ABSTRACT
This chapter discusses the issues of economic crime and regulation from the standpoints of the United Kingdom (UK), the United States (US) and Australia to identify areas where UK practice can be improved or, alternatively, where the US and Australia might recognise advantages in a UK approach. The UK has a number of agencies that may either investigate or prosecute fraud but the only agency with a specific role for fraud is Serious Fraud Office (SFO). The SFO is the prime UK agency for investigation and prosecution of bribery and corruption. The US has demonstrated its commitment to combating fraud by establishing Financial Fraud Enforcement Task Force (FFETF), with '$330m to investigate any suspected instances of mortgage fraud and to pursue any potential prosecutions that arise from those investigations'. Fraud in Australia is criminalised by individual states and territories under a variety of property offences such as 'theft and obtaining a financial advantage by deception', together with 'conspiracy to defraud'.
