The City of London Corporation is two things at once: the local authority for one square mile of London, and one of the least accountable public bodies in Britain. This is what the public record shows about how it works — and about the national fraud database it runs.
Every fact below is drawn from public sources: legislation, the Corporation's own published accounts, government procurement records, regulators, and the courts. It alleges no illegality. The arrangements described are, as far as the record shows, lawful. The argument is about accountability, not crime — and every claim is graded for how firmly it is sourced.
It runs the nation's fraud database. The City of London Police is the UK's national lead force for fraud, and it runs the National Fraud Intelligence Bureau — the system that automatically analyses and links the country's fraud and cyber-crime reports and routes intelligence to local forces. On 4 December 2025, the old "Action Fraud" service was replaced by "Report Fraud," with a new backend called the National Crime Analysis Service.
The new service — procured as the Fraud and Cyber Crime Reporting and Analysis Service — is delivered by two firms: Capita runs the public reporting and contact-centre layer (a £50m contract to 2029), and PwC is the integrator of the analytics platform underpinning the bureau. The whole-life cost is about £212m over eight years, jointly funded by the Home Office and the City of London Corporation.
And Palantir? Here discipline matters. PwC has publicly described Palantir as its "technology alliance partner" for that platform. But that rests on PwC's own statement to the trade press — not on a primary procurement record — so it is reported, not confirmed, and an independent verification pass could not corroborate the vendor from the contract documents. Palantir, if involved, sits beneath PwC, not as a direct contractor to the police. The honest line is: the national fraud-intelligence platform is being built by PwC, which names Palantir as its partner — a claim to be confirmed by Freedom of Information request, never "Palantir runs the police fraud database."
What is missing is the paperwork that should sit around a system like this. The Report Fraud privacy notice names the police force as data controller but cites only a generic lawful basis — "a task carried out in the public interest and law enforcement purposes" — with no specific data-protection condition, no stated retention period, and no statement about automated decision-making. Only summary versions of its five impact assessments are public. Whether the matching is probabilistic, how accurate it is, and what remedy exists for a wrongful match are all unknown.
It watches the Square Mile — but watch the overclaim. The City pioneered the "Ring of Steel," the cordon of cameras and automatic number-plate readers that has ringed the financial district since 1993. It runs Project Servator, a behavioural-detection patrol tactic — not, despite the impression, a facial-recognition programme. In fact the City of London Police is not on the Home Office's list of forces using live facial recognition: that programme is the Metropolitan Police's, not the City's. The honest surveillance story here is camera density and the absence of published policy, not face-scanning.
It is unaccountable by design. This is where the City becomes genuinely unusual. It is a public authority, but only partly subject to the Freedom of Information Act — and the part it shields is the larger one.
Its historic endowment, long called "City's Cash" and recently rebranded "City's Estate," had net assets of £2,681.3 million as of March 2025. It sits entirely outside the Freedom of Information Act. The mechanism is precise: the Act lists the Corporation only "in respect of information held in its capacity as a local authority, police authority or port health authority," and a provision of the Act then excludes everything else it holds. So the endowment is beyond FOI not by a balanced exemption that weighs the public interest, but by statutory design — there is no public-interest test to apply at all.
The Corporation runs three funds. Only one — the City Fund, around £2.1bn, covering its public-authority duties — is within FOI. The City's Estate (about £2.7bn) and the City Bridge Foundation charity (about £1.6bn) are outside it. The private endowment alone now exceeds the public fund.
It is also the only place in the United Kingdom that still has a business vote. Under the City of London (Ward Elections) Act 2002, companies appoint voters scaled to the size of their workforce; in the 2023–24 register, roughly 13,700 business and employee voters outnumbered about 6,500 residents. Such business franchises were abolished everywhere else in Britain in 1969.
And it keeps an officer inside Parliament. The Remembrancer — an office dating to 1571 — monitors and engages Parliament on legislation affecting the City, as a registered parliamentary agent with a reserved seat in the under-gallery of the House of Commons (by the Speaker's permission). The office is funded from the City's Estate, and so its detailed work is itself beyond Freedom of Information. (One honest caveat: the Remembrancer has no power to participate in, amend, or see legislation before publication — the popular "shadowy lawmaker" image overstates the formal role.)
What has actually been adjudicated. No court has ruled against the Corporation or its police force for unlawful data processing, and there is no enforcement action of any kind on record against the Corporation itself. The strongest watchdog action is an Information Commissioner's reprimand of the police force in February 2026 — but that concerns delays answering subject-access requests, not the fraud database. The fraud operation itself has drawn years of criticism — from the police inspectorate, the Justice Committee, and a 2019 undercover exposure of its call centre (then run by the contractor Concentrix) — but none of it is a finding of illegality. As with the rest of this work, the power of the case is the governance vacuum, not a conviction.
What this is, and is not. A transparency record built from public documents. It alleges no wrongdoing. It keeps the City of London strictly distinct from the Ministry of Justice's Splink programme and the Metropolitan Police's Palantir trial — three different systems that must never be blurred. It names a vendor only where a primary source documents it, and grades the Palantir link honestly as reported rather than proven. Where the record falls silent, the answer is a Freedom of Information request, not a guess.
A business franchise no one else is allowed. A private fortune larger than the public purse, placed beyond Freedom of Information by the wording of the statute itself. An officer who watches Parliament on the City's behalf. And, now, the machinery that links the nation's fraud reports — on a platform the public is not permitted to fully see. None of it is unlawful. That is exactly the point.