Enforcement Bodies

25 November, 2019 | 3 minute read

What’s the issue?

The UK has multiple bodies responsible for investigating and enforcing breaches of the UK’s anti-corruption and money laundering laws.

These include agencies for investigating and/or prosecuting overseas corruption offenses:

and multiple agencies for investigating and/or prosecuting money laundering including:

Parliament’s Treasury Select Committee described this enforcement landscape for economic crimes as a “complex web”. Determining which enforcement agency may be the right one to approach with allegations can be a confusing business. There have been concerns that allegations may fall through the net and be missed altogether.

In October 2018, a new National Economic Crime Centre was launched to coordinate the UK’s response to economic crime. The Centre brings together law enforcement, government departments, regulatory bodies and the private sector.

In July 2019, the government announced an Economic Crime Plan, governed by an Economic Crime Strategy Board, consisting of the largest UK banks, enforcement, and government ministries. Concerns have been raised about whether this could lead to the UK banks being overly influential in setting government policy in this area.

What does Spotlight on Corruption do?

We monitor how effective the different enforcement agencies are and developments in the enforcement landscape to see how they impact upon implementation of anti-corruption laws.

We assess whether resourcing is adequate, whether enforcement agencies are able to attract and retain suitably qualified staff and whether the enforcement agencies have sufficient independence from political interference and corporate interests..

Our resources

Lawsuits brought by ENRC against public watchdogs represent an egregious attempt to curtail freedom of expression and jeopardise anti-corruption efforts – June 2021

Joint statement from 21 human rights, freedom of expression and anti-corruption organisations denouncing ENRC’s legal tactics. ENRC is suing the SFO for misfeasance in public office claiming the SFO mishandled the corruption investigation, induced Dechert lawyers to breach duties owed to ENRC, and leaked information to the media

The US Department of Justice shouldn’t get away with acting as the bully of anti-bribery enforcement: lessons from the Tom Martin employment tribunal – Febuary 2021 

Blog by Susan Hawley

FinCEN Files: UK’s failure to prosecute high-end money laundering shows UK banks are above the law – September 2020

Blog by Susan Hawley on the FinCEN files, how they expose the role of big banks in faciliating money laundering and how they are beyond the law.

The new economic crime levy – is it enough? – March 2020

Blog looking at the proposal to impose an economic crime levy and exploring ways to make UK enforcement more effective.

Are UK aid-funded enforcement efforts to end the UK’s role in corruption working? – December 2019

Blog by Susan Hawley for the Centre for Study of Corruption at the University of Sussex on whether aid funded enforcement efforts in the UK to track corrupt assets and investigate bribery by UK firms is working.

Can big banks be trusted with the fight against economic crime? The UK government seems to think so – June 2019
Blog by Susan Hawley looking at the creation of an oversight body for the fight against economic crime – the Economic Crime Strategy Board – as a partnership with the big banks, raising concerns about policy capture.

Who will go catch the medium fish in foreign bribery cases? – November 2017
Corruption Watch blog looking at who is responsible for investigating and prosecuting smaller foreign bribery cases that the Serious Fraud Office won’t take.

Theresa May pledges to bring the SFO under political control– May 2017
Corruption Watch blog on moves to amalgamate the Serious Fraud Office into the National Crime Agency and why this would be disastrous for prosecuting bribery.

UK’s fight against corruption hinges on the SFO’s future: verdict of the OECD’s Phase 4 foreign bribery report – March 2017
Corruption Watch blog on the OECD Working Group on Bribery’s review of UK compliance with its Anti-Bribery Convention, and its key recommendation that the Serious Fraud Office’s role in fighting overseas corruption be maintained as a priority.

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