Overview
The anti-corruption enforcement tracker visualises publicly available data on anti-corruption enforcement and other related economic crime in the UK. In particular, it includes data on:
- Prosecutions and convictions for money laundering, misconduct in public office (MIPO), bribery and fraud in England and Wales (published by the Ministry of Justice),
- Asset recovery in England, Wales and Northern Ireland (published by the Home Office), and
- Anti-money laundering (AML) fines in England, Scotland, Wales and Northern Ireland (published by HM Treasury).
The tracker runs from financial years 2013/14 to 2023/24 (where data is available), providing insights into more than a decade of enforcement trends. We decided to collect data from 2013/14 to give this decade long view and becuase this was the year two major bodies with anti-corruption and financial crime enforcement responsibilities in the UK were established: the National Crime Agency and the Financial Conduct Authority. You can access the dataset here.
What anti-corruption enforcement does the tracker cover?
Corruption is notoriously tricky to define. The Office for National Statistics limits its definition of corruption offences recorded by the Police to bribery and MIPO enforcement. However the UK Government’s latest definition is much broader, identifying corruption as the “abuse of entrusted power for private benefit that usually breaches laws, regulations, standards of integrity and/or standards of professional behaviour”. It adds that “corruption need not be economic in nature and can still exist even if everyone has acted within the law”.
The data the tracker visualises is not exhaustive and does not cover the whole range of possible corruption in the Government’s definition, instead focusing on key indicators for anti-corruption related enforcement activity that are publicly available and recorded on a national level basis by the UK Government.
We intend to update the tracker on a rolling basis as new data becomes available. We welcome comments on how the tracker could be improved.
Prosecution and conviction data
Please note that it is not possible to accurately calculate annual conviction rates from the data presented because a prosecution may be initiated one or more years before a conviction is secured.
The UK Government collects and publishes data on prosecutions and convictions in two ways. The first way only counts the offence which carries the heaviest penalty (the “principal offence”), and excludes other, less serious offences for which defendants may be simultaneously prosecuted (“non-principal offences”). The second way counts all the offences a defendant is prosecuted for (both principal and non-principal offences, known as “all-offence” data).
While the all-offence approach captures a wider range of enforcement activity, it’s important to note that non-principal offence statistics are not subject to the same level of validation as the principal offence datasets, according to the Government. In addition, while the principal offence data reflects the number of defendants prosecuted for certain offences, the all-offence data does not reflect the number of defendants prosecuted, as a single defendant can be prosecuted for multiple offences.
For all the offences in the tracker we used the principal offence data. Since prosecutors often add money laundering as a non-principal offence, which does not appear in the principal offence data, we have also included the all-offence data for money laundering prosecutions and convictions to give as comprehensive a picture as possible.
For all offences in the tracker, we used the Outcomes by Offence data tool in the MoJ Criminal Justice Statistics to filter data for individual and corporate prosecutions and convictions for principal offences. For money laundering, we also used the All-offence prosecutions and convictions data tool to record the same metrics on a principal and non-principal offence basis.
In the officials data, some prosecutions and convictions are not labelled as individual or corporate, and instead appeared in a “not known” category. This means that in some cases, total corporate and individual prosecutions do not equal total prosecutions and convictions overall. It should be noted that “corporate prosecutions” in the tracker include prosecutions for public bodies.
In 2023, the Ministry of Justice undertook work to develop the processing of criminal court sentencing data. As a result, figures were revised from 2017 onwards due to more accurate and reliable methods for data processing for information on prosecutions, convictions, sentencing and remands.
While the Government notes that users are able to make comparisons between pre-2017 data and 2017 onwards, it advises exercising caution when drawing inferences where differences across that period are small. You can read more detail about this Technical appendix explaining the changes to the processing of criminal court sentencing data for Criminal Justice System Statistics Quarterly publication.
Money laundering offences
Only a small (but unknown) number of the money laundering prosecutions and convictions included in the tracker will relate to corruption or kleptocracy, as money laundering can occur off the back of any acquisitive crime. The UK Government does not currently publish data on High End Money Laundering prosecutions which according to the National Crime Agency is often associated with the laundering of the proceeds of overseas corruption into the UK.
For money laundering offences overall, we filtered the latest Outcomes by Offence data tool (June 2024) and the latest All-Offence data tool (December 2023) according to “Offence” – “38 – money laundering”.
This data includes the following offences and offence codes:
- 03801 – Concealing or transferring proceeds of criminal conduct’
- 03802 – Arrangements – being concerned in arrangement, knowing or suspecting, facilitating acquisition, retention, use or control of criminal property by or on behalf of another person;
- 03803 – Acquisition, use or possession of criminal property;
- 03804 – Proceeds of Crime Act 2002 – failure to disclose; another person involved in money laundering – regulated sector;
- 03805 – Proceeds of Crime Act 2002 – failure to disclose; another person involved in money laundering – nominated officers in the regulated sector;
- 03806 – Failure to disclose; another person involved in money laundering – other nominated officers in the regulated sector;
- 03807 – Tipping off – suspects a disclosure has been made, makes a disclosure likely to prejudice an investigation; regulated sector disclosure of S.21D(2) matters or that investigations into allegation of offence committed is being considered;
- 03808 – Nominated officer; must not give consent to the doing of a prohibited act;
- 03809 – Failure to comply with Money Laundering Regulations 2007;
- 09576 – Triable either way offences related to the MLRs 2017 (principal offence only).
For specific money laundering offences, we sought to only include data on offences which may typically be linked to corrupt activities.
Fraud offences
The prosecution and conviction data in the tracker for fraud offences was collected by filtering the Outcomes by Offence data tool (June 2024) by “fraud offences” (under “offence group”). This includes 88 different fraud offences which are listed in the offence group classification spreadsheet included in the Criminal Justice statistics release, covering both fraud against individuals and businesses as well as public sector fraud, e.g tax evasion and benefits fraud.
As the tracker is intended to give insights into corruption related offences, we only included specific data on fraud offences where there is a reasonable possibility that it could have included corrupt activity, namely conspiracy to defraud (offence code 05304), corrupt transactions with agents (offence code 05338, categorised by the Government as “Preserved other fraud and repealed fraud offences (pre-Fraud Act 2006)”, and fraud by abuse of position (offence code 05342). While other fraud offences may come under the latest Government definition of corruption they are not currently included in the tracker, however we are open to including additional offences in the future.
Bribery offences
Bribery offences overall include the following four offences and offence codes: 09907 – Offences relating to offering, promising or giving bribes; 09908 – Offences relating to requesting, agreeing to receive and accepting bribes; 09909 – Bribery of foreign public officials (only after 2018); 09910 – Commercial organisation – failure to prevent associate bribing another with intent to obtain or retain business or advantage.
Prior to 2017, the government notes that the offence code for “Bribery of foreign public officials” was “commonly used as a miscellaneous code by courts as well as for its intended purpose”. This means that all data for this offence up to 2017 is unreliable, so we have only recorded data from the 2018/19 financial year.
Misconduct in public office (MIPO)
MIPO is the closest thing the UK has to a domestic corruption offence. According to an analysis of MIPO cases by Spotlight on Corruption, the majority of defendants prosecuted under the offence are relatively junior employees of the Police or Prison services, and the majority of offences relate to “inappropriate relations”.
What doesn’t the tracker cover?
High-end money laundering
In some cases, data is unavailable or does not exist. For example, there are no publicly available statistics on enforcement actions relating to high-end money laundering (HEML) which would be crucial for shedding light on the UK’s response to its role as a key destination for funds stolen through grand corruption and kleptocracy. The UK did provide data for the Financial Action Task Force’s review of the UK in 2018 on HEML investigations started by the NCA, HMRC, and the SFO but has not published any further data on this since.
Sanctions enforcement
The tracker also includes no data on prosecutions and convictions for criminal breaches of UK financial sanctions. The Government does publish some data on sanctions (such as the value of assets frozen and number of civil fines imposed for breaches) and the Government includes offence codes for sanctions offences (including three offences under the Global Anti-Corruption sanctions regime) in the list of offences on which it holds prosecution and conviction data. However, there is no data currently held under these offences.
Additional data on AML supervision
We recognise that fines are by no means the only measure of AML enforcement action, and that supervisors often opt for informal over formal actions to remedy AML failures. We plan to cover AML supervision, including other forms of enforcement such as informal actions, in more detail in a future phase of the tracker.
Other asset recovery statistics
We did not include all the data in the asset recovery statistical bulletin in the enforcement tracker, for two reasons. Firstly, there is a large amount of data in the bulletin, and to include it all would have risked overloading users with information. Secondly, we sought to prioritise data which sheds the most light on the effectiveness of asset recovery relating to anti-corruption.
It is important to note that data cleansing and analysis has improved over time and there may be inaccuracies in the earlier publications of the Asset Recovery Statistical Bulletin. Further information and caveats around the data can be found in the user guide to asset recovery statistics published by the Home Office.
