We asked the Treasury and the Bank whether they had undertaken any analysis of how the £350 million loaned to GFG Alliance companies was used, or in which country the money was spent. The Bank told us it was aware that the loans were transferred to a “central treasury function within the GFG Alliance,” but it did not know where this was based. The Bank noted that it “would imagine that the whole tracking of that money through the administration would be something being looked at” but provided no further details.73 The Bank suggested that, if the money had left the UK, this could be a relevant factor in whether the guarantee holds as this may constitute a breach of the scheme rules.74 We asked the Bank whether, at any point, it considered that Greensill might have acted fraudulently. The Bank told us there was not proven fraud at the time Greensill was accredited, although several parties raised concerns later in 2020.75 It confirmed that it was “absolutely looking” into its fraud protocols to determine whether it needed to make any changes before lending money to business in the future.76 Learning lessons from Greensill’s failure