On 11 December 2025, Spotlight on Corruption and the UK Home Office co-hosted a workshop to explore options for legislative reforms to the Proceeds of Crime Act 2002 (POCA). Held under Chatham House rules, the workshop brought together around 30 participants from the legal profession, law enforcement, regulators, civil service, and civil society.
The workshop consisted of a plenary discussion to take stock of the strengths and weaknesses of POCA, followed by breakout groups to gather feedback on five specific options for reform under consideration as the government develops a new Anti-Money Laundering and Asset Recovery (AMLAR) Strategy.
The five options for asset recovery reform explored during these discussions covered:
- The introduction of a ‘harm to society’ model to allow for the targeting of assets identified as causing societal harm, without needing to evidence a clear link between the recoverable property and the unlawful conduct. There would be a presumption of recoverability where this threshold of societal harm is met. Variations of this model are found in Switzerland and Italy.
- The direct forfeiture of assets following the failure to comply with a UWO, rather than requiring law enforcement to file a further application and gather sufficient evidence to establish, on a balance of probabilities, that the conditions for civil recovery are met. This proposal would require the introduction of a distinction between full and purported compliance with a UWO to ensure inadequate or partial compliance does not thwart direct forfeiture. This reform could be accompanied by the introduction of presumptions about the reliability of evidence from certain jurisdictions. A further, more radical, reform to the UWO regime could entail lowering the standard of proof to belief or reasonable suspicion.
- A comprehensive review of POCA to simplify and modernise the legislative framework. This could be achieved either by translating the key principles of POCA into a cleaner and simpler regime or by taking a fresh look at the problem and building a new asset recovery regime from the ground up.
- A targeted review of confiscation order enforcement to consider reforming the model for calculating confiscation and the mechanism for satisfying those debts. This would explore moving away from a value-based model for confiscation, which treats confiscation orders as a fine for enforcement purposes, to an asset-based or hybrid model that focuses on realising specific assets to satisfy the debt.
- The appointment of an independent reviewer to assess the criminal finances legislative framework on an ongoing basis. This would bring an external perspective and expertise to identifying systemic barriers and opportunities for reform, providing a process for regular review and incremental reforms rather than relying on comprehensive reviews of the entire system that can take many years to complete.
This summary report draws out the main themes that emerged from the discussions, and consolidates the insights and feedback on the five proposals under consideration.
