Our recently launched anti-corruption enforcement tracker brings together public but hard-to-find data to shed light on the UK’s enforcement record against corruption and related economic crimes, which by one academic estimate cost the UK £350 billion a year.
Spanning the last decade, the tracker includes data on prosecutions and convictions for key offences associated with corruption, namely: bribery, misconduct in public office (MIPO), money laundering, and fraud.
It also tracks how much dirty money has been recovered from criminals, as well as the amount and value of fines imposed on businesses that are regulated for their compliance with anti-money laundering (AML) rules.
While there are some bright spots, the data in the tracker reflects years of chronic under–resourcing for anti-corruption and economic crime enforcement in the UK compared to the scale of the problem.
Right now the UK government is limbering up for a review by the Financial Action Task Force – which will consider whether law enforcement and prosecutorial authorities including those with asset recovery responsibilities, as well as AML supervisors and the UK Financial Intelligence Unit, have “adequate financial, human and technical resources”.
So it’s essential that policymakers consider how to address these resourcing challenges in order to ensure a positive review and, most importantly, a robust deterrent against corruption and other economic crime.
What are the key trends in the anti-corruption enforcement tracker?
Money laundering and fraud
The UK’s status as an international financial centre makes it especially vulnerable to money laundering, while fraud is the most commonly experienced crime in the UK. But prosecutions for both offences do not appear commensurate with the problem.
The tracker highlights an alarming decline in cases of money laundering and fraud where they were the most serious offence prosecuted, with the former down 36.1% since 2013/14, and the latter by a whopping 74.8%. Compared to the median things aren’t much better, with falls of 20% and 50% respectively.
However, prosecutions on this measure did increase by a small amount this year compared to last, suggesting that the long decline in prosecutions rates may be starting to reverse, likely resulting from the welcome focus on increasing enforcement outcomes under the Economic Crime Plan 2.
The fall in prosecutions for all money laundering offences (not just when it was the most serious offence prosecuted) is a less precipitous 10.3% since 2013/14, and an 8.2% decline on the median, though prosecutions on this metric went down 6.7% in 2023/24 compared to the previous year.
While the tracker does record prosecutions and convictions for specific sections of key legislation like the Proceeds of Crime Act 2002, the lack of more granular data means that any conclusions on the state of anti-corruption enforcement based on the tracker should be drawn cautiously. For example, there is currently no public data on High End Money Laundering (HEML), which limits the usefulness of the money laundering statistics in the tracker.
Bribery and MIPO
Prosecutions and convictions for bribery and MIPO, defined by the Office for National Statistics as the UK’s two main corruption offences, are more mixed.
MIPO prosecutions are down 34.9% since 2013/14 but saw no change in 2023/24 compared to the median and 2022/23. Bribery prosecutions meanwhile have fluctuated, hitting a peak of 27 in 2018/19 before falling back to just nine in 2023/24.
These results for MIPO and bribery pale in comparison to the potential scale of corruption in the UK, with the Economic Crime Survey 2020 estimating that over 1 million corruption incidents occurred over three years, including as many as 130,000 bribes offered to UK businesses.
Meanwhile, despite some recent high profile prosecutions including of commodities giant Glencore in 2022, the UK’s enforcement of foreign bribery has been underwhelming, with just seven foreign bribery investigations opened by the Serious Fraud Office since 2019 compared to 17 between 2013-2018. The UK lost its status as an active enforcer of foreign bribery in Transparency International’s 2022 Exporting Corruption report.
There are also real questions over whether the MIPO offence is fit for purpose. We found that 98% of these prosecutions since 2014 (where public information is available) were for junior to mid-level officials particularly in the police and prison forces.
This underlines the urgency for the government to bring in a new domestic corruption offence so that senior public officials can be held accountable for corruption – drawing on recommendations made in 2020 by the Law Commission for reform of MIPO.
Asset recovery and AML fines
The picture is more positive when it comes to asset recovery, with total recovered assets in 2023/24 up 35.8% since 2013/14 and 10.3% on the median (despite a 28.8% decline compared to the total recovered in 2022/23).
However, the £243.3 million recovered in 2023/24 represents just 0.2% of the £100 billion a year the National Crime Agency assesses could realistically be laundered through the UK, highlighting the potential increase in seized funds if there was more investment in the UK’s asset recovery capabilities.
AML fines meanwhile have steadily increased in number (if not value) since 2019/20. It’s worth noting that these macro statistics overlook sectoral nuances, with fines by legal sector supervisors few and far between (with the exception of the Solicitors Regulation Authority).
What doesn’t the data tell us?
The tracker does not tell the whole story of anti-corruption enforcement activity in the UK. For example, it does not cover work done by the enforcement agencies and regulators that goes under the radar such as disruptions or regulatory engagement.
It’s also important to highlight that the bare number of cases does not necessarily reflect their impact. For example, a single prosecution of a high-profile professional enabler for money laundering would be likely to have a higher impact and stronger deterrent effect than a dozen prosecutions of low-level drug dealers.
Similarly the steep fall in fraud prosecutions is partially explained by a shift in enforcement strategies by the Department of Work and Pensions and HM Revenue & Customs towards a smaller number of higher impact cases (as noted by a former Chief Crown Prosecutor at a recent webinar we held to launch the enforcement tracker).
What needs to happen now?
Overall, the tracker data suggests that while enforcement has generally been on a downward trend, things are starting to improve. But to really move forward in tackling corruption and economic crime in the UK, three things need to happen.
- First, the government needs to ensure that the right laws are in place for enforcement agencies to hold wrongdoers to account. There is a strong case for introducing a new domestic corruption offence, as well as a failure to prevent money laundering offence.
- Second, the government needs to make sure enforcement agencies are properly resourced to do the job. Reinvesting enforcement receipts like recovered assets and fines in an economic crime fighting fund would turbocharge the UK’s fight against economic crime and bring significant returns that could be used to increase victim compensation, be ploughed back into enforcement and spent on other vital public services.
- Finally, the government needs to make sure that key data is available to the public so that its efforts to tackle corruption can be accurately and fairly assessed. That means publishing more granular data on things like High End Money Laundering and disruptions. If this data was available we would be keen to include it in the tracker.
For too long, the UK government has talked a good game on tackling corruption but not backed this up with proper resourcing, a fact that is generally reflected in the tracker data. Now there is a real opportunity for the new government – starting with the upcoming Comprehensive Spending Review, as well as the new Anti-Corruption Strategy – to put its money where its mouth is and make good on its commitment to turn the UK into the anti-corruption capital of the world.
“While there are some bright spots, the data in the tracker reflects years of chronic under-resourcing for anti-corruption and economic crime enforcement in the UK compared to the scale of the problem.”
