Improving the response to organised immigration crime

Foreword

Reducing illegal migration to the UK is a priority for the Government. In January 2024, the then Home Secretary commissioned us to inspect how effectively the police and National Crime Agency (NCA) tackle organised immigration crime (OIC) in England and Wales.

During our inspection, we examined:

• how the response of law enforcement agencies to OIC was led;
• the initial response to suspected immigration crime incidents;
• the management of information and intelligence;
• how OIC groups were targeted by law enforcement; and
• organisational learning and training for officers and staff.

We carried out interviews and focus groups with personnel in police forces, regional organised crime units (ROCUs) and the NCA. We also visited several units under Home Office control, to interview personnel and hold focus groups. We also reviewed over 100 documents and consulted with the Independent Chief Inspector of Borders and Immigration, whose support we appreciate.

At the time of our inspection, the NCA was responsible for leading the UK law enforcement response to OIC. The NCA has committed significant resources to tackling OIC and has had some notable successes.

We heard that the methods used by criminal groups to smuggle people into the UK, and the number of different agencies involved in tackling it, created unique challenges. In 2021, the NCA director general agreed with other senior leaders to use his legal powers to direct the response of chief constables to tackling OIC. We found the response of UK law enforcement to OIC had improved since then. However, if the UK law enforcement response is to reflect the Government’s priority, much more still needs to be done.

We found that processes to manage the response to organised immigration crime existed. Generally, frontline and control room personnel understood them. However, we found that there were too many police forces not collecting and analysing immigration crime intelligence. We also found that the approach to intelligence gathering when migrants arrived in the UK was neither effective nor robust enough. Intelligence and investigative opportunities are being lost. And we found that the various agencies involved in tackling OIC can’t always share intelligence with each other as effectively as they need to.

We heard several examples of UK law enforcement agencies tackling the organised crime groups that organise illegal migration. Many of these examples needed assistance from overseas authorities to disrupt criminals operating outside the UK. In fact, we found that the number of disruptions relating to OIC recorded had increased substantially. However, we were surprised and concerned to find that most organised crime groups believed to be involved in OIC weren’t being actively investigated. We identified very few examples of police forces or ROCUs proactively targeting these criminals.

Since 2022, the National Police Chiefs’ Council has carried out peer reviews of police forces’ response to OIC. These reviews are valuable and have contributed to recent improvements. At the time of our inspection, these reviews were limited to Home Office police forces. We think they should be extended to include all agencies tackling OIC.

Training packages for police personnel likely to respond to or investigate immigration incidents are available. Attendance rates on relevant courses in some police forces need to improve.

Many law enforcement agencies are involved in tackling OIC, so it is important that every agency knows who is responsible for what. Concerningly, some don’t. After we completed our fieldwork for this inspection, the Government created a new Border Security Command. Although this development is positive, the Border Security Command should clarify roles and responsibilities for the law enforcement agencies and make sure they are overseen effectively.

In this report, we make ten recommendations. They are designed to improve how UK law enforcement agencies identify and tackle the organised crime groups responsible for immigration crime by:

• clarifying each agency’s roles and responsibilities, and improving governance;
• improving the processes being used for migrant identification and intelligence gathering;
• improving the way different law enforcement agencies share and analyse intelligence;
• making sure that all opportunities to investigate and disrupt the organised crime groups that have been identified are taken;
• including all law enforcement agencies in the established peer review process; and
• making greater use of available training packages.

Despite the efforts of successive governments to prioritise and tackle OIC, it remains a persistent and serious problem for the UK. Implementing our recommendations will lead to less OIC and, ultimately, fewer lives being lost.

Lee Freeman

HM Inspector of Constabulary

Summary

Reducing illegal migration to the UK is a priority for the Government. In January 2024, the then Home Secretary commissioned a report into how effectively the police and National Crime Agency (NCA) tackle organised immigration crime in England and Wales.

People try to enter the UK illegally by several methods. Since 2020, small boats crossing the English Channel have been the most used method. These attempts are extraordinarily dangerous. Increasingly, migrants – including children – drown during the crossing.

Migrants often use the services of people who specialise in organised immigration crime (OIC) to help them travel to the UK border and enter or remain in the UK illegally. In doing so they trust their lives to them. These criminal groups are often based overseas. This report examines how well UK law enforcement agencies tackle this type of crime and its distinct challenges.

Governance and direction

During this inspection we heard that OIC hadn’t always been a priority for police forces in England and Wales, largely because they saw it as the responsibility of Home Office Immigration Enforcement. That is changing. Police forces are now more likely to prioritise OIC.

At the time of our inspection, the NCA was responsible for leading the UK law enforcement response to OIC. An NCA director chaired a strategic governance group. The NCA had also created a strategic action plan that it used to manage progress on actions allocated at the strategic governance group. The action plan included updates from agencies including the NCA, Home Office Intelligence, Immigration Enforcement and policing. The detailed document clearly set out current activities to tackle OIC.

However, probably because there are so many bodies involved, not everyone we spoke to was fully aware of which body was responsible for the different activities. In January 2021, the NCA produced a document setting out roles and responsibilities called ‘Organised Immigration Crime High Level Responsibilities’. In addition, the Government has since created the Border Security Command. To make sure each body is clear on the part it is expected to play, we advise the NCA to review, revise and reissue its roles and responsibilities document to make sure each body is clear on the part it is expected to play.

The NCA director general has used his legal powers to improve the response of police forces to OIC. In 2021 and 2023, he wrote to the chief constables of police forces in England and Wales directing them to carry out specific tasks. The activities resulting from these letters have contributed significantly to improving law enforcement agencies’ responses to OIC, but not everything the director general requested has been done.

Initial response, information and intelligence

The National Police Chiefs’ Council established the Modern Slavery & Organised Immigration Crime Unit (MSOICU) in 2021. In February 2021, the unit introduced the National Response Plan (NRP) to improve the initial response to suspected immigration crime incidents. We were pleased to find that most police personnel we interviewed knew what to do when dealing with an immigration crime incident.

There is an established process for receiving migrants who make it at least halfway across the English Channel (to the ‘median line’) in small boats. It has a well‑established humanitarian and welfare approach. But opportunities to gather valuable intelligence relating to OIC are being lost. Irregular migrants who use small boats will almost certainly have paid members of organised crime groups (OCGs) to arrange transport to the UK. This means that they are potential witnesses and a valuable source of intelligence.

We visited several locations in the south of England that managed the arrival process. Personnel initially concentrate on the safety and welfare of people arriving, then try to verify their identity. Personnel carry out checks on several systems, but we were surprised to find that they didn’t have direct access to the Police National Database. We also found that automated facial-recognition technology wasn’t available for personnel to use.

We understand that it isn’t possible to debrief every migrant who has arrived illegally. Law enforcement agencies should increase the proportion of irregular migrants that they debrief for intelligence on arrival.

At the time of our inspection, we were concerned to find that there was no effective legal power to seize and examine mobile telephones or other electronic devices from irregular migrants to search for evidence and intelligence. These devices may contain valuable information about the criminals organising the crossing, how they were paid, the modes of travel and the routes they used.

Not all police forces and regional organised crime units (ROCUs) have satisfactory arrangements for collecting and analysing intelligence. Some have prioritised OIC and include it in their strategic governance arrangements. But we found some police forces didn’t prioritise OIC. Some have no intelligence collection plans, lack dedicated analytical resources and have limited access to other relevant organisations’ information.

All the organisations responsible for tackling OIC have their own IT systems, which don’t connect with each other. We often experienced this problem during our inspections. So, we weren’t surprised to find examples where agencies had found it difficult to share information.

We were encouraged to find that in 2023, the NCA working with Home Office Intelligence and Immigration Enforcement created the Joint Fusion Cell (JFC) to address this problem. We accept that it is new and still developing, but at the time of our inspection, several problems continued to limit its effectiveness. The NCA needs to improve how the JFC operates.

For example, staff working in the JFC can only access IT systems in their own organisations and there is no formal process to allow sharing information with each other. We also heard that the JFC had no dedicated analytical resources. JFC personnel are also required to use spreadsheets to record intelligence. There is no automatic process to link the intelligence systems of the relevant law enforcement agencies.

Many criminal groups involved in OIC are based overseas, often operating online. This makes it crucial that UK law enforcement agencies work closely with overseas counterparts. We heard several good examples of this happening, including work with officials in Europe to identify and target the supply of equipment such as boats and engines. We also heard how the NCA had worked with social media companies to remove online adverts relating to OIC.

We found that since the NCA director general wrote to chief constables, there had been a significant increase in the amount of intelligence about OIC available through the Police National Database. But we found that inconsistencies in the way agencies recorded information adversely affected the quality of the data.

Enforcing the law and disrupting the activities of organised immigration crime groups

We examined nationally held data related to the known OCGs involved in OIC. We were able to establish that law enforcement agencies had assigned most as low priority and weren’t actively investigating them.

We understand that in some of these cases there may be valid reasons for this, such as poor intelligence. We also understand that police forces face many competing priorities each day. However, the level of national importance assigned to tackling OIC means these police forces need to review decisions.

UK law enforcement agencies face unique challenges when tackling the organised criminals who make possible illegal immigration. Most personnel we spoke to told us that it would be difficult to illegally enter the UK without some assistance from OCGs. We heard that most of the criminals involved, particularly those at the head of OCGs, were based overseas. Additionally, many items used to support small boat crossings aren’t usually illegal, such as boats, engines and flotation aids.

Simply enforcing the existing law won’t stop immigration crime. Law enforcement agencies must work together and proactively use a full range of tactics to disrupt and reduce opportunities for criminals. This includes working with overseas governments and law enforcement bodies.

Immigration Enforcement Criminal and Financial Investigation teams lead most reactive immigration crime investigations. These normally start after UK authorities have discovered migrants entering the UK illegally. Generally, we found that personnel in the various agencies we visited understood the NRP process and it was working well. However, we did find some examples of police personnel not fully understanding each agency’s responsibilities.

We heard several examples of excellent investigations, both at home and overseas, targeting those responsible for OIC. We also found that generally there was an established process to decide which agency should manage individual investigations. However, these investigations were mainly reactive after law enforcement agencies discovered a potential offence.

We are concerned that we found few examples of police forces or ROCUs proactively targeting OCGs involved in OIC. This may be for several reasons, including police forces not collecting intelligence and too many known OCGs not being prioritised. This needs to improve.

We examined national data showing the number of disruptions recorded relating to OIC. In October 2021, the NCA director general used powers under the Crime and Courts Act 2013 to give police forces the task of tackling OIC. We were pleased to find that since then the number of recorded disruptions had significantly increased. Concerningly, we found that just four police forces had recorded over half of the disruptions. It is clear that most police forces must do more.

Organisational learning, including training officers and staff

Since 2022, the MSOICU has been reviewing the response of police forces in England and Wales to OIC. These peer reviews identified several areas for improvement. This included a lack of awareness of OIC among some frontline personnel. And not all police forces were using the NRP in their control rooms.

Generally, we found that the understanding and implementation of the NRP was good. This was especially true with police control room personnel and incident managers. During our visits to police forces, we found that some had included guidance about OIC in their initial training courses. This is an effective way of improving frontline personnel’s understanding of OIC and how they should respond to incidents. Police forces’ intranet systems should include information covering what to do when responding to suspected immigration crime incidents.

The MSOICU has developed an immersive training package primarily aimed at managers and investigators. The scenario allows attendees to deal with a fictional incident where a lorry drops irregular refugees in a clandestine location. The MSOICU has started to train police force personnel to manage training in their own forces.

At the time of our inspection, the College of Policing hadn’t provided any OIC‑specific training. However, it is using its online learning resource College Learn to host an e‑learning course aimed at raising awareness of OIC for police officers. The MSOICU and the Metropolitan Police Service developed the course. It is aimed at frontline personnel and investigators most likely to deal with immigration crime incidents. We were surprised to find that completion rates in police forces varied dramatically. In some, very few officers had completed this training. Some senior police officers told us that completion of this training should be mandatory. We agree.

We believe that the MSOICU peer review programme is valuable, but it needs extending. Non-Home Office police forces, such as British Transport Police and the Police Service of Northern Ireland, and the nine ROCUs should be included. The programme should also include reviews of other agencies involved in the response to OIC.

Recommendations

Introduction

Background

Reducing illegal migration to the UK is a priority for the Government. Official statistics show that, during the year ending March 2024, authorities detected 38,546 irregular migrants entering the UK. That figure doesn’t include attempts to enter the UK that the authorities successfully prevented. Illegal migration into the UK remains the subject of considerable media coverage and public debate.

People try to enter the UK illegally by several methods. These include clandestine entry by hiding in vehicles, abuse of the visa system and abuse of the Common Travel Area between the UK and the Republic of Ireland. They also include attempts to cross the English Channel in small boats, usually from the north French coast. These attempts are extraordinarily dangerous. Increasingly, migrants – including children – drown during the crossing. Less-dangerous methods can also lead to fatalities. In 2019, 39 Vietnamese migrants suffocated in the trailer of an articulated lorry that travelled from Belgium to Essex.

Since 2020, small boats have been the most common recorded method of illegal migration to the UK. We were told that this may be due in part to the pandemic lockdown making other methods such as air and ferry travel less viable. But even after the pandemic, small boats are still the most common recorded method of illegal entry.

The section of the UK’s coast that lies closest to mainland Europe is subject to comprehensive surveillance. Migrants trying to enter the UK using small boats in this area are much more likely to be detected.

In the year ending March 2024, official statistics show that 81 percent of all detected irregular migrants arriving in the UK had crossed the English Channel in small boats. But this figure should be treated with caution. People arriving by other methods are much harder to detect and nobody knows how many migrants enter undetected.

Migrants often use the services of people who specialise in organised immigration crime (OIC) to help them travel to the UK border and enter or remain in the UK illegally. In doing so, migrants entrust their lives to criminals. This report examines how well UK law enforcement agencies tackle this type of crime and bring to justice those criminals who pay scant regard to human life.

About us

His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) independently assesses the effectiveness and efficiency of police forces and fire and rescue services, to make communities safer.

In preparing our reports, we ask the questions that the public would ask, and publish the answers in accessible form. We use our expertise to interpret the evidence and make recommendations for improvement.

Our commission

On 5 January 2024, the then Home Secretary commissioned us under section 54(2B) of the Police Act 1996 and 11(2)(b) of the Crime and Courts Act 2013, to inspect how effectively the police and National Crime Agency (NCA) tackle OIC in England and Wales.

The Home Secretary asked us to assess how the whole system approached tackling OIC. This included consulting with other relevant bodies on a voluntary basis and engaging with relevant inspectorates such as the Independent Chief Inspector of Borders and Immigration.

Our terms of reference

Our inspection focused on how effective the law enforcement agencies were at:

• disrupting the activities of OIC groups, and enforcing the law against them;
• gathering, assessing, and exchanging information and intelligence;
• producing and communicating national and regional assessments;
• carrying out tasks (requested or directed by the NCA or another body) in respect of national and regional operations; and
• organisational learning, including training officers and staff.

Definitions of terms used in this report

At the time of our inspection, there was no single definition of OIC. However, the 2024 National Strategic Assessment (PDF document) of serious and organised crime contains the following: “Organised immigration crime involves an organised crime group assisting a person to cross borders without legal permission or documentation.”

Organised immigration crime isn’t the same as modern slavery and human trafficking. Modern slavery relates to an individual exploited by others for personal or commercial gain. Whether tricked, coerced or forced, they lose their freedom. Human trafficking is the use of violence, threats or coercion to transport, recruit or harbour people to exploit them for purposes such as forced prostitution, labour, criminality, marriage or organ removal.

In most cases, victims of modern slavery and human trafficking are the individuals themselves. This is different to OIC cases, where the country receiving the individual is generally the victim. However, there are occasions when this distinction is less clear. For example, when someone has paid organised criminals to arrange their movement to the UK, then finds themselves in debt to the criminals and, on arrival, is subject to labour exploitation.

Our reports contain references to, among other things, ‘national’ definitions, priorities, policies, systems, responsibilities and processes. In some instances, ‘national’ means applying to England and Wales. In others, it means applying to England, Wales and Scotland, or the whole of the United Kingdom.

Immigration-related legislation

The Immigration Act 1971 includes the most frequently prosecuted immigration crime offences:

• entering the UK without leave or arriving without entry clearance, contrary to section 24 (B1) to (E1), with a maximum penalty of four years of prison and/or a fine (on indictment);
• entering the UK in breach of a deportation order, contrary to section 24 (A1), with a maximum penalty of five years imprisonment and/or a fine (on indictment); and
• assisting unlawful immigration to the UK (or a Member State of the European Union) contrary to section 25, with a maximum penalty of life imprisonment (on indictment).

Paragraph 16 of Schedule 2 of the Act allows for a person to be detained pending a decision to give or refuse them leave to enter. This is often referred to as an administrative power.

The Nationality and Borders Act 2022 amended the section 24 offence (entering the UK or arriving without clearance) so that it is committed by arriving at the UK border rather than by entering the UK. Law enforcement agencies may detain anyone found entering the UK illegally.

Before a Crown prosecutor authorises charging a person, they consider several aggravating and public interest factors, for example:

• if the individual was the pilot of the boat;
• evidence of repeated attempts to enter the UK; and
• if the suspect has previous convictions of any kind.

In July 2023, the Illegal Migration Act 2023 received Royal Assent. Its provisions, including the power to seize and examine mobile devices, haven’t been implemented due to a change in Government.

Bodies concerned with tackling organised immigration crime

There are several bodies with significant roles and responsibilities for tackling OIC.

The National Crime Agency

The National Crime Agency (NCA) is responsible for leading, supporting and co‑ordinating the approach to serious and organised crime. This includes OIC. The NCA supports police forces, government departments and other law enforcement agencies. This support can come from different parts of the NCA, for example its intelligence and investigations directorates. The NCA puts considerable effort into tackling OIC, including having 320 OIC-dedicated officers.

The Modern Slavery & Organised Immigration Crime Unit

The National Police Chiefs’ Council set up its Modern Slavery & Organised Immigration Crime Unit in 2021. The unit’s activities include peer reviews in all 43 Home Office police forces in England and Wales, making recommendations and identifying good practice. The unit has introduced a network of co-ordinators based in each regional organised crime unit (ROCU).

Police forces and regional organised crime units

Throughout England and Wales there are 43 Home Office police forces. These are structured into 10 regions with 9 ROCUs. Each ROCU serves between three and seven constituent forces.

The Strategic Policing Requirement February 2023 (SPR) defines ROCUs as: “Collaboration arrangements between forces that deliver specialist policing capabilities” and “the primary interface between the NCA and forces.”

It sets out that: “The ROCU network mission is to protect communities by disrupting organised crime groups, individual criminals and those who enable them.”

The SPR also refers to the need for police forces to contribute to efforts to disrupt OIC. It adds that forces need to understand the local threat of immigration crime and provide sufficient operational capability to address it. The SPR also states that forces need to have good working relationships with partner organisations including the NCA, Immigration Enforcement, Border Force and Home Office Intelligence.

The Government’s ‘Serious and Organised Crime Strategy 2023 to 2028’ states: “ROCUs are the operational and intelligence link between the NCA and police forces in England and Wales and lead the law enforcement response to serious and organised crime in their regions.”

The Home Office

The Home Office is the lead government department for immigration and passports. It is responsible for securing the UK border, controlling immigration and considering applications to enter and stay in the UK. It works closely with other law enforcement bodies such as the NCA and intelligence agencies. There are several relevant parts of the Home Office.

Immigration Enforcement

Immigration Enforcement is responsible for preventing abuse of the immigration system, increasing compliance with immigration law, pursuing immigration offenders and protecting the vulnerable. It includes:

• Criminal and Financial Investigation teams, which investigate volume and serious organised immigration crime at the border and inland; and
• Immigration Compliance and Enforcement teams, which deal with in-country immigration offenders administratively and progress their removal from the UK.

Border Force

Border Force carries out immigration and customs controls for people and goods entering the UK. It includes the Small Boats Operational Command, “which provides an operational response to migrant vessels crossing the Channel by conducting the initial humanitarian response, triage and processing of the immigration status of those on board”.

Home Office Intelligence

Border Force and Immigration Enforcement created Home Office Intelligence when they merged their intelligence departments. Home Office Intelligence is accountable to both organisations.

UK Visas and Immigration

UK Visas and Immigration manages applications from people who want to visit, work, study or settle in the UK.

Independent Chief Inspector of Borders and Immigration

The Independent Chief Inspector of Borders and Immigration’s purpose is to help improve the efficiency, effectiveness and consistency of the Home Office’s border and immigration functions through unfettered, impartial and evidence-based inspection.

Methodology

Our inspection took place between February 2024 and June 2024. We carried out fieldwork in the NCA, visiting its offices in London and Kent. We also visited the following police forces and ROCUs, in England and Wales:

• East Midlands Special Operations Unit;
• Eastern Region Special Operations Unit;
• North West Regional Organised Crime Unit;
• Kent Police;
• Essex Police;
• Devon & Cornwall Police;
• Sussex Police;
• Bedfordshire Police;
• Humberside Police;
• West Yorkshire Police;
• Greater Manchester Police; and
• North Wales Police.

We carried out:

• 115 interviews and focus groups with personnel in police forces, ROCUs and the NCA;
• reality testing including speaking with frontline personnel and supervisors, specialist investigators and control room officers and staff;
• a review of over 100 documents, including national and local strategic threat assessments, presentations, and problem profiles;
• interviews with Home Office senior officers and staff;
• interviews and meetings with the Modern Slavery & Organised Immigration Crime Unit; and
• interviews with personnel from other bodies.

We also carried out interviews and focus groups in other units under Home Office control including:

• Border Force;
• Small Boats Operational Command, including the Western Jet Foil centre for arriving irregular migrants and the Manston processing centre;
• Immigration Enforcement;
• Home Office Intelligence; and
• the Joint Debriefing Team.

We also consulted with the Independent Chief Inspector of Borders and Immigration, who kindly provided a member of staff to help and advise us during our fieldwork.

Border Security Command

After our inspection fieldwork had ended, the Government created a new Border Security Command. Its responsibilities are to provide “cross-system strategic leadership, bringing together policy and operational delivery capabilities, to secure the UK’s borders against a range of threats”. This includes tackling the smuggling groups that make possible illegal migrant crossings over the English Channel.

Because the Border Security Command was created after our inspection, and because responsibility for inspecting it rests with the Independent Chief Inspector of Borders and Immigration, we don’t comment on the Border Security Command’s effectiveness or efficiency. However, the evidence we collected during our inspection has led us to make several recommendations to it.

Governance and direction

During this inspection we heard that organised immigration crime (OIC) hasn’t always been a priority for police forces in England and Wales, largely because they saw it as the responsibility of Home Office Immigration Enforcement. That is changing. Police forces are now more likely to prioritise OIC, but it wasn’t a priority in every police force we visited.

Governance in a complex landscape

National Crime Agency-led strategic governance meeting gives a good understanding of immigration crime-related threats

A director in the National Crime Agency (NCA) chairs a quarterly strategic governance group for OIC. They use this meeting to co-ordinate activity and share intelligence between agencies. We observed one of these meetings. The NCA provided a clear intelligence briefing at the meeting, which included information about small boats and clandestine entries. We observed that it gave attendees a good understanding of OIC‑related threats.

The NCA provided us with a copy of a strategic action plan that it used to manage progress on the actions allocated at the strategic governance group to tackle OIC. The action plan included updates from agencies including the NCA, the Home Office, Immigration Enforcement and policing. It was a detailed document clearly setting out the current activities to tackle OIC. But we found less certainty about responsibilities among people we interviewed.

Several agencies share responsibilities for tackling OIC, which creates confusion

Not everyone we spoke to was fully aware of which body was responsible for what. This is probably because there are so many bodies involved in tackling OIC.

In January 2021, the NCA produced a document called ‘Organised Immigration Crime High Level Responsibilities’. It was a good attempt to clarify responsibilities in a concise way. But we found it problematic in three respects:

1. It states that only regional organised crime units (ROCUs), not police forces, are responsible for investigating OIC-related organised crime groups. It states that police forces are only responsible for collecting community intelligence, initial crime scene management and the investigation of some offences not linked to organised crime groups. We disagree. And framing police responsibilities in this way may have contributed to some police forces assigning OIC low priority.
2. This division of responsibility between police forces and ROCUs is more practical for some regions than others. In several regions, larger police forces retain substantial serious organised crime investigation capabilities of their own.
3. As we explain later in this report, we found that ROCUs were doing little investigative work on OIC-related organised crime groups.

Four years have passed since the NCA created the OIC high level responsibilities document. In this time, Border Security Command has been established. In September 2024, the Government announced considerable additional funding and new measures to tackle OIC. This was followed, in November 2024, by another Government funding announcement, bringing the investment in the Border Security Command to £150 million over 2 years. To make sure each body is clear on the part it is expected to play, it would be advisable for the NCA’s roles and responsibilities document to be reviewed, revised and reissued.

The National Crime Agency’s powers

The NCA director general chairs the national strategic tasking and co-ordination group (NSTCG) meeting. This provides leadership and structure for tackling serious and organised crime. Other UK law enforcement agencies and organisations attend.

Section 5 of the Crime and Courts Act 2013 empowers the NCA director general to direct the following to carry out specific tasks:

• the chief officer of any England and Wales police force;
• the chief constable of the British Transport Police; and
• the director of the Serious Fraud Office.

At the NSTCG meeting in September 2021, the NCA director general agreed with other senior leaders to use these powers to respond to OIC. He wrote to chief constables of police forces in England and Wales on two occasions to direct the response to OIC. He sent his first letter on 5 October 2021 and his second on 6 January 2023.

One person we interviewed described the director general’s intervention as a “game changer”. We agree to some extent. The activities resulting from these letters have contributed to improving law enforcement agencies’ responses to OIC. However, not everything the director general requested has been done.

The director general’s first letter to chief constables

In his letter of 5 October 2021, the NCA director general directed chief police officers to implement seven measures to improve their response to OIC.

The chief constables were asked to:

• collect and manage community intelligence;
• adopt more proactive investigations;
• encourage the use of the National Response Plan;
• improve intelligence debriefs of migrants;
• gather intelligence about small boats;
• make sure that police share information with Border Force and Immigration Enforcement; and
• make sure that disruptions are recorded.

The director general’s second letter to chief constables

In his letter of 6 January 2023, the NCA director general recognised that police forces had made some progress, but the objectives hadn’t been fully met.

His letter again emphasised that the tasking related to all types of immigration crime. It stated that OIC was a problem for every force as migrants dispersed into local communities.

This letter stated police forces should:

• proactively collect and record OIC community intelligence and make sure it is retrievable through data searches;
• respond to the improved intelligence by proactively targeting suspects locally or, where applicable, referring opportunities for regional or national response;
• support ROCUs to provide intelligence assessments for use in national and regional tasking;
• increase disruptions against identified organised crime groups;
• improve the collection of covert intelligence relating to OIC; and
• improve the debriefing of illegal migrants.

Measures discharged and objectives not fully met

At the March 2024 NSTCG meeting, the NCA decided to discharge most of the tasking measures in the two letters. The two remaining related to the collection of community intelligence and increasing disruptions.

As we explain later in our report, our inspection findings don’t fully support the decision to discharge some of these measures.

Initial response, information and intelligence

The initial police response to immigration crime incidents

We were pleased to find that most police personnel we interviewed knew what to do when dealing with an immigration crime-related incident. This has improved since the earlier findings of a peer review process carried out by the Modern Slavery & Organised Immigration Crime Unit (MSOICU).

The National Response Plan is generally well understood

In February 2021, the MSOICU introduced the National Response Plan (NRP) to improve the initial response to suspected immigration crime incidents. It identifies actions police and relevant partner organisations should take when dealing with these incidents.

It includes the response to:

• inland incidents, such as migrants being discovered hidden in a vehicle or when migrants self-present to the authorities; and
• maritime (vessel-related) and aviation (light aircraft) incidents.

The NRP concentrates on the welfare and safety of migrants, and aims to maximise the collection of intelligence and evidence. It includes advice for first responders in categories including crime scene investigation, legislation, counter terrorism and dealing with unaccompanied children.

We carried out reality testing in police control rooms and with operational teams. Generally, police force control room personnel and incident managers understand the requirements of the NRP. Many police forces also have guidance for operators built into their command-and-control systems. We were pleased to find that most frontline police personnel knew what to do when dealing with immigration crime incidents.

Police work well with Immigration Enforcement but some intelligence opportunities are being missed

In 2006, Immigration Enforcement established the National Command and Control Unit (NCCU) that police should contact when dealing with a suspected immigration crime incident. The NCCU leads early discussions between the police and Immigration Enforcement staff to agree how the case will be progressed.

The NCCU told us that from June to September 2024, the police contacted it on 441 occasions, involving contact with 708 suspected irregular migrants.

Most personnel we spoke to in police forces understood the role of the NCCU. However, we did speak to some who weren’t aware of the unit or were unclear about who was responsible for what. Similarly, NCCU personnel told us that they sometimes found officers from forces where such incidents were less common had less understanding.

Police officers should complete and return an intelligence document to the NCCU explaining the circumstances of an incident. From June to September 2024, the NCCU sent 44 intelligence documents to police forces. Only 14 were returned. The NCCU told us that intelligence may be missed because of this.

Gathering intelligence from migrants

Opportunities to gather intelligence from irregular migrants are being missed

There is an established process for receiving migrants who make it at least halfway across the English Channel (reaching the ‘median line’, which separates UK and French territorial waters) in small boats, or who are recovered to the UK by search and rescue services when directed to by the Maritime and Coastguard Agency.

The process is designed to handle large numbers of migrants and effectively meets welfare and humanitarian needs. However, irregular migrants who use small boats (as well as some other methods) are highly likely to have paid members of organised crime groups (OCGs) to arrange their transport to the UK.

This means that they are potential witnesses and a valuable source of intelligence. But we found the overall approach to intelligence gathering was neither effective nor robust enough. This means both intelligence and investigative opportunities are being lost.

A joint control room tracks small boats across the English Channel using a range of technology

During our inspection, we visited several locations on the south coast of England where personnel were involved in the response to migrants who arrived in small boats. This included a joint control room that monitored information from several sources, including aircraft, drones and fixed cameras. Personnel in the control room could directly contact officials in France. As a result, UK authorities can quickly identify and respond to most small boats crossing the English Channel in the direction of the UK.

We were told that migrants crossing the English Channel usually alerted UK authorities to their presence once in UK territorial waters. The authorities then arrange for the migrants to be taken to Western Jet Foil, an arrival point in Dover.

Border Force’s Small Boats Operational Command manages the reception process. Personnel initially detain migrants under Schedule 2 of the Immigration Act 1971 (the administrative power). Immigration Enforcement staff only arrest individuals under section 24 or 25 of the 1971 Act in the most serious cases, or if they suspect the individual had been the boat’s pilot.

The process to verify the identity of irregular migrants should be improved

Border Force officers at Western Jet Foil initially concentrate on the safety and welfare of arrivals. All staff had received safeguarding training. Some had also been trained in behavioural detection. Border Force staff then transfer arrivals to the Manston processing centre for a maximum of 24 hours. Family members stay together. Following border security checks and welfare interviews, local authority children’s services manage any unaccompanied children using child safeguarding procedures.

Border Force staff at the Manston processing centre carry out checks on all arrivals. They take fingerprints and photographs, and check them against several intelligence systems including:

• the Police National Computer;
• the Immigration and Asylum Biometrics System; and
• counter terrorism data sets.

Once staff have completed the checks, they release migrants to accommodation throughout the UK. Some migrants must regularly report to a Home Office reporting centre or a police station. The National Asylum Intake Unit is responsible for managing ongoing reporting conditions.

We found that Border Force staff at Manston had no direct access to the Police National Database (PND) so couldn’t use it during migrant arrival checks. This means that any migrants who had been arrested in the UK before, or whose facial imagery had been captured at a crime scene, wouldn’t be identified at Manston.

The PND holds approximately 6.2 billion records from 250 databases. Police forces upload images of people following arrest for a crime. These are known as custody images. The PND includes 19.3 million custody images that law enforcement agencies can instantly search. Not using this is a weakness in the migrant arrival process.

Counter terrorism policing

This inspection examined how law enforcement agencies disrupt criminal groups facilitating organised immigration crime (OIC). We didn’t inspect any elements of counter terrorism policing. However, we did speak to several counter terrorism managers because they had personnel based at some airports and ports.

Senior counter terrorism policing officers told us that processes at Western Jet Foil and Manston had improved. However, they too were concerned about the lack of automated facial-recognition technology in use. They also expressed concerns that the 24-hour detention time limit sometimes affected their ability to investigate people they were interested in.

Improvements should be made to the intelligence debriefing process for arriving migrants

Law enforcement agencies should increase the proportion of irregular migrants that they debrief for intelligence on arrival. We understand that it isn’t possible to debrief every migrant who has arrived illegally. However, it is likely that arriving migrants will have communicated with and probably paid organised criminals to arrange their crossing. So, these debriefs represent a significant opportunity to gather intelligence about the criminal groups responsible for OIC.

Debriefs should be carried out in a co-ordinated way and by experienced personnel

The Joint Debriefing Team (JDT) is a Home Office unit responsible for debriefing irregular migrants who have arrived in the UK. Personnel concentrate on gathering intelligence about the criminals behind OIC, who they are, their structures and the methods they use to get people into the UK.

JDT personnel are based in several locations throughout the UK and carry out debriefs at a variety of sites including:

• UK ports;
• immigration centres; and
• prisons.

Additionally, JDT personnel are sometimes deployed to UK border control in Coquelles, France.

All intelligence debriefs are confidential and voluntary and aren’t limited to irregular migrants who arrived in small boats. No debriefs are carried out at Western Jet Foil or Manston processing centre. This is for several reasons, including the volume of arrivals, lack of suitable facilities and availability of interpreters.

JDT personnel approach migrants after they have left Manston processing centre. They don’t debrief children under 16 unless requested by other agencies. The JDT prioritises migrants who expressed a willingness to be interviewed when they arrived. However, it also approaches other migrant arrivals when, for example, they suspect that the migrant was the boat pilot or an agent.

JDT personnel told us that during 2023, they approached 5,000 migrants and approximately half agreed to be interviewed. During 2023, the Government recorded 36,704 irregular migrant arrivals. So fewer than 1 in 15 migrants are debriefed.

We heard that the JDT had collaborated with police forces and regional organised crime units (ROCUs) to carry out debriefs at migrant detention centres. We also found that the MSOICU had given police forces funding to carry out migrant debriefs. This was to support the National Crime Agency (NCA) use of powers under the Crime and Courts Act 2013 to give police forces the task of tackling OIC. As a result, police personnel had carried out some debriefs at locations such as hotels.

It is important that law enforcement agencies carry out interviews with irregular migrants in a co-ordinated manner. Some people we spoke to told us that there was a risk of multiple agencies trying to speak to the same person or inexperienced personnel going to carry out the interviews.

Electronic devices should be examined for intelligence

We were concerned to find that at the time of our inspection, there was no effective legal power to seize and examine mobile telephones or other electronic devices from migrants to search for intelligence.

Migrants’ electronic devices may have valuable information about the criminals they have been in contact with before crossing, how they paid them, the modes of travel and the routes used. So it is important to examine the devices for evidence and intelligence about the organised criminals who profit from immigration crime.

Section 15 and Schedule 2 of the Illegal Migration Act 2023 included a new power to seize and retain devices, and then examine them. At the time of our inspection, this hadn’t begun.

After the general election, the new Labour Government stated it would repeal the legislation because of its provisions to deport migrants to Rwanda. As a result, the powers to seize and retain devices also haven’t been implemented.

The findings of our inspection demonstrate the importance of introducing this provision under section 15 of the 2023 Act, if that is possible, or with a comparable provision as soon as practical. We were therefore pleased to see the introduction of the Border Security, Asylum and Immigration Bill on 13 February 2025. Sections 21 to 25 of this bill contain such a provision.

Case study 1 highlights the value of intelligence found on recovered electronic devices.

In another case, we heard that the NCA had supported a manslaughter investigation following the deaths of migrants crossing the English Channel. Investigators from the NCA interviewed survivors and examined mobile devices that they had recovered. Investigators found the details of someone suspected of helping the crossing in several of these devices. The investigation team used this information to support the criminal investigation.

Another example involved Immigration Enforcement staff recovering evidence from a mobile phone that proved who was the pilot during a small boat crossing. This led to an early guilty plea at court.

Equipment and property recovered following small boat crossings is being considered for potential evidence and intelligence

We found that there was a proportionate approach to the recovery and examination of equipment and property following a small boat crossing.

Border Force staff at Western Jet Foil seize all small boats used during crossings to examine them for potential evidence. Staff carried out a two-month trial of forensically examining the recovered boats. They showed that factors such as salt water and spilled fuel degraded potential DNA evidence. As a result, forensic experts only examine the recovered small boats if the crossing resulted in any fatalities.

Border Force staff also document all property belonging to migrants, including valuables such as phones and jewellery. They seize items they find if they think they are evidence of crime. They deal with any substantial amounts of cash under the Proceeds of Crime Act 2002. Staff also carry out checks on items such as the boats and engines to try to establish where they were manufactured and who had purchased them. They then develop any intelligence they find to identify lines of enquiry for new or ongoing investigations. In one example, an engine was found with a label showing the supplier was from Spain.

Not all police forces and ROCUs have satisfactory arrangements for collecting and analysing intelligence

Some police forces and ROCUs have prioritised OIC and included it in their strategic governance arrangements. For example, we found that the north-west regional control strategy included OIC. The North West ROCU had a strategic governance group that all six police forces in the region attended. We were pleased to find that a senior manager from Immigration Enforcement chaired this group. One interviewee told us that working closely with Immigration Enforcement had been “the best thing” for tackling OIC regionally.

In June 2023, Bedfordshire Police produced a threat assessment specifically covering OIC. The force had also developed an OIC intelligence collection plan, which included OIC vulnerabilities and hotspots. Working with Crimestoppers, the force had placed posters at relevant locations such as Luton Airport and motorway service stations. These posters included a QR code that allowed people to submit intelligence in several different languages. Bedfordshire Police told us that OIC intelligence submissions had increased significantly since it introduced these posters. The force had also presented its strategic threat assessment at the 2023 national OIC conference.

However, we found that not every police force and ROCU we visited considered OIC a priority. During interviews with personnel from various roles we often heard similar concerns. These included:

• no intelligence collection plan;
• a lack of, or complete absence of, dedicated analytical resources;
• no OIC problem profiles; and
• limited access to data held by partner agencies.

Our findings were broadly consistent with the National Strategic Tasking and Coordination Group’s decision not to discharge the NCA tasking measure about collecting community intelligence.

We accept that police forces face many and varied challenges. But if the response to OIC is to improve, police need to make it a higher priority. It is highly likely that many police force areas, including those without coastlines and ports, will have detected and undetected irregular migrants living there. It is also probable that some communities will include OCG members or people who are or have been in contact with OCGs. All police forces should make sure they actively collect, analyse and share information relating to OIC.

Information sharing

Agencies aren’t sharing information about immigration crime as effectively as they should

All the bodies concerned with tackling OIC have their own IT systems and they don’t connect with each other. We often encounter these problems during our inspections. So, we weren’t surprised to find examples where agencies had found it difficult to share information.

On one police force visit we heard that data held by partner agencies wasn’t easily accessible. During a focus group at one of the ROCUs, we were told there was no formal process for sharing intelligence at strategic or operational levels. This meant there was a lack of consistency when information from partner agencies was used to prepare strategic assessments and plans.

During several of our police force visits we heard that the NCA hadn’t shared much intelligence with them. If it had, it was primarily focused on small boat crossings. An interviewee in one force even stated that the NCA and Border Force didn’t share OIC intelligence with them. While we doubt the veracity of this statement, it does underline the problems faced by separate bodies, with disparate, unconnected IT systems, trying to work together. The National Assessment Centre is an NCA intelligence function. Staff from the National Assessment Centre told us that they had produced several intelligence assessments relating to OIC. They also monitor the impact of law enforcement activity on OIC and changes to supply routes and the cost of equipment such as boats and engines.

We found that Home Office Intelligence personnel produced several strategic and analytical documents about various aspects of OIC. These include:

• a bi-annual strategic threat assessment that highlights current and future threats to the UK border and immigration system;
• a quarterly strategic threat update that identifies any emerging trends in OIC threats;
• a monthly assessment about the abuse of air routes; and
• a fortnightly intelligence update about small boats.

We found these documents to be informative. However, they were compiled solely from intelligence held by the Home Office. In essence, nobody was joining the dots. In November 2023, the NCA created the Joint Fusion Cell (JFC) to address this. This joint venture with Home Office Intelligence and Immigration Enforcement now provides an intelligence co-ordination function.

The JFC is a positive development but improvements in how it operates are needed

Most of the people we spoke to during this inspection were positive about the JFC and believed it would improve the quality of intelligence. For example, during a focus group, representatives from partner agencies told us that the JFC would help to create a single version of facts and simplify the current system.

We were pleased to find that the NCA had created the JFC. We also accept that it is new and continuing to develop. But we found that several issues were limiting its effectiveness.

The JFC should consist of 30 staff from the NCA and Immigration Enforcement. We heard that recruitment had been difficult. At the time of our inspection, several vacancies remained. We heard that the main reasons for this related to pay and the loss of some allowances for Immigration Enforcement staff.

Most of the intelligence received at the JFC came from the Joint Debrief Team, Small Boats Operational Command, Border Force, NCA, police forces and ROCUs. The JFC had an on-call function that allowed it to deal with urgent matters in under 24 hours. It processed most non-urgent examples within 30 days.

We carried out interviews and focus groups with personnel from the JFC. Some told us they were frustrated with the IT systems. They were only able to access their own organisation’s IT systems and there was no formal agreement or process to share intelligence with each other. Short-term informal solutions were in place to remedy this, but it clearly remained a problem.

In another unsatisfactory situation, the JFC was copying intelligence relating to small boats onto a spreadsheet. Only one person at a time could access it. As a result, staff had to use several versions of the spreadsheet at the same time, which they then had to merge to create a complete version.

The JFC had no dedicated analytical staff. This means that when staff need any analysis, they must ask for support and are in competition with other NCA departments for valuable resources. Several JFC staff members we spoke to felt they would benefit from their own analytical staff.

A JFC staff member told us about an example where another agency shared information with the JFC about a mobile phone seized during an arrest. Staff from the JFC analysed data found on the mobile phone and identified OCG members involved in facilitating small boat crossings. In July 2024, several members of the OCG were arrested for OIC offences because of this information.

Gathering intelligence from overseas and online sources

Co-operation with overseas agencies is improving

During our inspection, we heard several examples of law enforcement agencies successfully gathering intelligence and carrying out investigations overseas. The NCA and Home Office Intelligence have staff based overseas. Along with Home Office and Foreign, Commonwealth & Development Office officials, they work with overseas agencies to secure international law enforcement co-operation. We were told that relations with overseas governments and law enforcement had improved considerably in recent years.

Law enforcement agencies are trying new methods to disrupt OIC

UK law enforcement agencies recognise that simply continuing with traditional investigation methods won’t significantly reduce OIC. The Operation Laserblue initiative, led by the Home Office and the NCA, tackles the illegal movement of migrants by targeting the supply and availability of equipment such as boats and engines.

They have worked with authorities in other countries seen as important to the movement of equipment and migrants, including China, France, Belgium, the Netherlands, Germany, Bulgaria and Turkey.

Authorities in Germany have piloted the use of their public protection powers to seize small boats that they believed criminals were going to use to transport migrants across the English Channel.

At the time of our inspection, the NCA hadn’t reviewed and evaluated the results of Operation Laserblue (but may have done since). However, we did hear about some successes, including the cost of a small boat engine increasing significantly and Bulgarian authorities agreeing to seize small boats at their border.

In July 2021, the NCA established a joint intelligence cell with French authorities. UK and French staff work together in northern France to target and disrupt OCGs. At the time of our inspection, the NCA and Home Office had several staff based with authorities in Paris and Calais. Overall, the NCA had 169 staff stationed around the world, 40 of these were working specifically on OIC. In 2024, these staff recorded 215 OIC disruptions.

In August 2023, the NCA led a week of action collaborating with French authorities, aimed at identifying criminals based in France who were helping small boat crossings. Similarly, in June 2024, the NCA worked with authorities on the border between Turkey and Bulgaria to target the movement of small boats and engines.

We also heard about some of the work Home Office Intelligence staff were carrying out overseas. Staff are based in 40 locations worldwide and focus on OIC. For example, they told us about their work with overseas agencies and airlines to tackle illegal migration by air routes. They told us that, during the 2023/24 financial year, they had recorded 115 disruptions to this type of immigration crime mainly originating in Asia (and many other disruptions relating to other forms of OIC).

Work has been carried out to remove online advertising of illegal migration

The Online Communication Centre (OCC) is an NCA-led function. It has worked with social media companies to target criminals advertising online. The OCC searches a range of platforms using key words in a variety of languages. When it identifies posts relating to OIC, it applies to social media providers to have them removed. We heard that between November 2021 and April 2024, the OCC asked social media companies to remove approximately 10,000 posts believed to relate to OIC. The social media providers have been supportive, removing over 95 percent of suspect posts within 5 days.

There is too much focus on small boat crossings

Throughout this inspection, we often heard that the Government and the NCA were too focused on small boats crossing the English Channel. Some interviewees told us that this may lead to missed opportunities in other areas of immigration crime, such as clandestine vehicle entries into the UK. This was also raised during a focus group with partner organisations in a ROCU. We were told that too much focus on small boats meant that a complete picture of all types of OIC wasn’t available.

Successful targeting of small boat crossings may lead to criminal groups adapting their approach and increasing their use of other methods. It is therefore crucial that UK law enforcement agencies focus on all methods being used by criminals to arrange for migrants to illegally enter the UK. To some extent, the NCA’s national control strategy document, and objectives set in the NCA’s strategic action plan, represent an attempt to do this; both cover several forms of OIC.

We did hear about two multi-agency gateway hubs in Kent and Humberside. Their aim is to gather intelligence to identify and disrupt criminal activity, including OIC, at UK ferry ports using freight traffic.

These hubs include several agencies such as Home Office Intelligence, the NCA, police forces, Border Force, Immigration Enforcement and His Majesty’s Revenue and Customs. Personnel at these hubs prepare intelligence packages which they share with UK law enforcement agencies and overseas organisations. Home Office Intelligence told us about an example when a hub provided an intelligence briefing that led to authorities searching several road freight vehicles in the UK and France. Six migrants were found hidden in them.

Police National Database

The Police National Database (PND) is a national information management system. There are 55 law enforcement agencies that use it to improve their ability to manage and share intelligence and other operational information. It holds approximately 6.2 billion records from 250 databases.

Immigration crime intelligence submitted to the PND has increased

During this inspection we sought to establish what information about OIC was available through the PND. We found that inconsistencies in the way agencies recorded information adversely affected the quality of the results that we obtained.

We were pleased to find that since the Crime and Courts Act 2013 tasking to police forces began in October 2021, the number of OIC intelligence reports submitted to the PND had increased. Between 5 October 2019 and 5 October 2021, only one information report had been submitted by an agency and then uploaded to the PND. Between October 2021 and 24 June 2024, the number of reports submitted had increased to 3,089. While the figures are a positive step, this remains low for a national priority. As we have already stated in this report, police forces should do more to collect OIC intelligence locally.

Law enforcement agencies should submit intelligence more accurately to improve data quality

The results of our PND searches were adversely affected by poor data quality. We believe that law enforcement agencies should submit intelligence about OIC more accurately. This will make it easier for professionals to retrieve and analyse information about OIC.

Identifier codes attached to PND submissions make it easier to search for and retrieve information. An OIC intelligence identifier code was introduced in August 2023, but we found that many intelligence submissions were made without it. Mandating the use of the OIC identifier code for all agencies would improve the quality of available intelligence to support OIC investigations.

We heard about a similar recent example. Police forces added the OIC identifier code to intelligence submissions relating to firearms. This resulted in a dramatic increase in available intelligence to support operational activity as well as reducing duplication for personnel.

Enforcing the law and disrupting the activities of organised immigration crime groups

Investigating organised crime groups

Organised crime groups aren’t always prioritised for active investigation

We were surprised to find that most known organised crime groups (OCGs) believed to be involved in organised immigration crime (OIC) weren’t being actively investigated.

Law enforcement agencies should record information about every OCG they identify on the Police National Database (PND). We examined this PND data. While it was affected by the data quality problem described above, we found that on 24 June 2024 there were 56 identified OCGs recorded with OIC as their primary criminality. Most of them (51) were assigned tier 4, the lowest level of priority. Groups at tier 4 generally attract a passive response, mainly the scanning of intelligence to identify opportunities to disrupt them.

The agency and partner management information system, and the single picture of demand

In our previous PEEL inspection reports, we have referred to how well police forces have managed and mapped or assessed OCGs. We refer to serious and organised crime (SOC) threats, which encompass OCGs, SOC priority individuals and SOC vulnerabilities.

This reflects changes introduced nationally to provide a “single picture of demand”. This has been achieved by setting up a national database of SOC threats called the SOC master list, which is held on the agency and partner management information system (APMIS). This is used to assess which SOC threat is a priority for each agency or police force. It holds information from the National Crime Agency, regional organised crime units (ROCUs), police forces and government agencies that tackle SOC. APMIS is also where police forces, ROCUs and other agencies should record their disruption activity against SOC threats.

OIC is sometimes given a low priority grade on the national database for serious organised crime

We examined APMIS data relating to known OCGs. OCGs recorded on APMIS aren’t necessarily mapped in the same way as OCGs on the PND so the figures on each system don’t necessarily match.

On 1 May 2024, there were 338 SOC threats linked to OIC on APMIS. Of these 111 were linked to OCGs and 79 had OIC as their primary criminality.

SOC threats recorded on APMIS are assigned one of four priority grades (P grade). OCGs posing the highest risk, often with international elements, are normally graded P1. More local and lower risk groups are usually P3 or P4. We were concerned to find that the 79 OCGs with OIC as their primary criminality attracted a generally low priority.

Figure 1: Number of organised crime groups by priority grade in England and Wales

Priority grade	Number of organised crime groups
P1	0
P2	14
P3	31
P4	34

Source: Agency and partner management information system (APMIS), data extracted 10 September 2024

Existing arrangements for prioritising OIC are limited

These priorities are largely derived from management of risk in law enforcement (MoRiLE), a system that law enforcement agencies use to help to help them consistently assess and prioritise risk. Some interviewees told us there were problems with the current way of assessing the level of risk that OCGs present. They explained that immigration crime OCGs often didn’t score as highly as groups involved in firearms or drug supply.

We often hear similar concerns during our SOC inspections in police forces and ROCUs. We have heard examples of police force personnel using their professional judgment as an alternative to other scoring methods such as MoRiLE.

Intelligence and priorities: a vicious circle

Part of the explanation for the low priority given to OCGs involved in OIC may be limitations in, or the absence of, current or detailed intelligence about them. This amounts to a vicious circle. The lack of intelligence collected undermines the prioritising process. As a result, OCGs involved in OIC aren’t always investigated, which in turn means there continues to be limited intelligence on these groups.

In the section on Initial response, information and intelligence, we recommended that police forces increase their local intelligence collection efforts. This would improve their knowledge about any OCGs involved in OIC. Law enforcement agencies should then use their existing tasking and co-ordination processes to target these OCGs using specialist resources.

We recognise that several factors, including the use of multiple databases by several parties, make this a significant undertaking that requires time to achieve.

Law enforcement agencies should use a variety of approaches to effectively tackle immigration crime

UK law enforcement agencies face unique challenges when tackling the organised criminals who make possible illegal immigration. Most interviewees told us that illegally entering the UK without some help from OCGs would be difficult.

We heard that most members of these OCGs, particularly the senior ones, were based overseas. Even if there is an element based in the UK, it is generally smaller, making targeting and enforcing UK law problematic. Additionally, many of the items used to support small boat crossings aren’t ordinarily illegal, such as boats, engines and flotation aids.

Given the difficulties inherent in tackling overseas-based criminality, we were pleased to see that the NCA had achieved several notable successes. See case study 2.

Other examples of international work are encouraging. But, as we highlighted in the section on Investigating organised crime groups, law enforcement agencies have identified and assessed somewhere between 56 and 300 UK OCGs involved in OIC. The police, NCA and other bodies all carry responsibilities to enforce the law against these groups.

It is vital that law enforcement agencies take a wider approach to immigration crime

There are other well-established approaches that law enforcement agencies should take. The Government’s SOC strategy advocates using the 4P approach to:

• pursue offenders through prosecution and disruption;
• prepare for crime occurring and mitigate the impact;
• protect individuals, organisations and systems from the effects of crime; and
• prevent people from engaging in criminal activity.

It is vital that law enforcement agencies take the same approach when tackling OIC. The NCA’s strategic action plan for tackling OIC is set out under the 4P headings to make sure that all law enforcement agencies use a broad range of tactics to reduce and prevent OIC. This included improvements in:

• intelligence collection and assessment;
• understanding of how OIC is funded; and
• disrupting the highest-harm networks using small boat crossings from Europe to the UK.

We heard that Greater Manchester Police was using a 4P plan to disrupt criminal finances of OCGs involved in OIC. The force was working with the NCA and the National Document Fraud Unit to identify assets and cash for potential seizure.

Initial response and reactive investigations

The National Response Plan is working well

Immigration Enforcement Criminal and Financial Investigation (CFI) teams lead most reactive immigration crime investigations. These normally start after UK authorities have discovered migrants entering the UK illegally. Generally, we found that personnel in the various agencies we visited understood the National Response Plan process and it was working well.

Once alerted to a case, Immigration Enforcement personnel decide how best to progress the investigation. For example, police officers should contact the National Command and Control Unit (NCCU) when they discover a person they think has entered the UK without clearance. The NCCU then connects them with the on-call CFI team member who will advise the police officers.

Personnel don’t always understand who is responsible for investigations

We found that there was a clear process to allocate discovered immigration crime offences for investigation. However, we did find some examples of police personnel not fully understanding which agency was responsible for investigations.

In most instances, ownership for criminal investigations is as follows:

• The NCA investigates the most complex facilitation offences (section 25 of the Immigration Act 1971), and leads overseas and online investigations.
• Immigration Enforcement’s CFI teams take responsibility for investigating most offences under section 24 and 25 of the Immigration Act 1971.
• Immigration Enforcement’s Immigration Compliance and Enforcement teams take responsibility for cases involving people illegally present in the UK who may be liable for administrative removal under paragraph 16 of Schedule 2 of the Immigration Act 1971.
• Police forces manage the initial response to OIC incidents and deal with any safety concerns, particularly for children; they always investigate offences involving fatalities.

There have been successful joint investigations by police and Immigration Enforcement

In October 2022, Lancashire Constabulary and Immigration Enforcement commenced a joint investigation Operation Thuton. They had detained a foreign national who had claimed asylum and had counterfeit currency. Investigators developed intelligence that revealed that the suspect was involved in OIC. They proved that he was part of a gang that was bringing irregular migrants into the UK at Dover using vehicles, then taking the people to the north-west of England. The investigation team made several arrests. At the time of our inspection, the suspects were released under investigation while Immigration Enforcement officers asked for charging advice from the Crown Prosecution Service.

There are few police-led investigations

We often heard that police forces weren’t managing many ongoing OIC investigations. We also heard that on occasions, law enforcement agencies had missed opportunities to investigate people for immigration offences. For example, an Albanian crime group was only investigated for drugs offences, even though there was evidence relating to immigration crime.

Not everybody found by law enforcement agencies to have entered the UK illegally is prosecuted. This is for several reasons, including the capacity of investigation teams and the public interest considerations we described in the section on Immigration-related legislation. And it is Home Office policy to use administrative powers of removal to deal with people who enter or remain in the UK illegally.

Proactive investigations

The number of proactive investigations needs to increase

We were concerned to find very few examples of police forces or ROCUs proactively targeting OCGs involved in OIC.

As we explained in the section on Initial response, information and intelligence, we found police forces weren’t always collecting and analysing local intelligence. This may have led to law enforcement agencies not identifying all the OCGs involved in OIC, or not gathering all the available intelligence about those that are known.

Senior leaders in charge of tasking and co-ordination meetings rely on high-quality intelligence to make their decisions. Without that intelligence, OCGs can’t be accurately assessed or allocated for investigation by specialist teams from police forces, CFI teams, ROCUs or the NCA.

The NCA has specialist teams investigating OIC

During this inspection, we visited the NCA branch office that focuses on OIC investigations. It has three operational teams. At the time of our inspection, they were collectively managing 17 investigations, 11 of which related to OIC. The teams had experience in carrying out covert investigations and could access support from other departments of the NCA when required.

Personnel in the teams told us they had good working relationships with police forces and ROCUs. The investigation teams weren’t specifically using 4P strategies, but were aware of other considerations, such as safeguarding. Some personnel told us they had access to specialist child protection advisors.

However, we did hear that the teams faced some challenges. As with other NCA teams, the investigation teams often operate with staff vacancies. This has caused delays in some investigations. We also heard that a lack of dedicated analytical staff had at times delayed investigations.

We heard from one manager that NCA IT systems were out of date and slow. One example highlighted that the NCA is unable to electronically transfer files to the Crown Prosecution Service.

The OIC investigation teams had two dedicated financial investigators. We heard that financial investigations could be difficult. For example, suspects often live overseas and investigators don’t know their real names. Investigators also highlighted that the use of alternative banking systems made investigations difficult.

Law enforcement agencies in other countries often support overseas investigations

When UK law enforcement agencies investigate the criminals behind immigration crime, it is often essential that they share intelligence and work collaboratively overseas. The NCA leads most overseas investigations.

In the chapter covering intelligence, we highlighted some of the ways UK law enforcement agencies work with overseas partners. During this inspection, we heard several examples of how the NCA was using the 4P approach to disrupt overseas OCGs. Law enforcement agencies in other countries often support these investigations (see case study 3).

In one example in June 2023, the NCA arrested three suspects believed to be responsible for bringing migrants into the UK in vehicles and small boats. Staff from Border Force and the NCA investigated the suspects and linked them to several Channel crossings. This included one in August 2022 when 46 migrants were intercepted by UK authorities on a small boat.

We heard that the NCA investigated a group that was supplying small boats being used to support illegal migration to the UK. The NCA worked with Belgian authorities to arrest a man who was prosecuted in Belgium and sentenced to 11 years in prison.

In another example, we heard that NCA staff based overseas had worked with officials throughout Europe. They identified equipment, such as boats and engines, that criminals were planning to use for small boat crossings. They tracked it from Bulgaria to Germany, where local law enforcement personnel seized it. We also heard that authorities in Bulgaria had introduced new legislation allowing for the seizure of any undeclared small boats and equipment. It is important that work such as this continues.

Law enforcement agencies have substantially increased the number of disruptions relating to OIC

We were pleased to find that since the Crime and Courts Act 2013 tasking to police forces began in October 2021, the number of disruptions relating to OIC recorded had increased substantially.

We examined disruption data recorded on APMIS between 1 January 2020 and 31 August 2024. Police forces recorded a total of 2,028 disruptions on APMIS. During the same period 3,873 disruptions were recorded by other agencies such as the NCA, Border Force, Immigration Enforcement and Home Office Intelligence.

Figure 2: Number of organised immigration crime disruptions by year recorded on APMIS by police in England and Wales between 1 January 2020 and 31 August 2024

Source: Agency and partners management information system (APMIS), data extracted 10 September 2024

Note: The 2024 figure only includes data to 31 August, so will increase further.

Police are taking a more active role, but four forces are doing most of the work

We noted that four police forces – Surrey Police, Thames Valley Police, Northamptonshire Police and Sussex Police – had submitted 62 percent of the recorded disruptions. Several police forces had submitted less than ten disruptions in the period we examined. Consequently, while we recognise the significant increase in disruptions being recorded, we conclude that the majority of police forces should do more.

Organisational learning, including training officers and staff

Training for frontline personnel

Police forces are providing training for officers and staff

In the section of this report on The initial police response to immigration crime incidents, we described finding a good understanding and implementation of the National Response Plan (NRP). This was especially the case with police control room personnel and incident managers. This is important. If personnel directing the response to possible immigration crime incidents are aware of the plan, they can guide the officers and staff dealing with them.

During our visits to police forces, we found that some of them had included guidance about organised immigration crime (OIC) in their initial training courses. This is an effective way of improving frontline personnel’s understanding of OIC and how they should respond to incidents. Police forces should include, on their intranet systems, information covering what to do when responding to suspected immigration crime incidents. This will support personnel dealing with incidents out of normal working hours.

We found some good examples of police forces providing training and guidance for frontline officers and staff. For example, we heard that officers in Sussex Police had access to a system called Crewmate on their mobile devices. The system provides officers with guidance on what they should do when attending a possible immigration crime incident. We found the information it held was detailed and included material about the NRP.

We were also told that the specialist lead for OIC in Greater Manchester Police had shared good practice on the force intranet. This included guidance on how fraudulent documentation is used. The force has also distributed OIC how-to cards to all frontline officers. These cards include a description of what constitutes OIC and guidance on:

• initial actions that officers should take;
• how to contact the National Command and Control Unit; and
• how to address concerns in respect of fraudulent documentation via the National Document Fraud Unit.

Police forces should more widely use the Modern Slavery & Organised Immigration Crime Unit training package

The Modern Slavery & Organised Immigration Crime Unit (MSOICU) has developed a Hydra training package for immigration crime incidents. This is a technology-based, immersive training method that allows attendees to deal with a fictional clandestine lorry-drop incident. It is primarily aimed at managers and investigators, although some frontline personnel have also attended the course. Although immigration crime incidents are relatively rare (compared to volume crime), this is the type of incident frontline personnel are most likely to attend. OIC co-ordinators based in the regional organised crime units (ROCUs) have arranged this training.

During the year ending April 2024, the MSOICU provided 23 training sessions to a total of 316 attendees from a variety of law enforcement agencies including police, ROCUs and the Home Office.

The MSOICU has started to train personnel in police forces to help them provide training in their own forces. At the time of our inspection, the MSOICU had trained 93 personnel from 31 different police forces. We found several examples of forces and ROCUs successfully using the MSOICU package.

Some have developed their own versions. The North West ROCU has provided training to regional police forces. This training covered matters such as document abuse, abuse of legitimate means to enter and remain, clandestine entry, recording intelligence and the required response to clandestine lorry drops. Police forces in the region told us that they valued this training and were continuing to provide it to their personnel.

The unit was planning to introduce a training co-ordinator to manage a combined OIC and modern slavery training programme for 2025/26.

The College of Policing is providing some training for frontline personnel

We found that at the time of our inspection the College of Policing hadn’t provided any training specifically for OIC. However, it is using its online learning resource College Learn to host an e-learning course aimed at raising awareness of OIC for police officers. The MSOICU and the Metropolitan Police Service developed the course. It is aimed at frontline personnel and investigators most likely to deal with immigration crime incidents such as lorry drops. There are four short modules covering:

• an introduction to OIC, how it occurs and the implications for the UK if it isn’t tackled effectively;
• the legislation and powers available to police officers when dealing with an OIC incident;
• the different types of incidents and adopting an investigative mindset when dealing with OIC, plus the role of the Home Office and other partner agencies; and
• an OIC-related case study where course participants explore how they would deal with an OIC-related incident inland.

Some College of Policing staff told us they thought these modules were particularly good and introduced personnel to the challenges of dealing with OIC incidents.

The College of Policing provided us with data showing how many people had completed these modules in each of the 43 Home Office police forces. We were surprised to find that attendance rates varied dramatically. For example, in Greater Manchester Police over 4,000 officers have completed the training. In other police forces the number was in single figures. During our visits to police forces, some leaders told us that the completion of this course should be mandatory for relevant personnel. We agree.

Training for specialist personnel

Levels of training for specialist personnel varies and involvement with OIC investigations improves knowledge

During our visits to ROCUs, we found that the level of training varied. Some were using their intranet pages to circulate advice and guidance about OIC to their personnel. We also found examples of ROCUs sharing nationally produced OIC bulletins to the police forces in their region.

When we visited Immigration Enforcement Criminal and Financial Investigation teams, we were told that they aimed to train all their investigators to level two of the professionalising investigations programme (PIP). We also found that the training and development unit provided a pathway for staff to become accredited. Inexperienced staff are allocated experienced PIP-qualified colleagues as mentors. The turnover of staff and the demands of training new starters presents challenges to Criminal and Financial Investigation managers, which we often find in police forces.

During our visits to National Crime Agency (NCA) departments, some personnel told us that they had received mixed levels of training. We heard that the NCA had included elements about OIC in its two-year training programme for new recruits. During focus groups we heard that being involved in OIC investigations helped with investigators’ awareness and knowledge.

Regional OIC co-ordinators are effective

We found that there were OIC co-ordinators in each of the nine ROCUs. These co‑ordinators are experienced investigators or staff who specialise in modern slavery and OIC. Because of this expertise, they provide advice to investigators from police forces and ROCUs. We heard examples of them connecting investigations across the UK and supporting regional partnerships. For example, in the Eastern region, a collaboration between the ROCU, the NCA, Border Force and the regional police forces led to an increase in intelligence about OIC. Regional co-ordinators are also leading intelligence development operations in locations vulnerable to OIC, such as small airports and coastal areas.

The peer review process

The MSOICU peer review process is valuable, but needs extending

There is a valuable peer review programme underway, but it needs extending. Since late 2022, the MSOICU has carried out peer reviews of Home Office police forces’ response to OIC. Specialist MSOICU staff carry out these reviews. They concentrate on the following areas:

• the police force’s leadership and governance arrangements for tackling OIC;
• intelligence collection and development;
• operational response;
• investigations; and
• training and awareness.

The MSOICU provides the police force with a report and an enhancement plan including recommendations at the end of the review. It encourages police forces to set up a process to implement the recommendations.

The Strategic Policing Requirement February 2023 includes a requirement for all police forces to implement recommendations and good practice identified by the MSOICU peer review programme. We encourage chief constables to comply with this requirement.

Most police forces and ROCUs have responded well to the peer review programme

In September 2024, the MSOICU completed its initial reviews of the 43 Home Office police forces in England and Wales. These reviews identified several areas for improvement, such as lack of awareness about OIC among frontline personnel. The unit found not all police forces were using the NRP in their control rooms and there was a lack of strategic documents and intelligence collection. During our inspection we found most police forces and ROCUs had developed plans to implement the MSOICU’s recommendations. At the time of our inspection, the MSOICU told us that it was planning to carry out revisits to police forces.

We recognise the benefits of this programme and the improvements in the police response to OIC, such as understanding of the NRP and the initial response to immigration crime incidents. However, at the time of our inspection, the MSOICU programme was limited to the 43 Home Office police forces in England and Wales. We think that the MSOICU should extend its reviews to include other police forces such as British Transport Police and the Police Service of Northern Ireland, as well as the nine ROCUs in the UK. Once completed, there should be a schedule for revisits. This will allow the MSOICU to assess how well each police force implemented its enhancement plan.

We also note that the MSOICU only provides its review programme to police forces. It doesn’t include the many other agencies with important roles in tackling OIC. We think that extending this programme or developing something similar for these agencies would also be beneficial.

Back to publication

Improving the response to organised immigration crime