Economic crime plan

The UK government’s second economic crime plan aims to reduce money laundering, sanctions evasion and fraud, combat kleptocracy and recover more criminal assets.

The three-year plan contains 43 actions to “strengthen” the UK’s economic crime supervisory regime. The reforms include:

• greater government oversight to “ensure effectiveness and compliance” with the Money Laundering Regulations 2017
• increasing information sharing between the public and private sectors

The plan is partly funded by the economic crime levy, which is collected from anti-money laundering regulated businesses – including law firms.

Small firms are exempt from the levy, following our warnings about its potential impact.

Our view

We welcome the publication of the plan as a step towards strengthening the UK’s response to economic crime.

Solicitors continue to play an important role in the public-private partnership in tackling economic crime.

The profession invests significant resources in tackling money laundering and financial crime.

Encouraging greater information and intelligence sharing will also help to better identify and target criminality to ensure that the UK is a hostile place for illicit finance.

What's happening

In March 2024, the Royal United Services Institute (RUSI) published a report on the progress, pitfalls and prospects of the second economic crime plan.

Progress against the plan’s actions included:

• enhanced Companies House powers introduced by the Economic Crime and Corporate Transparency Act 2023
• efforts to strengthen the sanctions response through the Office of Financial Sanctions Implementation
• Financial Conduct Authority work to close vulnerabilities that enable illicit use of cryptocurrency
• responsibilities for large social media platforms on certain types of fraudulent content introduced by the Online Safety Act 2023
• consultation on changes to the Money Laundering Regulations to allow for more effective implementation, a new corporate offence of failure to prevent fraud and reforms to the ‘identification doctrine’

RUSI highlighted potential pitfalls, including:

• limited communication about progress made against the plan
• concerns over the sufficiency of planned increases in personnel dedicated to fighting economic crime
• the anti-corruption strategy and economic crime data strategy are in progress and have not yet been published
• lack of response to the 2023 consultation on anti-money laundering supervision
• concerns about lack of enforcement
• need for more public-private collaboration on economic crime
• need for a focus on enforcing existing measures rather than generating new policies

On prospects for the plan, RUSI observes:

• there is no guarantee the plan will continue after the upcoming general election
• the upcoming Financial Action Task Force evaluation will assess the effectiveness of the UK’s response to money laundering and terrorist financing

What we’re doing for you

We contributed to the drafting of the plan as an anti-money laundering supervisor for the legal profession.

We will continue working with the government to deliver the plan through a new approach to public-private prioritisation.

This includes joint priorities to maximise public and private resources to prevent, detect and disrupt economic crime, as well as the ambitious reform of the UK’s supervisory regime.