Bounce Back Loan Fraud Risk Assessment

So the Bounce Back Loan Support Scheme could be rolled out quickly, businesses were permitted to self-certify fulfilment of their eligibility criteria as part of the application for a loan and it appears this was considered as part of the overall Bounce Back Loan risk assessment.

The main independent checks conducted when a company applied for a Bounce Back Loan were Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”).

Freedom Of Information Act Request

Oliver Elliot’s CEO, Elliot Green on 19 May 2021 issued a Freedom of Information Act request about the government’s Bounce Back Loan Scheme to attempt to understand the Government’s Bounce Back Loan fraud risk assessment in light of the Public Accounts Committee’s reference to the heightened risk with the scheme.

The following information was sought:

1. Confirmation if BEIS had anticipated heightened risk with Bounce Back Loan Schemes (“BBLS”).

2. Copies of the risk assessment undertaken of fraud with the BBLS was contemplated.

3. Copies of the minutes of meetings that recorded the heightened risk.

4. Details of what was done to mitigate the risk and copies of documents that record that position.

Project April – Fraud Risk Review

The Department of Business, Energy and Industrial Strategy response was received in June 2022 which declined to provide much of this information. However, it did say it had anticipated fraud with the Bounce Back Loan Scheme and a risk assessment undertaken by PricewaterhouseCoopers was sent to the British Business Bank on 29 April 2020.

This was referred to as Project April – Fraud Risk Review from which it can be seen lenders were concerned about the scheme’s potential to be abused:

… by individuals (in distress) with no real business and inactive or dormant accounts …

It does appear the Government was alive to the issue and took it into account in their assessment.

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