An update from Pete Easterbrook, Director of Inspections and Enforcement. Pete leads the SIA’s drive against training malpractice and qualification fraud.
Training malpractice and qualification fraud are not simply shortcuts – they have real-world public safety consequences. That’s why we continue to take decisive action under Operation RESOLUTE to protect the integrity of SIA licence-linked qualifications and ensure the public can have confidence that security operatives are properly trained and genuinely qualified.
Coordinated nationwide action
In October 2025, our teams conducted a series of targeted inspections across the UK, visiting 9 training centres in a single week. While standards were generally high, we found that three training centres we visited were delivering training below our expectations. In one of the cases, we witnessed malpractice taking place. As a result, the centre is being investigated by the awarding organisation, and any further training will be scrutinised and monitored.
In November 2025, our teams conducted a major series of targeted inspections. More than twenty officers from the SIA’s Inspections and Enforcement Directorate, working closely with our partners at Ofqual, carried out simultaneous unannounced inspections across London, Manchester, Bradford, and Liverpool.
In a single day, we visited 8 venues: 5 approved training centres, 2 security companies, and 1 non-approved training centre. We took this targeted action in direct response to intelligence we received. It was necessary to disrupt an organised network we believe has been engaging in serious malpractice and fraud.
The results speak for themselves. The training centres we visited are now under investigation and close scrutiny from the awarding bodies. One of these centres has been further sanctioned, meaning the awarding organisation will not authorise the release of any further qualifications until it is satisfied the quality of training can be met.
Operation Resolute: our commitment to rooting out malpractice
These operations are part of Operation Resolute, our comprehensive initiative to identify, pursue, and root out anyone who undermines the system. We are determined to ensure the public have confidence that SIA licence holders have been properly trained, are genuinely qualified, and are fully capable of doing the job required of them.
We’re now receiving intelligence from a wider range of sources. As these recent operations demonstrate, we’re using that intelligence, our UK-wide resources, and those of our partners to track down individuals who falsely believe they won’t be caught.
Since the start of 2025
19 training centres have been closed down
242 SIA licences have been suspended
Report your concerns
If you have concerns about the integrity of SIA licence-linked training, please report them. Every piece of intelligence helps us protect the public and support the majority of training providers who operate to good standards.
We will continue to provide updates on our progress as appropriate.
An update from Pete Easterbrook, interim SIA Director of Inspections and Enforcement. Pete leads our drive against training malpractice.
We will not hesitate to act if we believe that an operative has not been trained to the standards we require as a result of training malpractice or qualification fraud.
In the last 24 hours we have suspended the SIA licences of more than 60 people who undertook training at two separate centres in Glasgow and Manchester that were operated by the same company. This came as a result of information provided to us.
We are continuing our enquiries. In the meantime, the responsible awarding organisation has prevented the centre from delivering any further training.
We will continue our work under Operation RESOLUTE, acting swiftly and decisively to root out abuse, detect and disrupt criminality, and make the private security industry a hostile environment for those who seek to exploit it.
We will provide updates on our progress as appropriate.
Pete Easterbrook, Interim Director of Inspections and Enforcement talks about a new phase to our approach to tackle training malpractice or mismanagement.
Those working within the private security hold positions of trust and responsibility. It is essential that the public, customers and stakeholders have confidence and trust that security operatives are properly trained, qualified, and capable of keeping people, property and premises safe. A key component of ensuring this trust and confidence is assuring the validity of the qualifications that operatives receive before they can apply for an SIA licence. The majority of providers who deliver SIA licence linked training are professionals who share our commitment to high standards, however where this is not the case, poor standards and training malpractice can, at its worst, put the public at risk.
While we play a central role in setting the minimum standards for licence-linked training, we’re not the only players in the game. We define the core skills and knowledge required for operatives to qualify for a licence. However, the delivery of that training is conducted by around 650 training providers who are in turn approved by six Awarding Organisations (AOs), each regulated by Ofqual (England and Wales), SQA (Scotland), CCEA (Northern Ireland), which oversees quality assurance across the sector.
Qualifications’ regulation is a well-established model that is in use in other sectors across the UK, but having multiple organisations involved in the process doesn’t always make things straightforward. Regardless of who is responsible for which part of the process, where a qualification leads to a licence being granted, then our role is to ensure that the individual we have granted a licence to is fit and proper – and that includes possessing the safety critical skills and knowledge to undertake their role effectively.
In 2024, we began to focus greater attention on training malpractice, which at it’s most serious can constitute fraud – a criminal offence. As part of this, we undertook work to improve strategic relationships with key partners such as Awarding Organisations and qualification regulators such as Ofqual. An enhanced communications campaign resulted in an increase in the intelligence we received relating to training malpractice – essential for us to be able to take the appropriate action.
Since April 2025, we’ve built on the foundations of this work, and we are now moving into a new phase under Operation RESOLUTE. RESOLUTE has been designed as a high impact initiative with a strong operational focus on intelligence led, unannounced inspections to training providers, as well as a deeper collaboration with partners.
We are realigning our resources and ensuring we leverage the considerable expertise of our people. By way of an example, we’ve now brought specialist training integrity resources into our Inspections and Enforcement directorate. This shift has unlocked wider investigative expertise and enabled a more proactive, intelligence-led approach to tackling training abuse. In addition, we’ve invested in nationally accredited training to sharpen the investigative skills of our frontline teams to ensure they are equipped to tackle training malpractice head on.
Our robust and decisive approach is already having an impact.
Since the 1st April 2025;
we’ve increased the number of unannounced training centre visits by 120% compared to the same period last year. Those visits have resulted in 10 training centres having their approval to deliver training withdrawn, and one centre suspended from delivering training until the Awarding Body is satisfied the appropriate standard can be met.
we’ve commenced a criminal investigation in one case due to the serious nature of the offending. As part of this investigation 17 individual SIA licences have been revoked where our enquiries have brought into question whether the training an individual has received has been up to the required standard.
In July 2025 my teams conducted a series of targeted inspections across the UK, visiting 15 training centres in a single week. Whilst standards were generally high, four training centres we visited were found to be delivering training below our expectations. In two cases the issues were so serious the centres were sanctioned by Awarding Bodies and any further training will be scrutinised and monitored. One of these centres was further sanctioned, and the Awarding Body will not authorise the release of any further qualifications until it is satisfied the quality of training can be met
We are about to undertake a strategic review of the licence linked qualifications, within which we will seek to further reduce opportunities for abuse of the training system. Naturally, this will involve us taking a close look at how assessments are conducted and administered. In the meantime we are working closely with partners, will continue our work under Operation RESOLUTE, acting swiftly and decisively to root out abuse, detect and disrupt criminality, and make the private security industry a hostile environment for those who seek to exploit it.
We will continue to provide updates on our progress as appropriate.
We’ve set up a dedicated multi-disciplinary team across the SIA, headed by Paul Fullwood, our Director of Inspections and Enforcement, to address labour exploitation under the name Operation EMPOWER. The aim of this operation is to seek to reduce labour exploitation across the UK private security industry, working in collaboration with the industry itself, key partners, and government. Our plan begins with the launch of a communications campaign to raise awareness of the signs of potential labour exploitation and encourage reporting. Paul explains more here:
We know that labour exploitation exists within the private security industry. The harm to individuals is unacceptable. The consequent injury to standards and public safety, to law-abiding businesses who are undercut by criminal enterprises, and to the reputation of the industry, demand a response.
We’re confident that most private security suppliers meet high standards and provide fair working conditions, which contributes to public safety. However, we know from our intelligence and stakeholder engagement that the industry has concerns that some companies are undermining quality businesses through alleged poor practices.
We’ve set up a dedicated multi-disciplinary team across the SIA, headed at director level, to address labour exploitation under the name Operation EMPOWER. This project team includes intelligence specialists and criminal investigators, as well as representatives from Individual and Business Standards, Legal, Policy, and Communications.
The aim of this operation is to seek to reduce labour exploitation across the UK private security industry, working in collaboration with the industry itself, key partners, and government. We need the commitment and support of departments and agencies with relevant powers, such as HM Revenue and Customs and the Home Office. This is because our current powers under the Private Security Industry Act 2001 provide us with limited opportunities to tackle this issue on our own.
People who are being exploited can be hard to reach. They may be vulnerable due to their immigration status. They may not even realise that they’re being exploited. We want security operatives to understand what labour exploitation looks like. For example, they may not be being paid the National Minimum Wage. For some individuals, particularly those who are being used by organised crime, their situation may be far worse. We need these individuals to be able to identify when they’re being exploited, and to know that they can report their situation in confidence to the SIA and other agencies. The expectation must be that action will follow.
We are also talking to security businesses to make sure they’re aware of their responsibilities to the people they employ. We want buyers of security to be vigilant as well, as we know that labour exploitation – particularly low pay – can be a feature of sub-contracting chains. If buyers are sourcing cheap security, say for an event, they may be paying an amount that guarantees that operatives themselves are not being paid National Minimum Wage.
A private security company supplier, which is under contract to a buyer, must make sure that their employees are paid correctly and contribute the correct amount of national insurance and tax. They must also make sure that this is being done throughout their supply chain.
No employer is exempt from paying their workers the statutory minimum wage. Employers must pay their employees the National Minimum Wage (to apprentices or people aged under 21) or the National Living Wage (to people aged 21 or over). There are also minimum unavoidable costs for basic employment matters such as national insurance.
This should be of special interest to legitimate security businesses, as unscrupulous operators can undercut those who treat their staff fairly and pay them properly.
Our plan begins with a communications strategy aiming to raise awareness of the signs of potential labour exploitation, and encourage reporting, with the support of key communications partners. We’re directing people to a new guidance and reporting page on our GOV.UK site. We will follow this first phase with a programme of engagement on the actions we are collectively taking to address labour exploitation.
In this way we are embarking on a multi-partnership operation intended to disrupt and dissuade the individuals and businesses that direct or facilitate labour exploitation. Keep an eye out for our messages, and if you come across exploitation in the private security industry – please report it.
One of our Investigations Officers, Jo, takes us through two days on site at the Reading Festival, as part of our SIA team ensuring licence holder compliance.
The famous music event attracts over 105,000 festivalgoers each year, while the security provision numbers around 2,000 operatives.
Walking to the festival
Tuesday 22 August
10.45am I arrive at the festival command centre for the event. It’s home to control teams from the police, ambulance and fire services, as well as event control and security. There’s already an impressive buzz to the place. Communication equipment, monitors and displays are arranged in the centre’s multi use courts.
11.00am I meet the rest of our inspection team who are supporting me today. We meet the Safety Manager for the Reading Festival, and he takes us to the site.
Before we’re allowed in, we must go through a site induction and be given our access wrist bands. This was one of the smoothest processes we’ve encountered to access an event. We were impressed by the improvements to the accreditation process implemented since last year.
The weather was glorious – so no festival mud to traipse through.
When operatives arrive, they must scan in a QR code, which amongst other details includes emergency contact details, then they move to accreditation desk.
Our inspection team splits into groups to do the same with the other two companies supplying security.
Firstly, we are assured of how their accreditation is set up. When operatives arrive, they must scan in a QR code, which amongst other details includes emergency contact details, then they move to the accreditation desk.
Each operative is checked against a staff list, their SIA licence is checked against additional photo identity and against the SIA register of licence holders, as well as a physical check of the card itself using an ultraviolet light to test security features.
It is a good set up and well run. We see people being taken out of the line to undergo further clarification on their accreditation, which shows due diligence on behalf of the security company.
Operatives then move through to pick up their uniforms, any equipment they need and a tabard, different colours for security staff and stewards.
Before they leave, they attend an initial briefing and one final SIA licence check.
It was a good set up and well run.
Next to the main stage
12.00pm Within the accreditation area, we undertake our own further checks on SIA licences and contact our operation control to confirm all is well.
By the time we finish, our team has checked 85 licence holders – all good.
It’s worth a note, that the total security provision numbers around 2,000 individuals across the whole weekend, less today as the event is still setting up. But the number of operatives on duty will increase when the festival opens to the public.
1.30pm We man the gatepost where operatives enter to undertake initial checks before they get to the accreditation gate.
2.00pm We return to the main security compound and meet back up with our team who have been doing similar checks with the other companies.
After a brief break, we go to see the deployed security staff. There’s security staff at three gates to the site and more dotted around arena and stages. We go to the main site gate then walk into the arena, checking staff as we go.
On our way back to the security compound, we hitch a ride on a buggy. We are held at a junction to make way for a convoy of 12 ice cream vans!
5.00pm We meet our team and make our way to the exit performing a few more checks along the way.
6.00pm We’re signed out of the site, and I can make my way back home. I endure the M25 again and when I get home, spend a little time catching up on emails and messages before signing off the day.
Thursday 24 August
Jo, Elsie, Dawn and Michelle on site
11.00am We arrive back at the command centre and meet with our team including our Chief Executive, Michelle Russell who is joining us today.
Despite threats of rain, and taking heavy coats and stout shoes, it was another glorious day.
By now, the festival is functioning rather than being set up. The campsites are filling up fast, there are already tents cheek by jowl. Concessions stands are open and the festival feels like it’s getting into full swing.
There are lots of people walking around, sitting about, enjoying the atmosphere, and getting to know where things are. Metal roadways along the main routes save these from turning into mud baths if it rains.
We can see a constant stream of people arriving, some with some strange luggage solutions; chairs strapped to backs, tents being dragged, sleeping bags hanging from rucksacks, things being dropped.
Security staff are now doing their job rather than being accredited.
Operatives are deployed walking around the camps, keeping an eye on concessions, undertaking access controls and deploying searches for main access areas.
There are eight camps in total; white, brown, orange, purple, blue, yellow, orange and eco.
Our team splits into a separate group.
11:30am We head off for ‘white’ camp, the furthest away, about a 30-minute walk. It was a good day for steps. I clocked up around 15,000 during the day.
White camp is over a temporary bridge built over a river. At each of the camps is a camp manager, store and security manager. We make further checks as the Security Manager radios his team one-by-one to come in for a check.
On the way back we check a further two camps. In addition, we sweep up any security operatives we meet as we walk through and carry out further licensing checks.
1.45pm We stop for lunch sitting down for a well-deserved break. After which, we walk on a bit further to a site access point and carry out some more checks. We don’t interfere with the search area, as this is very busy.
2.30pm We visit the brown and purple campsites on the way back carrying out more licence checks.
4.15pm As we sweep our areas the other team does the same with theirs. We meet up at the main arena where another security company is providing service for the main arena with the huge stage. We introduce ourselves. The manager is helpful but very busy, so we carry out checks as efficiently as possible and let them get on.
“It was good to have our Chief Executive, Michelle Russell along to share our experiences and talk to her about the little things that can help make our jobs easier.”
4.45pm We decide to call it a day and sit in the command centre for a de-brief.
Overall, the team undertook a total of 85 checks during the day.
It was good to have our Chief Executive, Michelle Russell along to share our experiences and talk to her about the little things that can help make our jobs easier.
5.50pm Michelle thanks the event controller and we leave the site.
8.30pm I get home. A quick check in to catch up on emails and messages before logging off for the day.
Overall, the team completed 170 checks during the two-day operation. In addition, I created 14 watchlists and checked 637 licences prior to the event. So quite an achievement.
This was the first festival operation that I was leading on, and I was pleased with how it went. Everything was well planned and everyone in the team, both (literally) in the field and at control did a marvellous job.
It was good to see the security provision being deployed to a very high standard. All the checks we undertook were positive, testimony to the work we do with security suppliers long before events take place.
Thank you to the SIA team, the security and events management companies and security operatives who all did a fantastic job in keeping the public safe over the two days.
“Everything was well planned and everyone in the team, both (literally) in the field and at control did a marvellous job.”
On Tuesday 12 September Sarah Dines, Minister of State for Safeguarding, accompanied our compliance team members and City of London Police on an inspection across six locations in the square mile.
The Minister, Sarah Dines, and our Chair, Heather Baily met and spoke with frontline security operatives, including door supervisors and security guards. The Minister was keen to understand the role and the experiences of licence holders as well as speak with them about public safety.
Our Investigations Officer, Kirsty Tagg shared with the Minister our ongoing work to tackle violence against women and girls in partnership with local boroughs and the police. She also highlighted the vital training that operatives receive on recognising indicators of abuse and their duty of care to protect vulnerable people.
The visits provided an opportunity for the security operatives to speak with the Minister and our Chair, and an opportunity for the Minister to observe our role in enforcing standards within the private security industry.
The visits allowed us to meet security operatives with a wide range of experience of working in the private security industry. A couple of the operatives had been in role for over ten years, with one holding 18 years of service at the same venue. We also met with an operative who had only just recently received their first licence.
One of the head door supervisors detailed that they had recently turned away a security operative, with what they thought may have been a fake licence.
Using ultraviolet light, they had been unable to detect a lack of security features that should have been present on the individual’s licence card.
We discussed the issue of counterfeited licences with the Minister and explained the ways in which we are tackling this issue by encouraging companies to undertake checks.
The inspection was completed with a short debrief at the end of the night.
It was a valuable exercise to introduce the Minister to the work we do out in the field, learn about the experiences of the SIA licence holders, and discuss some of the challenges we can encounter in our work.
Our thanks go to Sarah Dines, her team, the City of London Police and to all who took part for their continued commitment to working with us.
The Coronation weekend required a large private security presence to deliver safe events and ensure public protection.
Our Inspection and Enforcement teams engaged extensively in advance with the event organisers, partner agencies and security companies involved as well as being present during the weekend events to undertake compliance-related activity
Our compliance activity focused on the large events in Windsor and Central London
Windsor
Our South East regional investigators worked with the main security contractor to quality assure the accreditation process of SIA licence holders arriving at Windsor Castle to work at the event.
The team gave proactive advice around due diligence measures to mitigate against the risk of individuals trying to work in the private security industry using counterfeit licences.
The security operation at Windsor was very well organised with several hundred security operatives going through the process without issue.
We completed 40 random licence checks out of around 400 licence holders working the event, all were compliant.
Investigators also carried out inspections in and around Windsor town centre and the train station.
London
Our team of London investigators engaged with the organisers and suppliers in advance of the events across the weekend. Approximately 2,100 SIA licensed operatives were required for the event working alongside Police and the armed forces.
In the lead up to the Coronation during the `build’ phase our investigators carried out visits to ensure the integrity of security around areas of temporary infrastructure.
On Friday 5 May we undertook inspection activity carrying out licence checks in allocated areas at Green Park, Hyde Park, Trafalgar Square, Whitehall, Parliament Square and finally St James’s Park and Horse Guards Parade.
On Saturday 6 May on the day of the Kings Coronation investigators were out early in Parliament Square, Millbank, Green Park, and Hyde Park.
During both inspections our investigators spoke with SIA licensed personnel to check they held a valid and active SIA licence. We spoke with 260 individual licence holders. All held valid and active SIA licences. Warnings were issued to those failing to display their licence in accordance with licensing requirements.
The team not only checked SIA licences but spoke with the officers about their role, their experience and training. We also engaged with supervisors and managers on the ground representing the numerous providers of security personnel.
Jonathan Fleet, Regional Investigation Manager for London said:
“Many of the security officers at the event started work on event day at 4am for a 12 hour shift. We were impressed by the professionalism and dedication of the security operatives we spoke with who were doing a great job in areas with high numbers of the general public.”
John Sandlin leads the Security Industry Authority’s Compliance & Inspections teams. Here he talks about the additional work that Christmas brings as the night time economy gears up for the busiest time for bars, restaurants and entertainment venues.
John Sandlin leads the Security Industry Authority’s Compliance & Inspections teams. Here he talks about the additional work that Christmas brings as the night time economy gears up for the busiest time for bars, restaurants and entertainment venues.
When does planning for Christmas start? Pretty much as soon as we’ve drawn a breath from the summer events season which finishes around the end of September. Then we start thinking about Christmas. We look at what inspection activity we might want to do and consider requests from partners (such as police, local authorities, and the HMRC) to undertake operations to support their own objectives too. We draw on the huge amount of expertise across the team from colleagues who know the environment well and can help identify issues we need to consider.
London, UK – November 3 2022: Christmas lights in Oxford Street, view at night
So what issues do we need to consider? In the run up to Christmas there’s more footfall in venues. This creates an increased risk of harm to the public which in turn requires a bigger police presence supported by a larger private security resource. It’s the increased private security deployment that requires our involvement to make sure those working in licensable roles are complying with the necessary regulation.
Although there are variations across the UK, the police tend to focus on ensuring venues are licensed and adhere to the terms and conditions of that licence. This might cover maximum occupancy, fire controls, health and safety considerations and security provision. The police and local authorities are increasingly engaging with venues about protecting the vulnerable alongside checking venue licences. Actually, whenever they are out and about, most agencies talk about protecting the vulnerable as part of protecting the public.
Watch our ‘Helping people in vulnerable situations’ video here
How many of your team are involved in Christmas specific activity? It’s fair to say all teams are doing some form of activity that directly supports or is impacted by Christmas, so most team members will be involved in that.
As we speak there’s a multi agency operation in Belfast around the ‘ask Angela’ campaign. We’ll be undertaking licence checks, whilst supporting the initiative with messages about the campaign.
Manchester, United Kingdom – November 25, 2011 – Big wheel in the City center of Manchester with beautiful lights during christmas preparation
What additional activities do we deploy for Christmas, is it more of the same or different actions? We may undertake specific activities, especially if we have solid intelligence that provides a clear aim or benefit. However, Christmas is generally doing more of the same, but with a stronger focus on the night time economy. There’s a huge upshift in volumes and that’s the biggest difference. There’s still a need to continue with other work, for example we’re working in Oxford Street in London during the day, although, to be fair, that’s also connected to the increase in footfall in the run up to Christmas.
What do we do on the front line? It will depend on the site and any objectives for an operation. However, primarily we’re interested in compliance with the Private Security Industry Act. So, we’re mainly checking individuals are correctly licensed and ascertaining the businesses that operatives work for to build our understanding of the makeup of the local economy. This is especially useful when newly formed companies emerge. We’re also interested in in how labour is deployed and what the labour chain looks like; the more links in a labour chain, the higher the risk of noncompliance. We also check individuals’ employment status which helps identify possible exploitation. Where possible we push other messages and support campaigns to promote awareness and conversations across the industry.
How do security operatives and venues react to your teams’ presence? Mostly, we get a positive response. Generally, licence holders like to see us out checking licences as they don’t want rogue people in the industry. We occasionally meet one or two unlicensed operatives that may be a little reticent for want of a better word but using our skills we overcome those hurdles.
Do other agencies do similar tasks around Christmas? The Police and local authorities will be undertaking checks based around venue licensing and will want to assure themselves that venues are complying. Sometimes they may support us on our operations, it depends on specific operations, or sometimes the location. For example, I’d be fairly happy undertaking checks in Westminster without police support but wouldn’t want to do so in other areas without them. That goes not just for London, but anywhere else, you get a good feel for what risks maybe posed in undertaking checks without partners.
How much does the night time economy grow over the festive period? We always hear that businesses are at their busiest and it’s very true, there are more people in more venues over more nights of the week. There are additional Christmas get togethers with friends, socialising after work, organised office parties – it’s difficult to put a figure on, and it will vary from location to location, but it’s noticeably much busier. Let’s not forget this is the first Christmas without any COVID restrictions.
On top of venues being busier, there are additional entertainment venues and events to consider; pop up fairs, Christmas markets, ice rinks, entertainment offerings, temporary licensed premises.
How stable is resource in the night time economy? If more door supervisors are needed because a company has a shortfall, then most companies will contract in staff from another to match the demand. However, what sometimes happens is the supplying company will in turn go to another to fulfil the request. This is not a problem as such, but it is a concern. With each company’s loan of resource comes a charge. This can lead to a squeeze on profit margins which is where corners can be cut. When that happens to the risk of improper employment and unlicensed personnel can start to emerge.
How effective are the operations we undertake? Of course, we have limited resource and we can’t visit every venue. However, what we do has a definite ripple effect. When we’re in a large town or city, just by visiting a few premises, word gets around very quickly that we’re out and about undertaking checks and looking at licences. That has a great deterrent effect within the security community. So, we enlarge the size of our footprint. In addition, we work with colleagues in the Communications team to get the message out and again, this spreads across the community well.
What does it take to deploy an operation? That’s a good question; lots of work.
Before we set foot on the ground, we undertake pre-inspection activity. This could be meetings with partners, considering intelligence we or our partners have received and undertaking a recce in the locality. We then need to work up aims and objectives before putting an operational order together. Information needs to be created within our database (CRM). Risks also need to be considered and risk assessments completed. We also need to secure resource from across the team and make sure everyone is available for the operation. In addition to staff on the ground, we always have an operational control to assist with licence checks on the STeP database, as well as then inputting the checks onto CRM. This can be quite a laborious task, especially if there are a voluminous amount.
Any last words? The team are very committed. We have had a fair few new staff so as well as preparing and undertaking activities, experienced team members are also helping to train and guide their new colleagues in this crucial area of work. Everyone in the Compliance & Inspections team plays a part in what we do from the MST to the investigators themselves, supported by colleagues from other teams. The inspection activity being centred on the night time economy requires staff to work evenings and weekends to attend operations, which at this time of year means being out in the cold. I want to thank the teams, I appreciate everyone’s effort and support in keeping the public safe.
About the author
John Sandlin served for 30 years with the Metropolitan Police. He worked as an Investigating and Senior Investigating Officer for over 11 years investigating homicides and other serious crimes. He’s worked at the SIA since early 2015.
We remind you that those who use labour supplied by other parties remain responsible for ensuring that the supplied licensed operatives hold a valid and genuine SIA licence. You must undertake appropriate due diligence. We are encouraging all suppliers of security to continue to ensure that the SIA licence produced at `check-in’ is physically checked and is valid.
We encourage you to use a UV (ultraviolet) light where possible as a quick and easy method to check licences. The SIA licence features several easy-to-check security features. These include:
• on the front of the licence you should be able to see holograms when the licence is tilted backwards and forwards.
• the expiry date of the licence is embossed on the bottom of the photograph (not printed on) – you should be able to run your finger over the date and feel that it is raised.
• on the back of the licence there is a QR code and a bar code. The bar code should bring up the same licence number as shown on the licence.
• a UV light should reveal `SIA’ in the top right and bottom left of the licence when scanned across the front. On older licences there will be a watermark pattern on the back of the licence that can only be revealed by the UV.
• The address on the rear of the licence should show an `E’ post code.
This month, one of our Criminal Investigations Managers, Nathan Salmon explains how the SIA uses the (Proceeds of Crime Act (2002) to recover the profits made from offending within the private security industry.
Our blog aims to discuss developments in the private security industry and to provide further insight and opinion on our work. We look forward to having an on-going discussion with you; share your comments and opinions.
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Over the last 12 years, the SIA has been investigating and prosecuting anyone who repeatedly shows that they do not care about being licensed or working within the law. Our Partnerships and Interventions department does this by encouraging those working in the private security industry to stay within the law (the Private Security Industry Act). You can find out more about our enforcement activity on our website.
The SIA licence is a way to safeguard the industry and general public, and it is our responsibility to make sure that only ‘fit and proper’ people work in the industry. Those who ignore us and disregard the importance of licensing could be barred from operating in private security and prosecuted.
We do not always prosecute but investigate and consider whether there are public safety risks or if we need to protect the integrity of the private security industry or our licensing system.
The Proceeds of Crime Act (POCA) and repeat offenders
In recent years, we noted that some security companies were being investigated repeatedly. We had to do something because we didn’t want businesses treating court fines as a type of tax where the level of profit for working outside the law is worth the potential penalties any judge or court may give.
In 2015, the government amended POCA to include to regulatory bodies like us and we applied to take advantage of these powers. POCA is a law that means any money made from criminal activity can be recovered. It is also used by the likes of local authorities, HMRC and the Police to name a few.
We started using POCA in November 2015 to financially investigate companies and individuals who make a profit from criminal activity in the private security industry. Since then, we have employed financial investigators. They are accredited to use POCA to investigate and confiscate assets.
A recent example of our use of POCA is the case of Billy Jones, a security director who continued to work despite having had his Security Industry Authority (SIA) licence revoked. He was ordered to pay £300,000 at Cardiff Crown Court, in April 2019. This kind of conviction removes the benefit of working outside the law in the private security industry.
How does the SIA use POCA?
Our Criminal Investigations Team, is part of our Partnerships and Interventions department and is responsible for the SIA’s criminal investigations. This includes Accredited Financial Investigators (AFIs) who are able to legally present financial information in court. AFI’s are unique and very important because they have the power to ask financial institutions for information and use this to build a clear picture of someone’s financial status.
There are currently two main ways that our AFI’s can use POCA:
Restraining assets
AFI’s can apply to the court to restrain the assets of people under financial investigation. This makes sure that the money or assets of anyone we are prosecuting cannot be sold or dissipated before a court case ends. For example, for someone who is being investigated, the amount they can withdraw from their bank account can be restricted and their assets frozen.
Confiscating assets
Once convicted, a court can order a person to pay an amount of money based on how much they made through criminal activity. If they fail to pay this money, they could end up in prison and when released they would still need to pay this amount. In some cases, life-changing amounts of money can be confiscated by the courts. How POCA figures are calculated is shaped by case law, meaning specific cases determine how the calculations should be applied. We’re really pleased to have contributed to this and case law specific to the security industry exists.
During POCA proceedings, the people we’re investigating may see their lifestyle change. Due to current case law and depending on the situation, how much we confiscate may be the entire value of a security contract and not just the profit. This is because the turnover from a security contract may be a significant figure, a business or person might have to pay back hundreds of thousands of pounds. Selling assets like houses, cars or investments, to pay back the proceeds of their crime may be required.
If you’re wondering where this money goes, most of it returns to the Treasury. A proportion is allocated to the investigating organisation, which we can use to fund future financial investigations. In practice, we get no more than 34%. The money can also be allocated towards good causes, and we are exploring opportunities that will benefit the private security industry.
What will the SIA do with POCA in the future?
Over the next few months, we want financial investigations to become increasingly a core part of the way we prosecute at the SIA. This is really important because it is how we can guarantee that criminal profits are not reinvested, into “phoenix” companies that are essentially the same companies with a different name that have been set up after a criminal conviction. Our ability to use POCA should act as a warning to businesses seeking to operate outside private security regulations – you risk not only your business, but potentially your personal assets as well.
We are making really good progress and the volume of criminal cases under consideration has never been higher. Our success with POCA strengthens our regulation of the private security and we will continue to work with Regional Asset Recovery Teams and Police partners so that those who want to profit from illegal and poor business practice are removed from the private security industry.
