Government progress update: ICAI review on Tackling fraud in UK aid: country case studies

Introduction

The Independent Commission for Aid Impact (ICAI) review of on Tackling fraud in UK aid: country cases was published on 26 March 2024. The government’s response was published on 7 May 2024.

The government provided ICAI with a progress update in November 2025, which we have published below.

Background

In March 2024, ICAI completed a review of tackling fraud in UK aid which highlighted several challenges and made four recommendations. The review built on findings and themes from earlier ICAI reviews on fraud and governance, and assessed how effectively fraud risk in UK aid is managed at the country level, through the Foreign, Commonwealth and Development Office (FCDO) network of embassies and high commissions. It looked at case studies including India, Kenya and Mozambique.

In May 2024, the government published a response which accepted or partially accepted the four recommendations by ICAI. The response welcomed the review and thanked ICAI for the findings, noting that tackling fraud is an important issue for FCDO and how progress has been made since previous ICAI reviews on fraud. Key progress made included updating whistleblowing procedures, actively exploring the possibility and cost effectiveness of a creating an FCDO Fraud Intelligence Unit, expanding the Fraud Liaison Officers’ Network, and refreshing support to Heads of Missions on their counter-fraud responsibilities.

In this update the government provides an account of the further progress made against each recommendation.

Recommendation 1

The FCDO should take a substantially more robust and proactive approach to anticipating and finding fraud in aid delivery.

Progress

The FCDO has invested in and improved its approach to counter fraud, particularly to anticipating fraud. We have started developing more pro-active capabilities for finding fraud. Since March 2024, the FCDO has:

  • Created 7.5 FTE new roles dedicated to countering fraud. The Counter Fraud Policy team has grown from 4.5 FTE to 9 FTE roles and the Fraud Investigations team (including the team who triage reported concerns) has grown from 20 FTE to 23 FTE including ongoing recruitments across both teams. These roles focus primarily on either pro-active fraud detection, data analysis or fraud risk assessment.
  • Invested in our second line team, such that all team members have either recently completed or are undertaking a professional development course appropriate to their role.
  • Built the capability of the Counter Fraud Policy team to guide and quality assure fraud risk assessment, including through professional development courses and ongoing engagement with the Government’s centre of excellence on public sector fraud and partners such as via the International Public Sector Fraud Forum.
  • Introduced a requirement for all programmes over specified thresholds (currently £200m for Policy Programme and £35m for Corporate Programmes) to have an Initial Fraud Impact Assessment (IFIA) at the planning and design stage (prior to business case approval). In 2024/25 we conducted eight IFIAs, for planned expenditure totalling £1.39bn.
  • Continued to respond quickly and effectively to allegations and occurrences of fraud; recovering losses wherever possible.
  • Strengthened our fraud awareness campaigns, particularly for International Fraud Awareness Week 2024 and 2025.

Recommendation 2

The FCDO should strengthen its second line of defence in the top 20 ODA recipient countries, allocating dedicated, well-trained and sufficiently senior resources to manage fraud risks.

Progress

The FCDO has maintained dedicated teams working on counter-fraud policy and fraud investigations and strengthened engagement with the country network. Since March 2024, the FCDO has:

  • Allocated 4.5 of the 7.5 new counter fraud roles to the second line Counter Fraud Policy team.
  • Expanded our global network of Fraud Liaison Officers (FLOs) from approximately 80 in 2024 to over 300 as of May 2025. This expansion has been supported by a revamped summary of FLO responsibilities, a bespoke two-day training programme and other guidance for FLOs and Posts.
  • Ensured all top 20 ODA recipient countries now have at least one FLO.
  • Increased the L&D offer to FCDO staff on fraud. Online Counter Fraud and

Bribery training is now mandatory for all FCDO staff and has a completion rate of 86% (as of October 2025). We now include counter-fraud content in the FCDO Induction Course and we have refreshed the counter-fraud content in budget holder and Corporate Services Manager training.

  • Performed extensive outreach work to promote counter-fraud good practice to

Posts and UK Directorates, for example, the Counter Fraud Policy Team ran over 35 counter-fraud events in 2025 and a new Counter Fraud Policy Hub has been established on the intranet and available to all FCDO staff.

Recommendation 3

The FCDO should develop specific guidance on capital investments within its Programme Operating Framework.

Progress

The FCDO accepted this recommendation and has written the guidance.

Recommendation 4

The FCDO should increase Head of Mission oversight of and accountability for fraud risks relating to centrally managed programmes and other government department programmes that operate in their country.

Progress

Whilst fraud oversight and accountability for non-FCDO programmes are the responsibility of those departments and ultimately their Accounting Officer (not the Head of Mission) we have continued efforts to strengthen and support UK aid delivery and related fraud risk management. We will further strengthen this through the ongoing transformation programme and forthcoming Counter Fraud Strategy.

FCDO Heads of Mission, and their deputies, understand their responsibilities on counter-fraud. This is supported by a policy framework and guidance for senior budget holders.  Since March 2024, the FCDO has expanded this support, and we have:

  • Reminded all Directors and Heads of Missions of their responsibilities on counter-fraud through a letter sent by the FCDO’s Director-General for Finance and Corporate in October 2024.
  • Introduced counter-fraud sessions in the pre-posting training offered to Heads of Missions and Deputy Heads of Missions.
  • Improved the financial reporting available to Heads of Mission and other budget holders.
  • Further clarified, via the One-HMG network, the line management responsibilities of Heads of Mission for senior representatives from other government departments at post, including those where the Head of Mission has operational oversight. This includes the main other ODA spending departments such as DEFRA.