Targeting the Untouchables: The UK’s asset recovery efforts since the introduction of the Criminal Finances Act 2017

A series of governments over the past decade have promised to end the UK’s role as a laundromat for corrupt and criminal wealth.

Major new legislation was introduced in 2017 after former Prime Minister David Cameron promised at his 2016 Anti-Corruption Summit to “show that there is no home for the corrupt in Britain”. The Criminal Finances Act 2017 brought in the UK’s ‘McMafia orders’ and a range of other tools with bold political promises that the UK would seize assets that previously could not be touched by law enforcement.

Eight years on, and two Economic Crime Acts later, this report asks what these tools have delivered, and whether the high expectations for a step change in recovering criminal assets has been achieved.
As the UK prepares to host an international summit on illicit finance in 2026, its ability to show that it is stepping up to prevent the UK being a magnet for dirty money, and to seize and disrupt criminal wealth, is on the line.

Furthermore, in 2027, the UK will face international scrutiny from the global money laundering watchdog, the Financial Action Task Force, over how well it has prioritised asset recovery and implemented a culture shift to mainstream the seizure of criminal assets within law enforcement.

Our report is a stocktake on how well the UK has done so far, and what it needs to do to deliver a real step change in taking the proceeds of corruption and crime off kleptocrats and organised criminal networks.

We find that rates of successful recovery of frozen criminal funds have virtually flatlined since the Criminal Finances Act came into effect. Just 28% of the overall assets frozen since 2018 have been permanently seized – well below what is needed to make a dent in the UK’s dirty money problem.

Of the new tools introduced through the Criminal Finances Act, politically high-profile Unexplained Wealth Orders have contributed towards just 2.3% of assets recovered since 2018. Meanwhile, the unsung hero of asset recovery reforms, the Account Freezing Order, accounts for 60% of all assets frozen using new civil forfeiture powers, but less than a third (29%) of this money is actually recovered.

Incentives for law enforcement to undertake more asset recovery are not strong enough and are undermined by arcane Treasury rules. The difficulties and expense of chasing illicit wealth in the courts have resulted in an increased use of opaque settlements for high-stakes money laundering investigations. White-collar professionals implicated in facilitating this illicit wealth have rarely if ever faced accountability despite a new Cross-System Professional Enablers Strategy.

From beefing up existing tools, to undertaking a thorough review of what further legislative reforms we need to get more results, and developing a comprehensive asset recovery strategy that boosts incentives for law enforcement, there is much for the government to do to finally deliver the promise of making the UK’s financial system a hostile environment for illicit wealth.