Earlier this week, we held our Tackling Fraud in Social Housing Conference. Our in-house fraud experts and a number of external speakers delivered a 360 degree look at fraud in the social housing sector. We covered topics including how best to protect your organisation, responding to a fraud or cyber-attack, tenancy fraud, and whistleblowing investigations.
We have collated our five key takeaways below:
- Failure to Prevent Fraud is on everyone's lips this year as we count down to the implementation of the new corporate criminal offence on 1 September 2025. On paper, it is a very significant threat to unprepared organisations, both individual corporate entities and groups that in aggregate meet the requisite thresholds of a 'large organisation'. Recently issued Government guidance gives a steer as to what is required in order to obtain the defence of 'reasonable procedures', but organisations will need to grapple with the sticky question of who within or outside their organisation amounts to an 'associated person'. A well-documented risk assessment, along with robust policies and procedures, will be critical in mitigating exposure to prosecution.
- Cybersecurity made the Sector risk profile again at the end of last year with the Regulator noting that, in addition to risking breaching legislation (and potentially significant ICO penalties), failure to adequately ensure the security of data may also result in breaches of the regulatory standards. We discussed steps you should be taking such as training, policies/procedures, supplier due diligence and ensuring adequate contractual protection. In addition, we looked at key steps when faced with a cyber-attack.
- It is imperative that RPs have robust and agile internal controls to identify risk and existence of fraud in every form that it comes in. Boards must seek evidence based assurance to satisfy themselves that this ever evolving issue is being properly dealt with, and know when to engage with the relevant Regulators.
- Tenancy fraud can come in many different forms, to include unlawful subletting, fraudulent housing applications and right to buy fraud. It's important to tackle tenancy fraud and to publicise wins to deter tenants from engaging in tenancy fraud. Staff at various levels should be trained to recognise and detect tenancy fraud, particularly those visiting homes, with accurate records being kept. Your case is only as good as the evidence presented at Court!
- Whistleblowing is a key tool organisations can use to detect fraud and, in particular, can bring to light concerns about improper and unlawful relationships between employees and suppliers which might otherwise go undetected.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
