Who is this guidance for?
The guidance on this page is for leaders, Local Counter Fraud Specialists, those staff working in NHS procurement, finance, and payroll teams, particularly those responsible for setting up bank account details and processing bank payments. The guidance provides awareness to senior managers and staff of mandate fraud and Chief Executive Officer (CEO)/payroll email fraud during the COVID-19 pandemic.
What are the risks?
Whilst the NHS and Government’s response to the Covid-19 pandemic is evolving, we know that criminals will take advantage during times of crisis. The NHSCFA’s immediate concern is the urgency placed on paying suppliers within seven days (instead of the usual 30) as well as the surge of new staff joining the NHS workforce as part of the response to COVID-19. It is important that managers and staff remain vigilant as ever when paying suppliers and staff during this time, as analysis indicates that vulnerable periods – such as the COVID-19 pandemic – are more at risk for mandate fraud to occur in the NHS.
What is mandate fraud?
Mandate fraud occurs when someone contacts an NHS organisation with an urgent request to change a direct debit, standing order or bank transfer mandate, by purporting to be from a genuine supplier that regular payments are made to. During the COVID-19 pandemic, the urgent nature of such requests is likely to appear more pressing and convincing. If the organisation accepts the fraudulent request, the payments are then diverted into the criminal’s bank account. The genuine supplier details are usually obtained from a range of sources including corrupt staff, publicly announced contracts and online logs of supplier contracts.
CEO/payroll email fraud
CEO/payroll email fraud is another form of mandate fraud whereby the fraudster requests changes to payroll bank account details. This type of fraud typically occurs when an email is sent to an NHS organisation from a criminal purporting to be the organisation’s CEO or a senior director with instructions to change bank account details of the person they are impersonating. The criminal will request that funds are transferred as a matter of urgency to the alternative bank accounts. The member of staff receiving the email will feel pressured to comply due to the apparent seniority of the sender and urgent nature of the email. During the COVID-19 pandemic, the urgent nature of such requests is likely to appear more pressing and convincing.
How to spot mandate fraud
Mandate fraud can occur in different ways, here are some methods to be aware of:
- A telephone request is received where the caller is suggesting some urgency in making a change to a supplier’s bank account details.
- An email request is received from an unknown email account that is not recorded on the NHS organisation’s records.
- An email is received where a minor amendment has been made to the sender’s address details, giving the impression it is a correct and genuine contact email address at first glance. For example, the genuine address is Joebloggs363@mail.com but the fraudulent email came from Joebloggs36@mail.com. Staff should always check the authenticity of an email received from a supplier (e.g. the domain name) by using established supplier contact details already held on file.
- A written request is received in the form of a letter or invoice that does not contain the supplier’s logo or the logo may be less sharp or slightly blurred (this would most likely be a scanned copy of an original document which has been counterfeited).
What should you do?
Controls that mitigate the risk of mandate fraud should be documented in a policy and standard operating procedures (SOPs) and staff should be trained on identifying and reporting any risks and breaches. Without proper controls, NHS organisations are at risk of unintentionally paying a supplier’s invoice or staff salary into a criminal’s account.
The following controls should be in place:
- NHS organisations should periodically confirm supplier information held on file, including previous bank account details, registered address, email address, company registration number, company VAT number or the name of the company secretary.
- When contacting a supplier this should be done using the supplier’s contact details found in existing records held by the NHS organisation and not from information supplied in a change request.
- If there should be a need to amend bank account details, suppliers should be sent a bank account amendment form for their finance director or company secretary to sign, confirming the change of bank account details. Information provided on the amendment form should be checked against the health body’s existing records before any change is made.
- A senior member of the finance team should always review any change of bank account details and formally authorise this.
- All staff should be aware of and adhere to internal procedures and controls to minimise the risk of losses to this type of fraud.
- There should be a segregation of duties and an appropriate level of access with respect to accessing invoice processing tools in payment systems.
- Staff should be vigilant for invoices related to office supplies as this is a known high-risk area relating to reported mandate fraud in the NHS.
- A dual control procedure for authorising payments should be implemented.
- Staff should be vigilant during the months of August and December and during vulnerable periods – such as the COVID-19 pandemic – as analysis indicates these are vulnerable periods for mandate fraud to occur in the NHS.
- It is very important to maintain the organisation’s processes around fraud prevention and treat it as a ‘business as usual’ activity.
- Staff should be clear about when and where to report all incidents or threats of mandate fraud.
- Staff should be trained on social engineering techniques that can be used by an attacker to commit mandate fraud (social engineering is the psychological manipulation of people and systems into divulging confidential information and performing actions that they otherwise wouldn’t).
The signs of how to spot and preventative advice on how to stop CEO email fraud are very similar to those in mandate frauds. It is important that payroll staff are acutely aware of these risks when administering employee payroll banking account information.
If you suspect mandate fraud
- If a call from an alleged supplier seems suspicious, hang up and call the supplier organisation using established contact details held on the NHS organisation’s records.
- If you suspect that a mandate fraud has occurred, the organisation’s escalation process should be followed and immediate action is crucial and may prevent any actual loss of NHS funds. Staff must act immediately by alerting their Local Counter Fraud Specialist (see also how to report fraud below) and the following actions must be taken:
- Your organisation’s Local Counter Fraud Specialist or Director of Finance should contact the targeted NHS organisation’s bank advising them of the suspected mandate fraud in action.
- The NHS organisation's bank should be instructed to contact the bank of the suspect account where the fraudulent transfer of NHS funds have been made to.
- An immediate freeze on the funds should be requested.
All fraud whether suspected, attempted or successful should be reported to NHSCFA.
Please see the NHSCFA’s wider advice on the prevention of procurement fraud on our Guidance page. You can also find more information and definitions for the different types of procurement fraud affecting the NHS in the NHS Fraud Reference Guide.
The video below shows an example of a mandate fraud stopped by the quick thinking of an NHS staff member.
Stop fraud in its tracks
This animation shows an example of a mandate fraud (also known as payment diversion fraud) stopped by the quick thinking of an NHS employee, to support a wider message on fraud prevention.
How to report fraud
Report any suspicions of fraud to the NHS Counter Fraud Authority online at https://cfa.nhs.uk/reportfraud or through the NHS Fraud and Corruption Reporting Line 0800 028 4060 (powered by Crimestoppers). All reports are treated in confidence and you have the option to report anonymously. You can also report fraud to your nominated Local Counter Fraud Specialist.