Tagged as: US Law

Fraud Lecture

1.0 Introduction and Background

In England and Wales, the law regarding fraud was reformed through the enactment of the Fraud Act 2006, whose principal offences came into force on 15^th January 2007. Prior to this the statutory deception offences were set out in sections 15, 15A, 16 and 20(2) of the Theft Act 1968 and sections 1 and 2 of the Theft Act 1978. The decision for reform arose out of the Law Commission’s Report on Fraud published in 2002 which criticised the law at the time for being too broad and complicated and stated that it was out of date in that offences requiring deception of a person could not cover a transaction carried out entirely by machine.

The Fraud Act 2006 provides one general offence of fraud which can be committed in three different ways:

(i) By false representation

(ii) By failing to disclose information

(iii) By abuse of position.

The Act also created the key new offence of obtaining services dishonestly. Sections 6 and 7 cover possessing articles for use in fraud and making or supplying articles for that purpose, including electronic data. Section 9 deals with fraudulent trading by persons outside section 993 of the Companies Act 2006.

2.0 Fraud

Section 1 of the Fraud Act 2006 provides as follows:

A person is guilty of fraud if he is in breach of any of the sections listed in subsection (2) (which provide for different ways of committing the offence).

(2) The sections are—

(a) section 2 (fraud by false representation),

(b) section 3 (fraud by failing to disclose information), and

(c) section 4 (fraud by abuse of position).

A vital initial point to note is that each of these three ways of committing fraud requires dishonest conduct and the specified intent. It is not necessary for the purposes of the offence that anyone actually be defrauded. For example, say the defendant is selling his blue car and is desperate for a buyer. A potential buyer approaches who tells the defendant they are looking to buy a green car. The defendant believes them to be totally colourblind and tells them that he has such a car and is willing to sell it to them, thus making a fraudulent representation with the intention of procuring a sale of the vehicle. It so happens that the buyer is not colourblind, and is thus not defrauded by the lie. For the purposes of section 1 this is irrelevant; the offence is completed upon the carrying out of the fraudulent act.

2.1 Fraud by False Representation

Section 2 of the Fraud Act 2006 provides,

A person is in breach of this section if he:

(a) dishonestly makes a false representation, and

(b) intends, by making the representation:

(i) to make a gain for himself or another, or

(ii) to cause loss to another or to expose another to a risk of loss.

2.1.1 Actus Reus

Making a false representation

A representation is a statement that portrays and communicates a situation or state of affairs. Section 2(3) provides that the actus reus of the offence covers:

Any representation as to fact or law, including a representation as to the state of mind of—

(a) the person making the representation, or

(b) any other person.

Representations can be made in numerous ways. For example, using the car discussed above, the colour of that car could be communicated, or represented to another person by each of the following means:

Directly verbally communicating it.

Person 1: “I have a blue car”.

Confirming someone else’s assumption of the colour indirectly.

Person 1: “You have a lovely blue coloured car”

Person 2: “Thank you”

Through a silent physical action.

Person 1: “If you have a blue car please stand on the left hand side of the room.”

Person 2: *moves to the left*

By doing nothing.

Person 1 to Person 3: “Person 2 has a lovely blue car”

Person 2: *does not react*

It can be seen from this, albeit slightly ridiculous example, that there is more than one way of going about communicating information or in legal terms, making a representation to others. Section 2(4) of the Act deals with this by setting out that a representation may be express or implied. The express representation being doing or saying something that directly asserts things to be a certain way. In the example above, this would be achieved by the verbal communication and the physical action. The implied representation is made by acting in a way that implies that things are a certain way. In the example above this would be done by saying thank you in return to the compliment about the car. The two words imply acceptance and confirmation of what has been said prior to this. Silence can also convey agreement if, in the circumstances, the person can be understood to have adopted what was said.

In modern times it is not just other people that representations are made to. Increasingly digital communication and machinery are taking over more and more aspects of life, especially information handling. Every time that you, the reader, sign up to a new social media site you are representing to that server that you are the person whose details you are entering, if the site asks for your own details. When you use an ATM you are representing to that machine that you are the owner of the account that you are withdrawing from or that you have permission to be withdrawing from that person’s account. Examples of technological means could be listed at length and accordingly, the Act provides in s.2(5) that for the purposes of the offence a representation may be regarded as made if it is submitted to a system or device designed to receive, convey or respond to communications, with or without human intervention.

Having gained an understanding of what will constitute a qualifying representation for the purposes of the Act it is necessary to consider the requirement that the representation be false. Section 2(2) provides an explanation of what will be considered a false representation, stating that a representation is false if it is untrue or misleading and the person making it knows that it is, or might be, untrue or misleading.

2.1.2 Mens Rea

• Dishonestly;
• Knowing the representation is, or might be, untrue or misleading, and;
• Intending to make a gain, cause a loss, or cause a risk of loss.

Dishonestly

For the purposes of fraud, dishonesty is assessed using the test as restated by the Supreme Court in Ivey v Genting Casinos (UK) Ltd [2017] UKSC 67. Although Ivey was technically obiter on the point of dishonesty in the criminal law, the Court of Appeal in R v Barton [2020] EWCA Crim 575 confirmed that Ivey represents the correct test, effectively replacing the earlier two-stage test in R v Ghosh [1982] QB 1053. The test now asks:

1. What was the defendant’s actual state of knowledge or belief as to the facts? (This is a subjective question.)
2. Was the defendant’s conduct dishonest by the standards of ordinary decent people, judged in light of those facts as the defendant believed them to be? (This is an objective question applied to the defendant’s subjective belief.)

Crucially, under the Ivey test there is no longer a requirement that the defendant must themselves have realised that their conduct was dishonest by the standards of ordinary people. The second limb of the old Ghosh test - which asked whether the defendant knew their conduct was dishonest by those standards - has been removed. This is a matter of fact for the jury to determine.

Knowing the representation is, or might be, untrue or misleading

In order for the representation to be considered false the person making it must know that it is, or might be, untrue or misleading. This requires a subjective understanding on the part of the defendant. Going back to the car scenario from earlier, if the defendant were to for whatever reason honestly believe the car to be green without realising he might be wrong then this will not be satisfied, even though the car was clearly blue.

It is enough that the defendant actually recognised that the representation might be untrue or misleading. It is insufficient that they ought to have recognised that possibility.

Of course it is not sufficient for the defendant to simply say what they believed and for it to be accepted as fact. Their state of mind is a matter of fact for the jury to decide based on an assessment of all of the evidence before them.

Intending to make gain, cause a loss or cause a risk of loss

Section 5 of the Act explains how gain and loss will be interpreted.

Section 5(2) states that gain and loss extend only to gain or loss in money or other property. Property is interpreted widely and means any property whether real or personal and includes things in action and other intangible property such as shares or intellectual property rights.

Unlike the offence of theft, for the purposes of fraud there is no need for an intention to permanently deprive as the gain or loss includes any gain or loss whether it is temporary or permanent. The intended gain need not be for the defendant personally. An intention to make a gain for another person is sufficient for the mens rea.

Section 5(3) expands further and states that gain encompasses keeping what one has, as well as a gain by getting what one does not have; and s.5(4) explains that loss includes a loss by not getting what one might get, as well as a loss by parting with what one has.

As can be seen from the s.5 definition, there is no requirement for a gain to include making a profit and accordingly Attorney General’s Reference (No.1 of 2001) [2002] EWCA Crim 1768 confirms, in the context of false accounting and using a false instrument, that a defendant can intend to gain even where he claims a legal entitlement to the money.

2.2 Fraud by Failing to Disclose Information

Section 3 of the Fraud Act 2006 provides for the offence of fraud by failing to disclose information in situations where there exists a legal duty to disclose information. The section provides that:

A person is in breach of this section if he

(a) dishonestly fails to disclose to another person information which he is under a legal duty to disclose, and

(b) intends, by failing to disclose the information—

(i) to make a gain for himself or another, or

(ii) to cause loss to another or to expose another to a risk of loss.

2.2.1 Actus Reus

• Legal duty to disclose information is in existence; and
• Failure to disclose that information.

Legal duty to disclose

This legal duty to disclose exists for example when applying for non-consumer insurance. Under sections 2 and 3 of the Insurance Act 2015, the duty of fair presentation requires the insured to disclose every material circumstance they know or ought to know, or enough information to put a prudent insurer on notice that it needs to ask further questions. If a person was suffering from advanced cancer this would likely affect any decision or premium payable relating to life insurance. A consumer taking out life insurance must take reasonable care not to misrepresent the facts, for example when answering a question about their health (Consumer Insurance (Disclosure and Representations) Act 2012, s.2). There is no general duty to volunteer every material fact. Similarly, a private seller of a house need not volunteer every defect. If the house is suffering from rising damp and the purchasers ask whether the house is in good condition, a misleading answer could fall within s.2 of the Fraud Act. Liability for silence under s.3 depends on a legal duty to disclose the damp.

It is impossible to list an exhaustive set of situations where this legal duty would arise, however in general a duty to disclose particular information can arise in the following situations:

• Under contract law
• Under certain statutory provisions, for example those governing company prospectuses
• Where the law requires disclosure as part of a transaction of utmost good faith
• From the custom of particular trades
• Under the existence of a fiduciary relationship
• Between professionals and their clients
• When claiming social security

Ignorance of the legal duty is not in itself a defence, but the defendant’s belief about what they had to disclose may bear on dishonesty. The judge decides whether the facts are capable of giving rise to the duty. The jury decides any disputed facts.

A fiduciary relationship is one where a duty of loyalty is owed and exists for example between a director and his company, where the director may have to declare an interest in a proposed transaction with the company (Companies Act 2006, s.177). It also exists between a trustee and beneficiary where a trustee may owe a duty to account to the beneficiary for the trust property.

For more information on the situations where a relationship creating a duty to disclose could arise look into the Law Commission’s Report on Fraud where this concept is explained more fully at paragraphs 7.28 and 7.29.

Note here that this offence is only committed where there is a legal duty to disclose the information. If there is no legal duty, there is no offence under this section. For example, if a person has an interest in mechanics and their friend is buying a car and that person notices something wrong with the car but does not inform the friend, they are not in breach of any legal duty to disclose that information, merely a moral duty. There will be no offence under s.3. If however in this situation the seller of the car offers £10 to the person not to give their opinion to the friend, they may be in breach of s.2 if their conduct goes beyond merely taking the money and dishonestly conveys a representation to the friend that the car is in good condition, knowing that this is not the case, in order to make a gain for themselves.

Failure to disclose the information

This is a situation in English law where the actus reus requires not a positive act, but instead an omission. The defendant does not have to do anything per se in order to fulfil this element of the actus reus; it is completed upon them omitting to provide the requisite information when the legal duty arises.

The scope of the legal duty determines what must be disclosed. If the duty extends only to material information, the omitted information must be material. Accordingly, if the defendant were to disclose 99% of the information legally required of him but failed to disclose a potentially unimportant remaining 1% this could still be sufficient to complete the actus reus of the offence.

2.2.2 Mens Rea

• Dishonestly; and
• Intending to make a gain, cause a loss or cause a risk of loss

Dishonestly

As before, this is assessed by applying the Ivey test.

Intending to make a gain, cause a loss or cause a risk of loss

This is assessed by applying the s.5 provision of the Act in order to assess what a qualifying gain or loss is and then coming to a conclusion as to whether the defendant subjectively intended to make such gain or cause or expose the victim to the loss.

2.3 Fraud by Abuse of Position

Section 4 of the Fraud Act 2006 provides that:

A person is in breach of this section if he—

(a) occupies a position in which he is expected to safeguard, or not to act against, the financial interests of another person,

(b) dishonestly abuses that position, and

(c) intends, by means of the abuse of that position—

(i) to make a gain for himself or another, or

(ii) to cause loss to another or to expose another to a risk of loss.

2.3.1 Actus Reus

• Occupation of a position where an expectation to safeguard or not to act against the financial interests of another exists, and;
• Abuse of that position.

Occupation of a position where an expectation to safeguard or not to act against the financial interests of another exists

For the purposes of this provision there are numerous instances and relationships where such a position could arise. The Law Commission explained instances encompassed by the term position at paragraph 7.38 of its Report on Fraud. These include but are not limited to:

• The relationship between trustee and beneficiary
• The relationship between director and company
• A professional person and client relationship
• Between an agent and his principal
• In the relationship of employee and employer
• As between partners
• Certain situations within a family
• In the context of voluntary work
• Other relationships where the parties are not at arm’s length and the relevant expectation exists.

Some of the above listed instances encompass a traditionally recognised fiduciary relationship as discussed above. A fiduciary duty concerning the other person’s financial interests is sufficient, but the existence of a fiduciary relationship is not essential for the purposes of a qualifying position. The judge decides whether the position is capable of giving rise to the expectation. The jury decides objectively whether it did on the facts (R v Valujevs [2014] EWCA Crim 2888).

The term ‘financial interests’ is not defined in the Act so must be taken to have its ordinary meaning, that is the victim’s interests in money or other property.

Abuse of that position

The meaning of abuse for the purposes of committing the offence is not defined by the Act so must be taken to consist of the ordinary meaning of the word. To rely on the Oxford Dictionary definition, abuse means using something for a bad effect or for a bad purpose or more simply a misuse of something.

Applying the lay meaning of the word to the offence, it can be seen that an abuse of the position will occur where the position is used to do something that it is not intended for. For example, a Power of Attorney is put in place as a mechanism of handling the financial interests of another in their best interests and to organise the provision of their affairs for them. It would be a misuse of this power for the holder of the Power of Attorney to use the access it grants to the person’s money without authority to purchase a holiday for themselves. This use is not what the power intends nor what the position was designed for, and thus constitutes an abuse.

Note the wording of the provision is that the defendant “occupies a position”, and thus this suggests a present context. Accordingly, in order to abuse that position the defendant must occupy it at the time in question. If the defendant no longer occupies the position at the point at which abuse occurs, then there will be no offence. For example, consider that the defendant was an employee and in this position gains access to sensitive trade information. If the defendant is subsequently fired and then uses this information to set up a new company competing with his old employers this alone will not be fraud by abuse of position if he no longer holds a qualifying position.

Further to this, the employee, or indeed anyone who at a time holds a qualifying position for the purposes of the offence, can be guilty of an offence if they dishonestly abuse that position with the required intent whilst they still hold the position, even where they do not put the plan into action until the relationship has ceased. To demonstrate this using the employee from above, consider that the employee transfers company information and customer details from his office computer to his home laptop during the course of his employment. Having been fired by the company the employee utilises this information in starting a competing company. In this scenario the employee will satisfy the actus reus of the offence as although he no longer occupies his position he was an employee when he copied the information for his own use.

Section 4(2) of the Act further provides that:

A person may be regarded as having abused his position even though his conduct consisted of an omission rather than an act.

It can be seen from this that once again no positive action is required from the defendant in order to fulfil the actus reus of the offence as the abuse can be committed by either an act or omission. For example, a trustee could dishonestly let a relative take trust money with the intention of benefiting that relative. Mere negligence by a trustee or director is insufficient.

2.3.2 Mens Rea

• Dishonestly, and;
• Intention to make a gain, cause loss or a risk of loss.

These two elements of the mens rea carry the same meaning as for the other fraud offences and should be assessed in the same way.

2.4 Charging and Sentencing

A company or partnership can itself commit fraud. Under section 250 of the Crime and Policing Act 2026, an organisation can be liable where a senior manager commits fraud within the actual or apparent scope of their authority. A separate offence under section 199 of the Economic Crime and Corporate Transparency Act 2023 can apply where an associate commits a specified fraud intending to benefit a large organisation, or a person to whom, or to whose subsidiary, the associate provides services on its behalf. A subsidiary of a large organisation can also be liable if its employee commits fraud intending to benefit the subsidiary. The organisation has a defence if it had reasonable fraud prevention procedures, or if it was reasonable to have none. The client-benefit route does not apply where the organisation itself was or was intended to be the victim.

Section 1(3) of the Fraud Act 2006 states that:

A person who is guilty of fraud is liable—

(a) on summary conviction, to imprisonment for a term not exceeding the general limit in a magistrates’ court or to a fine not exceeding the statutory maximum (or to both);

(b) on conviction on indictment, to imprisonment for a term not exceeding 10 years or to a fine (or to both).

In England and Wales, fraud is triable either way. On summary conviction the maximum term is 12 months, or 6 months for an offence committed before 2 May 2022 (Schedule 2, paragraph 1). The fine is unlimited for offences committed on or after 12 March 2015.

3.0 Obtaining Services Dishonestly

Section 11 of the Fraud Act 2006 provides for the offence of obtaining services dishonestly stating that:

A person is guilty of an offence under this section if he obtains services for himself or another-

(a) by a dishonest act, and

(b) in breach of subsection (2).

(2) A person obtains services in breach of this subsection if—

(a) they are made available on the basis that payment has been, is being or will be made for or in respect of them,

(b) he obtains them without any payment having been made for or in respect of them or without payment having been made in full, and

(c) when he obtains them, he knows—

(i) that they are being made available on the basis described in paragraph (a), or

(ii) that they might be, but intends that payment will not be made, or will not be made in full.

3.1 Actus Reus

• Obtaining services
• Payment required but not made
• Dishonesty caused the services to be obtained

Obtaining services

This is satisfied upon the successful obtainment of a service for the defendant or another person. Neither ‘obtain’ nor ‘service’ is given further definition in the Act, and thus must be taken at the ordinary and natural meanings of the words.

Payment required but not made

The services must be made available on the basis that payment has been, is being or will be made. They must be obtained without payment having been made in full.

Dishonesty caused the services to be obtained

This is a causation element of the actus reus as unlike the fraud offences discussed above, the offence of obtaining services dishonestly is a result crime and as such a service must actually be obtained as a result of a dishonest act. Apply the ‘but for’ test to establish causation: but for the defendant’s dishonesty would the services have been obtained? Then apply the legal causation test to ensure that the defendant’s dishonesty was more than a slight or trifling factor in obtaining the services. 

3.2 Mens Rea

• Dishonesty
• Knowing that payment was or might be required
• Intending to avoid payment in whole or in part

Dishonesty

This is established by applying the Ivey test.

Knowing payment was or might be required

This requires a subjective understanding on the part of the defendant that the services were, or might be, available on the basis that payment had been, was being or would be made.

Intending to avoid payment in whole or in part

When obtaining the service, the defendant must intend that payment will not be made, or will not be made in full. The simple omission of failing to provide a payment where there was no knowledge that one was or might be due, or not paying as there was a belief that payment had already been made, is not sufficient for the purposes of the offence. The dishonest act must obtain the service. There need be no further step to avoid payment.

Payment in whole or in part ensures that all situations are covered so it is not a defence if some form of consideration is provided, i.e. a deposit or a nominal sum in relation to a larger amount due. It is not necessary that the defendant intends to avoid the entire payment; an intention not to pay the full amount is sufficient.

3.3 Charging and Sentencing

Section 11(3) provides that:

A person guilty of an offence under this section is liable—

(a) on summary conviction, to imprisonment for a term not exceeding the general limit in a magistrates’ court or to a fine not exceeding the statutory maximum (or to both);

(b) on conviction on indictment, to imprisonment for a term not exceeding 5 years or to a fine (or to both).

As with the s.1 offence, the maximum term on summary conviction in England and Wales is 12 months, or 6 months for an offence committed before 2 May 2022. The same rules on fines apply.

Hands on Example

The following scenario will assess your knowledge of the fraud offences and give you a chance to try applying the law in a practical context.

Read over the following passage and pull out any key facts and legal issues as you go. Once you have done this try and identify what relevant offences arise on the facts and if you’re feeling really confident, have a go at putting together an answer!

If you don’t feel confident just yet, there is absolutely no need to worry! These types of questions take time to get your head around and you’re taking all the right steps just by having a look and familiarising yourself with them. A step by step outline answer has been provided for you that contains pointers as to how you should go about addressing the scenario. Use this as guidance in putting together or checking your own answer. There is nothing raised in this question that we haven’t already covered so if you get stuck look back over the notes. You’ll find that you have all the tools necessary to do a great job!

Ben is going on a big night out to see a famous DJ with his friends Will and Alex. It is day 5 of Freshers Week at their university and Ben has no money as he spent it all earlier in the week, however Ben does not want to admit this in front of his new friends. As they are arriving at the club Ben tells Will and Alex that he will meet them inside as he needs to run back to the flat to pick up his ID. Once Ben sees that the other two have gone inside the club Ben sneaks round the back and enters through the fire exit in order to avoid paying the entrance fee on the door.

Once inside Ben reconvenes with Will and Alex and the boys go to the bar to buy drinks. Ben has taken out his flat mate Sebastian’s ID with him. Sebastian is a Freshers Rep and the club are offering free drinks to the Reps that night in order to thank them for their hard work throughout the week. Ben shows Sebastian’s ID to the barman and as it is very dark and busy the barman cannot check it properly and assumes that the picture is of Ben. Ben is given a gin and tonic for free.

Later that week, Ben gets homesick and misses his girlfriend a lot. He decides that university is not for him and that he will quit his studies immediately. Ben is in receipt of a student loan and never tells his loan provider that he is no longer studying and continues to receive his loan payments, using them to fund rent on a new flat back in Nottingham.

Discuss Ben’s liability for any potential fraud offences.

Nightclub entry

Possible offence of obtaining services dishonestly under s.11 of the Fraud Act 2006.

Actus Reus

• Obtaining services

Ben gains access to the nightclub facilities and the DJ’s performance.

• Payment required but not made

There was a fee due on the door in order to gain access to the club but this was not paid.

• Dishonesty caused the services to be obtained

But for Ben’s actions of sneaking through the fire exit, he would not otherwise have gained access to the club. It was the only reason for his access to the club, and thus causation is established.

Mens Rea

• Dishonesty

Applying Ivey, it is likely that Ben’s conduct would be considered dishonest by the standards of ordinary decent people, judged in light of the facts as he believed them to be. This is evidenced on the facts by him keeping his actions secret from his friends.

• Knowing that payment was required

Ben knew that payment was required on the door which was why he did not enter the club that way.

• Intending to avoid payment in whole or in part

By sneaking around the back through the fire exit Ben intended to avoid making payment in whole.

Therefore, on the facts it is likely that Ben will be found guilty of the s.11 offence.

Free Drink

Possible offence under s.2 of the Fraud Act 2006 of fraud by making a false representation.

Actus Reus

• False representation

It can be seen that through showing Sebastian’s ID at the bar, Ben was falsely representing to the barman that he was the person in the picture, and thus that he had earned the free drink. It could be argued that this representation was express or implied but either way, applying s.2(4) it will constitute a representation for the purposes of the offence.

Mens Rea

• Knowing representation was false

Applying s.2(2) Ben knows that he is not Sebastian and that this is untrue so this is easily satisfied on the facts.

• Dishonesty

Applying Ivey it is likely that Ben’s actions will be deemed dishonest by the standards of ordinary decent people, judged in light of the facts as he believed them to be.

• Intention to make a gain, cause a loss or risk of loss

By showing the ID Ben is not merely just intending to convince the barman that his name is Sebastian, he is intending to take advantage of the free drink offer, and thus applying s.5 he intends to gain the drink without parting with any of his money. It makes no difference to liability under s.2 whether he receives it.

Applying the law to the facts it is likely that Ben will be guilty of a s.2 offence.

Loan Payments

This is a possible offence of fraud by failing to disclose under s.3 of the Act if there exists a legal duty to inform the loan provider of the change in circumstance.

Actus Reus

• Legal duty to disclose information is in existence

If there is a contractual duty under the loan agreement to inform the loan provider of any change in circumstance, then this will satisfy this element of the actus reus. For a student funded under the Education (Student Support) Regulations 2011 in England, Schedule 3, paragraph 2(a) requires the student to inform the Secretary of State forthwith if they withdraw from or abandon their course. A student funded by Student Finance England must tell the Student Loans Company when they leave.

• Failure to disclose the information

Ben does not inform his loan provider that he is no longer studying which, assuming that he has a duty to do so, satisfies this element of the actus reus.

Mens Rea

• Dishonesty

Applying Ivey it is likely that not informing the loan provider would be considered dishonest by the standards of ordinary decent people, in light of the facts as Ben believed them to be.

• Intention to make a gain or cause a loss or risk of loss

Ben intends by not informing the loan provider of his change in circumstance that he will continue to receive the payments, and thus make a financial gain.

Although this is a loan that Ben will one day have to repay this is irrelevant for the purposes of the offence as applying s.5(2)(b) of the Act there is no requirement of a permanent gain or loss. The temporary gain of the money is sufficient.

Assuming that Ben is under a legal duty to disclose the information, it is likely that Ben will be guilty of a s.3 offence. In the unlikely event that there is found to be no such duty then applying the law in R v Rai there may still be an offence of fraud by making a false representation if Ben originally represented that he was studying and dishonestly maintained that representation after he knew it had become false, intending to obtain the money for his rent.

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