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City of London Police were asked to work with the Food Standards Agency (FSA) as part of its inquiry into the scandal. It reviewed evidence from law enforcement agencies in Europe and the UK, as well as from the FSA.
The force launched an investigation in May and said it made the arrests "during the initial stages" of the inquiry. Officers also carried out searches at businesses and homes in the UK.
Detective Chief Superintendent Oliver Shaw, from the City of London Police, said:
Two men have been arrested on suspicion of conspiracy to defraud by detectives investigating the horse meat scandal, City of London Police said today.