The Department continues to make slow progress on its counter fraud activities related to the Bounce Back Loan Scheme. The Department’s counter-fraud response on BBLS started too late. The Department did not liaise with the Cabinet Office counter fraud function until well after the scheme launched, and had a virtually non-existent counter fraud function of its own at the time the scheme was designed, of two full-time staff. Subsequent Fraud Risk Assessments identified additional fraud risk indicators that weren’t considered at the point the scheme was launched. The Department told us key learning from Bounce Back Loan Scheme has been applied to the Recovery Loan Scheme, although this has fundamentally different features such as industry standard checks in place, and the lack of a 100% guarantee. The Department provided an update on the progress of the National Investigation Service (NATIS), which having been provided with £13.2 million funding, had recovered £5.8 million (which is 0.2% of the total estimated fraud and error for the COVID-19 business support schemes), made 58 arrests and had 558 open investigations at the time we took evidence. Recommendation 3: • The Department should publish its counter-fraud strategy straightaway and make maximum use of available resources, including lender data and lender audits, to target its activity where it can be most cost effective. • The Department should report back to the Committee with the updated results of the spend on counter fraud and the recovery results obtained compared to the level of estimated fraud.