Cross-border fraud—encompassing a wide range of deceptive practices from online retail fraud and romance scams to pyramid schemes—poses a significant and growing challenge worldwide. Although evidence of its escalation is clear, strategic policing responses have lagged significantly. Prof. Mark Button and his co-authors, Branislav Hock, Joon Bae Suh, and Chol Soo Koh, address this gap in their detailed study, Policing cross-border fraud ‘Above and below the surface’: mapping actions and developing a more effective global response, published in Crime, Law and Social Change. By examining the diverse manifestations of cross-border fraud and evaluating existing enforcement measures, the authors shed light on urgent reforms needed to combat this pervasive issue.
The Nature and Scale of Cross-Border Fraud
Cross-border fraud has grown into a multifaceted global phenomenon, intertwining traditional deceit with sophisticated digital tactics. It thrives on blurred legal boundaries, rapid technological progress, and the globalisation of commerce—creating ample opportunities for fraudsters to move freely between jurisdictions. This study explores both the variety of cross-border scams and the inherent difficulties in accurately assessing their prevalence, shedding light on why these schemes so often evade detection and punishment.
Cross-border fraud manifests in numerous forms, ranging from online impersonation and cyber-enabled pyramid schemes to large-scale romance scams and “pig butchering” involving cryptocurrency investment. The paper emphasises how technological advancements and the globalisation of financial systems enable fraudsters to target victims across multiple jurisdictions with ease, laundering proceeds in yet another country.
Despite the clear indicators that cross-border fraud is widespread, reliable data remain limited. Legal and operational barriers, along with inconsistent reporting, make it difficult to identify how, where, and to what extent these criminal activities occur. As the authors point out, many victims fail to report scams, and law enforcement agencies often classify complaints according to local frameworks—leading to underestimation of the true scale.
Policing Responses: Above and Below the Surface
The authors draw a distinction between efforts “above the surface” and those “beneath the surface.”
“Above-the-surface” initiatives include those led by governments, intergovernmental bodies (such as Interpol and the European Union agencies), and major national organisations like the FBI in the United States. While these bodies do engage in high-visibility activities—occasional extraditions, raids on scam call centres, and large-scale collaborative operations—they remain under-resourced compared to the vast scale of cross-border fraud. Bureaucratic hurdles, jurisdictional constraints, and low prioritisation contribute to a generally fragmented response.
In contrast, “beneath the surface” policing largely takes place in the private and voluntary sectors. This hidden response includes:
Commercial security and investigative firms assisting clients who have fallen victim to scams.
Large multinational corporations (Amazon, Microsoft, Google, and others) that shut down fraudulent websites and monitor suspicious activities.
Non-governmental organisations and citizen activists—often known as “scambaiters”—who adopt quasi-vigilante methods to disrupt scam operations.
Although these lower-profile efforts can be highly effective at times, they suffer from a lack of central coordination and enforcement powers. Consequently, the overall impact on global fraud prevention remains limited.
Challenges in Combating Cross-Border Fraud
Investigating and preventing fraud that spans multiple countries is notoriously complex, as perpetrators frequently exploit gaps between different legal frameworks and jurisdictions. Inadequate resource allocation, limited international cooperation, and the sheer diversity of fraud typologies further complicate enforcement. The following sections highlight specific obstacles that hinder effective intervention against cross-border scams.
Jurisdictional and Legal Complexities
One of the central barriers is jurisdictional mismatch. Fraudsters can easily operate from countries where local laws are weak or differ significantly in definitions of fraud. Extradition is seldom pursued due to cost, diplomatic hurdles, and often a lack of political will.
Investigative Friction
The authors highlight the stark disparity in “friction” faced by fraudsters compared to investigators. Fraudsters can send mass phishing emails or set up scam call centres with very little overhead. Law enforcement, by contrast, must navigate time-consuming, resource-heavy, and fragmented procedures (e.g. mutual legal assistance treaties, international liaison offices, and foreign language barriers).
Under-Reported Crime and Data Scarcity
Many victims of cross-border scams do not come forward, sometimes from embarrassment or the perception that reporting will be futile. Hence, official statistics are patchy and fail to capture the true scale. This data vacuum weakens policymaking, budgetary allocations, and the development of targeted strategies.
The Need for a Stronger, Integrated Response
Existing attempts to combat cross-border fraud often lack cohesion, as enforcement agencies and private entities work in isolation without a comprehensive, unified framework. This fragmentation allows organised criminal networks to thrive, continually adapting to and exploiting gaps in current approaches. To address these systemic shortcomings, a concerted effort is needed—one that aligns public, private, and non-governmental actors under a shared mandate and pool of resources.
Enhancing International Cooperation
The authors call for a comprehensive global framework that unites public-sector, private-sector, and non-governmental stakeholders. Improved intelligence-sharing mechanisms, common definitions of fraud, and centralized databases could allow law enforcement agencies to coordinate rapidly across borders. This aligns with the growing recognition that the scale of cross-border fraud demands collective action, an effort in which GASA plays a central role.
As Prof. Mark Button emphasizes, “The scale of frauds and scams requires global co-ordinated actions that bring the international anti-scam community together. GASA has already done much to achieve this through their work: exposing the scale of the problem, hosting summits, facilitating the sharing of ideas to developing action plans. Its reach has spread across the globe with events and interest in the Far East, the Americas and Europe. GASA has become central in the tackling of global scams.”
Building a Unified Global Forum
Alongside strengthening existing bodies such as Interpol or the United Nations Office on Drugs and Crime (UNODC), the paper advocates establishing a dedicated international entity—either within or outside existing institutions. Such an entity would:
Host a global forum bringing together law enforcement, private corporations, and NGOs.
Develop an accreditation system for anti-fraud professionals, enabling common standards and faster collaboration.
Encourage research into emerging scams and identify best practices for disruption.
Regulatory Measures and Sanctions
Beyond traditional prosecutions, the authors propose alternative enforcement avenues such as:
Targeted sanctions on financial intermediaries and companies that enable criminal enterprises.
Disruption tactics (shutting down scam-related websites and telephone lines, freezing assets, “naming and shaming” fraudsters).
Civil recovery and regulatory fines, which often involve a lower evidentiary threshold than criminal prosecutions.
Private-Sector Engagement and Vigilante Activism
While private firms and vigilante scambaiters have shown success in disrupting scam networks, their actions need ethical frameworks and consistent oversight. A clearer, formalised set of standards could harness their expertise while minimising legal or moral risks.
Conclusion
The study illustrates the glaring disparity between the breadth of cross-border fraud and the patchwork of responses that barely scratch the surface. The “above the surface” efforts—although occasionally high-profile—remain fragmented and under-resourced, whereas the “beneath the surface” activities, led by private companies and volunteer groups, are rarely consolidated into a strategic global framework.
Ultimately, the authors argue for a new or vastly reconfigured international architecture that unites governments, corporations, NGOs, and everyday citizens to gather intelligence, disrupt scammers, and share best practices. Only through bold innovations, heightened cooperation, and significant investment in enforcement can policy-makers match the ingenuity of cross-border fraudsters and protect millions of potential victims worldwide.
About the Author
James Greening, operating under a pseudonym, brings a wealth of experience to his role. Formerly the sole driving force behind Fake Website Buster, James leverages his expertise to raise awareness about online scams. He currently serves as a Content Marketing & Design Specialist for the Global Anti-Scam Alliance (GASA).
James’s mission aligns with GASA’s mission to protect consumers worldwide from scams. He is committed to empowering professionals with the insights and tools necessary to detect and mitigate online scams, ensuring the security and integrity of their operations and digital ecosystems.
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