

The Strategic Policing Requirement (SPR) defines ROCUs as:

The primary interface between the NCA (National Crime Agency) and policing, supporting the co-ordination and tasking of the collective effort against the serious and organised crime threat.

The Government’s 2018 SOC strategy states that ROCUs should:

Lead the operational response to serious and organised crime on behalf of forces within their regions, taking tasking from the NCA on national priorities, and working together in a more networked way, allowing capacity and capability to be shared where appropriate.

Police forces should work closely with ROCUs, following the objective set out in the national Serious and Organised Crime Strategy to achieve a ‘whole system’ approach to tackling SOC. ROCUs provide a range of specialist capabilities to forces. These include the regional organised crime threat assessment units (ROCTAs), surveillance, undercover policing, sensitive intelligence units, regional asset recovery teams, cybercrime teams, the Government Agency Intelligence Network (GAIN), prison intelligence units and others.

ROCUs are set up under collaboration agreements (made under section 22A of the Police Act 1996) between the chief constables and police and crime commissioners (PCCs) in each region. ROCUs are not statutory bodies. They rely on forces to supply the administrative and support functions they need, including human resources, finance and IT. As a result, each ROCU is set up differently, under different terms of collaboration.

Each ROCU’s financing is largely provided by chief constables and PCCs, with additional financing from the Home Office. In each region, forces negotiate their financial contribution to the ROCU.

Changes to how SOC threats are managed nationally

Our previous PEEL inspection reports have referred to how well forces have managed and mapped or assessed organised crime groups (OCGs).

In this report, we refer to SOC threats, which encompasses OCGs, SOC priority individuals and SOC vulnerabilities.

This reflects changes introduced nationally in response to the SOC strategy’s goal to provide a “single picture of demand”. This has been achieved by establishing a national database of SOC threats, which holds information from the NCA, ROCUs, police forces and government agencies that tackle SOC. This database is referred to as the SOC master list and is used to assess which SOC threat is a priority for each agency or force.

Terminology in this report

Our reports contain references to, among other things, ‘national’ definitions, priorities, policies, systems, responsibilities and processes.

In some instances, ‘national’ means applying to England and Wales. In others, it means applying to England, Wales and Scotland, or the whole of the United Kingdom.

Regional findings

The approach to tackling organised crime in the London region differs from every other region in England and Wales. The three forces that operate across the Greater London area are the Metropolitan Police Service (MPS), the City of London Police (CoLP) and British Transport Police (BTP).

The London region doesn’t have a ROCU. Instead, each force maintains its own set of specialist capabilities to tackle organised crime. This means that the forces don’t share all the specialist regional policing capabilities that ROCUs have to tackle organised crime, except one joint unit, the regional organised crime threat assessment (ROCTA) unit.

BTP is the police force responsible for policing the railways of England, Wales and Scotland. The force therefore transcends local and national borders. BTP differs from most police forces in several ways. Firstly, it falls under the remit of the Secretary of State for Transport, and not the Home Secretary (as do forces in England and Wales) or the Cabinet Secretary for Justice (those in Scotland). Secondly, the force is funded almost entirely by the rail transport industry through police service agreements with the British Transport Police Authority.

The CoLP is responsible for policing the City of London, which is one square mile in area. It has a small residential population, but over 500,000 workers commute into the city daily and there are a further 18m visitors annually. The force has a dual role: providing a local service in the City of London and tackling fraud and cybercrime nationally.

The MPS is the largest police force in the country with over 43,000 personnel. The threat from organised crime confronting the force is substantial. As of 4 July 2022, it had identified 266 SOC threats, the highest for any force in the country and 7 percent of the total for England and Wales. It has considerable resources to tackle SOC.

The organised crime challenges faced by BTP and the CoLP are different from those dealt with by the MPS. They both have small residential communities and temporary and diverse populations resulting from many daily visitors and service users.

Retaining specialist staff across the region is challenging

It is difficult for the forces in the London region to retain specialist staff such as financial investigators and analysts. Employers in the private sector frequently offer better terms and conditions than policing can. While this situation isn’t unique to the London region, London forces do appear to suffer more acutely, especially the MPS. We have highlighted these staffing pressures in the individual force sections that follow.

British Transport Police

British Transport Police is adequate at tackling serious and organised crime.

Understanding SOC and setting priorities to tackle it

BTP has an established process to identify its priorities, including SOC

BTP faces a distinct challenge from SOC, compared to other forces across England and Wales. It generally tackles groups and individuals that target its infrastructure or use the rail network to carry out their criminality, rather than those that reside in a geographical area.

The force has a strategic assessment and an associated control strategy. These establish the current priorities as:

• terrorism;
• modern slavery and human trafficking;
• robbery;
• sexual offences;
• serious violence and weapons;
• death and serious injury on the railway; and
• football violence.

The force also identifies several common themes across these priorities:

• safeguarding and vulnerability
• organised crime groups
• prolific and high-harm offenders
• exploitation.

SOC threats relate to county lines or organised acquisitive crime

As of 4 July 2022, BTP had identified 22 SOC threats. Of these, 10 related to county lines (of which 5 related to drug supply and 5 to modern slavery and human trafficking) and 12 related to organised acquisitive crime (such as theft, robbery or burglary).

Organised acquisitive crime includes the theft of metal (for example, cables from the rail network), robbery, theft from motor vehicles, theft of motor vehicles, theft from persons, theft from cash machines and skimming thefts (involving secretly scanning a payment card to obtain its information).

The theft of metal from the rail network poses a risk to critical national infrastructure and therefore is a high-threat area. This type of theft costs the Government, and taxpayers, millions of pounds each year. It can disrupt rail travel across the country and put lives in danger. At the time of our inspection, we felt that the force could do more to prioritise this threat. The force told us that, as of January 2023, metal theft has been added as a control strategy priority.

Considering the rail infrastructure and geographic coverage of the force, we were disappointed to find BTP hadn’t identified any SOC vulnerabilities, for example, locations where metal theft is frequently occurring or payment kiosk sites that are repeatedly targeted by fraudsters.

Frontline officers and staff have an inconsistent understanding of SOC threats

We found that several different IT systems were being used to inform frontline officers and staff of current SOC threats. This meant that these personnel had an inconsistent understanding of these threats. The force highlighted to us that they are trialling a geographically based briefing system. One option for the force is to use it to brief the workforce on SOC threats.

BTP can access information from partners to develop its understanding of SOC threats

The force has effective information-sharing relationships with the train operating companies, who are its primary partners. The companies are aware of the importance of identifying and safeguarding vulnerable people.

As explained at the start of this section, BTP doesn’t have OCGs resident in its area. This is because its area includes only the railway itself and associated infrastructure (such as ticket offices and concourses), as opposed to the large areas covered by the other forces across England and Wales. We were pleased to find examples of BTP contacting police forces to request access to intelligence about OCGs in those forces’ areas, for instance, an operation tackling an OCG that was targeting cash machines to steal money.

Resources and skills

We found that generally the force had sufficient personnel and resources to tackle the level of SOC threat it faces. However, in some areas we believe the way they are used could be improved. This is especially true in the deployment of covert teams across the country.

BTP has invested in combatting county lines drug dealing

The force has secured funding from the Home Office and invested in resources to tackle county lines drug supply. There are six county lines teams spread geographically across the country. Each team has a social worker with expertise in third sector support through The Children’s Society. These social workers are focused on safeguarding vulnerable individuals identified in investigations.

Tackling SOC and safeguarding people and communities

BTP has effectively targeted OCGs and disrupted drug-related SOC

We found several examples of the force using a variety of methods to effectively target OCGs. In one investigation, £2.5m worth of property was stolen from a depot alongside the railway. An investigation lasting over 12 months identified the offenders and recovered the stolen property. The senior investigating officer used a range of covert and overt tactics to achieve this success.

In the year ending 30 June 2022, two thirds of recorded SOC disruptions involved a threat of drugs. This reflects the force’s focus on tackling county lines drug supply and the fact that it has the specialist teams to do so.

BTP needs to improve recording of SOC disruptions

BTP has made improvements in how it records SOC disruptions, but more could be done. In the year ending 30 June 2022, the force recorded 184 disruptions compared with 34 the previous year, representing a substantial increase. Virtually all these disruptions were designated as pursue events. Personnel suggested to us that some disruptions were still not being recorded and that they were aware that virtually all were pursue activities.

The force explained that national standards don’t allow the recording of a pursue disruption at the same time as a prevent disruption, for example, if a county lines drug dealer is arrested and then subsequently safeguarded. This is true and provides some context. However, in line with other forces, BTP should do more to identify and record non-pursue disruptions.

BTP identifies safeguarding concerns during its investigations

Generally, the personnel that we spoke to displayed a good understanding of safeguarding. They explained that it was a force priority and were able to give examples of where people had been safeguarded. These included using staff from St Giles Trust to support victims during county lines investigations.

We found evidence of the national referral mechanism being used to support those being exploited by criminal gangs. Since the county lines teams were set up in 2019, they have secured 20 charges for human trafficking and modern slavery offences. The presence of two full-time members of staff from children’s services has helped the teams to support young people and reduce the risk of them becoming involved with OCGs.

BTP has provided cyber awareness training for rail companies

The cyber investigation team has developed a campaign called ‘think before you click’ for rail staff. This is to help prevent them from becoming the victims of cybercrime or making companies vulnerable to attack. There has been positive feedback from staff about this training. Unfortunately, none of this work appears in the disruption figures for BTP, but there may be an opportunity to learn from the CoLP, which has been effective at recording disruptions in this area.

The City of London Police

The City of London Police requires improvement at tackling serious and organised crime.

Understanding SOC and setting priorities to tackle it

The CoLP is the national lead force for fraud. It receives approximately £30m per year from the Home Office to provide this function. It co-ordinates prevention and investigation of fraud and cybercrime activity with private industry and law enforcement partners nationally.

In July 2022, the CoLP had identified 43 SOC threats. Thirty-three of these threats were classified with a primary crime type of fraud. The force has experienced difficulties in gathering intelligence from the business community regarding non-fraud crime types.

The CoLP has defined priority threats from organised crime, and its control strategy highlights the main fraud issues

The force has prepared a strategic assessment and associated control strategy. The following are defined as their priority threats from organised crime:

• illicit financing and money laundering
• drugs
• modern slavery and human trafficking
• intellectual property crime.

There is a separate section in the control strategy covering fraud, highlighting the main issues. Specialist teams such as the dedicated card and payment crime unit have been developed to tackle specific threats.

Resources and skills

The CoLP should make sure it has sufficient intelligence staff to effectively analyse the threats it faces

We found that resourcing issues were hampering the force’s approach to SOC in several areas:

• A theme common to this inspection and the force’s last PEEL inspection is the lack of available analysts.
• The intelligence department aims to provide around-the-clock support but is only able to provide cover until 10pm.
• The sensitive intelligence unit is operating with one supervisor and one analyst. This limits its effectiveness and provides little resilience.
• The force has one member of staff in the ROCTA. Their effectiveness is limited by having no access to intelligence in other regional forces. There is no backup to cover this role.

As the national lead for fraud, the CoLP hosts some specialist resources

The force hosts some specialist anti-fraud resources. These include the following:

• The insurance fraud enforcement department is a unit funded entirely by the insurance industry to combat fraud.
• The police intellectual property crime unit is the country’s only dedicated intellectual property crime unit, funded by a direct grant from the intellectual property office.
• The dedicated card and payment crime unit is a team run jointly by the CoLP and the MPS. It is funded by the banking industry, with the sole purpose of combating crimes associated with banking payments.

Additionally, the CoLP hosts the national fraud and cybercrime reporting centre. This is critical to supporting the approach to these two crime types. The force also co-ordinates regional fraud resources based in the nine ROCUs across England and Wales, through the funding it receives from the Home Office.

Tackling SOC and safeguarding people and communities

The CoLP is effective at conducting investigations

We saw examples of effective investigations that had achieved significant results. These included:

• a money laundering investigation that identified a professional enabler and a subsequent account forfeiture order for €34m; and
• the disruption of a drug trafficking crime group that was using hotels and Airbnb accommodation to supply controlled drugs.

The CoLP works with partners to share information and protect communities from fraud

The CoLP, through its role as national lead force for fraud, is responsible for routinely sharing information locally and nationally to protect communities from SOC. This is done alongside the various partners from the financial sector.

One example is its work alongside UK Finance. The CoLP works with a dedicated prevent team that presents webinars to share key messages with the business community to prevent people becoming victims of crime.

The CoLP manages the National Fraud Intelligence Bureau and Action Fraud. These communicate alerts when new threats are identified, to protect the public and business community against new and emerging threats.

The CoLP has personnel dedicated to preventing people from becoming victims of fraud

We saw several diversionary schemes run by the CoLP, consistent with its role as national lead force for fraud. These focused on fraud and the impacts on the local business community. Examples included the following:

• The national economic crime victim unit is part of the National Fraud Intelligence Bureau. The unit focuses on preventing the public from becoming repeat victims.
• The cyber unit has prevent and disrupt personnel dedicated to taking down websites suspected of perpetrating fraud.
• The Insurance Fraud Bureau has dedicated personnel working alongside the insurance industry to develop strategies to prevent insurance fraud.
• The force has developed a project to prevent romance and courier fraud across the UK. It has conducted evidence-based research into these crime types to understand the demographics of the victims. It has then deployed preventative messaging.

The CoLP is working to tackle crime connected with the nighttime economy

Following the pandemic, the force identified a change in the nighttime economy. More staff were working from home and consequently not travelling into the City.

The force has recognised this as an opportunity to tackle crime in the nighttime economy, including those engaged in drug supply. Although in its early stages, this may provide opportunities to understand and disrupt OCGs operating in the City. The force has established Operation Reframe to work with partners, such as the London Fire Brigade, and concentrate on keeping people safe in the City.

In addition, the City of London Corporation, of which the CoLP is part, received funding from the Home Office to introduce a campaign to help prevent violence against women and girls. The force has started to roll out the campaign by training staff in bars and other venues.

Metropolitan Police Service

The Metropolitan Police Service is adequate at tackling serious and organised crime.

Understanding SOC and setting priorities to tackle it

The MPS has a large intelligence gathering capability to assess the threat from organised crime. It produces a control strategy to help the force prioritise the targeting of organised crime threats.

However, we found several areas where the collection of intelligence and information wasn’t as effective as it should be. This means that the force doesn’t always have the best information available to assess the threat and risk from organised crime.

Resources and skills

The economic crime teams can’t meet SOC demand

We have outlined that the economic crime teams have significant resourcing pressures. This means that they can’t meet demand and are missing some opportunities to identify and confiscate criminal assets. Furthermore, the force is potentially losing out on extra funds from selling criminal assets, through the Home Office asset recovery incentivisation scheme.

Financial investigators told us that they had insufficient time to fully investigate all suspects in their assigned cases. In one example, 30 suspects had been arrested for drug supply. The appointed financial investigator could only concentrate on the four top suspects. Because of this, investigators weren’t able to establish whether the other 26 suspects had any criminal assets. In another case, officers identified that at least £7.5m had passed through the bank accounts of an OCG. However, the lack of available financial investigators meant the origin of this money was never investigated.

Officers from Trident teams – the MPS teams that investigate non-fatal shootings – told us that they had stopped asking for financial investigator support because generally none was available.

The MPS has invested in the provision of digital forensics

The MPS has invested in personnel and technology to improve how it investigates crimes involving digital evidence. This includes a new IT system for analysing data recovered from mobile phones, which one investigator described as a “game changer”. We heard from investigators that they had access to good levels of equipment and to trained officers to analyse mobile phones and other digital devices in support of their organised crime investigations.

The use of organised crime advisors has improved how SOC is tackled

The MPS has trained organised crime advisors. These are qualified detectives who can assist with problem-solving and understanding the specialist tactics and resources available to support organised crime investigations. Frontline personnel have welcomed this initiative.

Tackling SOC and safeguarding people and communities

The MPS supports local and national initiatives to tackle SOC

The Home Office has provided the MPS with additional funding to lead national initiatives aimed at tackling SOC. For example, the force led Operation Orochi, working with other forces to tackle county lines drug supply. The force told us that, so far, they have closed 952 telephone lines operated by drug dealers and made over 2,000 arrests. Since 1 April 2022, further Home Office funding has been obtained to expand Operation Orochi to fund a drug task force to dismantle SOC networks across London. Another project supported by funding has seen hundreds of harmful posts removed from the internet. This project also provides key social media intelligence and evidential support to SOC investigations.

The MPS is successful at targeting and disrupting organised crime

We found examples of how the force had successfully targeted and disrupted organised criminals:

• An operation used a wide range of tactics to target three female drug couriers suspected of exporting cocaine to Australia. This resulted in the seizure of large amounts of cash and cocaine, as well as the arrest of the main members of the OCG.
• A large-scale human trafficking operation identified and safeguarded over 300 individuals and disrupted the OCG that had been exploiting them.
• Since 2018, a project to disrupt OCGs has resulted in 261 vehicles, 743 kg of drugs and 15 firearms being confiscated, and £2.4m in cash being recovered. At the time of our inspection, the number of people charged with a drug trafficking offence had risen by 31 percent to 6,784, compared to the previous 12-month period.

The MPS has improved how it records disruptions of OCGs

The MPS has made substantial improvements in the way that it records disruptions of OCGs. In the year ending 30 June 2022, the number of disruptions recorded rose from 4,795 to 8,021. Of these, 78 percent were pursue disruptions, 10 percent were protect disruptions, 7 percent were prevent disruptions and 5 percent were prepare disruptions. However, the force acknowledges further work remains to be done. Most personnel we spoke to understood what was expected of them concerning the reporting of disruptions.

This improvement appears to be due to positive leadership from the deputy assistant commissioner and other senior officers to refocus the workforce on recording disruptions.

The MPS is improving operational support for covert teams

During our inspection, we were told that the operation support rooms in the force could monitor only a limited number of covert operational teams. However, the force has many more covert operational teams, meaning it is likely that at times this support may not be sufficient. In one example we were told of, a firearms commander had to use his personal device to monitor the locations of his teams on a live operation.

The force is working to expand its operational support facilities to allow support for more covert operational teams, so that their activity can be fully and securely monitored and deployed officers kept safe. We welcome these changes.

Safeguarding procedures are generally understood by personnel

Most personnel we spoke to appeared to understand safeguarding procedures and how to access support when required. We found good evidence of safeguarding in crime types such as county lines drug dealing and modern slavery.

Partnership structures appear inconsistent

During our inspection, we found an inconsistent picture of partnership working.

Some areas in the force have well-established partnership arrangements and we saw evidence of effective preventative initiatives being led by partners. These include the Most Valuable Person programme and the Constructive Conversation Programme. Both are aimed primarily at high-harm gang members and are designed to help them make better life choices. Also involved in trying to divert individuals away from the influence of organised crime and county lines drug supply are Project Adder and the Rescue & Response Partnership (including St Giles Trust, Abianda and Safer London).

But in other areas we found little evidence of working with partners to divert people away from organised crime. In 3 of the 12 BCUs, there is an integrated gangs unit, which appears to work well with partners such as youth services. The force should consider replicating this unit to improve partnership working in all BCUs.

The MPS should look to bring consistency to partnership structures and intelligence sharing. It should support this with 4P plans across all organised crime investigations, not just those involving high-harm gangs, county lines or drug supply.

The cybercrime team has developed several initiatives to prevent people from becoming victims of crime

The cybercrime team has visited all 3,200 schools across London and provided a basic cyber awareness package. Additionally, 580 people have signed up for cyber awareness webinars. The team has conducted over 130 presentations to individuals and groups, highlighting the threat from cybercrime.

Appendix 1: Map of regional organised crime units

There are ten ROCUs in England and Wales:

1. The North East Regional Special Operations Unit covers Cleveland, Durham and Northumbria.
2. The Yorkshire & Humber Regional Organised Crime Unit covers Humberside, North Yorkshire, South Yorkshire and West Yorkshire.
3. The North West Regional Organised Crime Unit covers Cheshire, Cumbria, Greater Manchester, Lancashire, Merseyside and North Wales.
4. Tarian covers Dyfed-Powys, Gwent and South Wales.
5. The Regional Organised Crime Unit for the West Midlands Region covers Warwickshire, West Mercia, West Midlands and Staffordshire.
6. The East Midlands Special Operations Unit covers Derbyshire, Leicestershire, Lincolnshire, Northamptonshire and Nottinghamshire.
7. The Eastern Region Special Operations Unit covers Bedfordshire, Cambridgeshire, Essex, Hertfordshire, Kent, Norfolk and Suffolk.
8. The South West Regional Organised Crime Unit covers Avon & Somerset, Devon & Cornwall, Dorset, Gloucestershire and Wiltshire.
9. The Metropolitan Police Service, City of London Police and British Transport Police work collaboratively in the London region.
10. The South East Regional Organised Crime Unit covers Hampshire, Surrey, Sussex and Thames Valley.

There is a separate collaborative arrangement for the London region, incorporating the constituent forces of the Metropolitan Police Service, the City of London Police and British Transport Police. The forces share some ROCU capabilities. For the purposes of this inspection the London region has been inspected, but as it is not conventionally considered a ROCU, it has not been awarded a ROCU grading.

Appendix 2: Data methodology and caveats

The data used in this report was extracted from the national database: the Agency and Partners Management Information System (APMIS).

APMIS contains data that is recorded by police forces throughout England and Wales, ROCUs, the NCA and other organisations (such as HMRC and Home Office Immigration Enforcement).

This data includes:

• The SOC master list, which contains all MoRiLE assessments for the SOC threats identified by forces and organisations.
• Event-based disruption data (‘disruption data’) that is recorded following national minimum standards. At the time of our inspection, minimum standards stipulated that disruption data should only be recorded against organised crime groups, and not priority individuals or SOC vulnerabilities.

MoRiLE assessment data was extracted from APMIS on 1 June 2022 and therefore any changes made to assessments since that date will not be accounted for in the analysis. The following filters were used on columns to extract this data: Type is Tactical, Moderation status is Moderated, SOC is SOC, Tier is not Tier 5 and Phase is not contains closed.

Disruption data was extracted from APMIS in June 2022 and includes all disruptions made after 1 June 2021. The following filters were used on columns to extract this data: Disruption type is Lead Disruption, Record data is greater than 1 June 2021 and Assessment Category is Major, Minor and Moderate.

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An inspection of the London regional response to serious and organised crime