Treasury Committee Inquiry into Economic Crime: December 2020

10 December, 2020 | 2 minute read


  1. The immediate introduction of a failure to prevent economic crime offence to complement the current Law Commission review into the identification doctrine.
  2. An urgent amendment to the costs regime for public authorities bringing Unexplained Wealth Orders (UWOs) under the Criminal Finances Act 2017 (CFA);
  3. Amendments to the CFA to ensure UWOs can effectively be used where property is held by trusts or by those who are not the ultimate beneficial owner.
  4. Consideration be given to putting Property Freezing Orders (PFO) on an evidential par with Account Freezing Orders (AFO).
  5. Consideration of an individual failure to prevent economic crime offence for seniormanagers in the event that a company is found guilty of such an offence, or enters into a Deferred Prosecution Agreement (DPA).
  6. The introduction of a power for prosecutors to apply to courts for directordisqualification orders (DDOs) for directors where a company is convicted or enters into a DPA.


Spotlight on Corruption has real concerns about the ongoing issues with the consistency of anti-money laundering (AML) supervision, including low rates of criminal and regulatory enforcement in relation to AML violations.


Spotlight on Corruption recommends that an independent expert review of the effectiveness of the UK’s supervision and criminal enforcement for AML is commissioned by the government in March 2021. This review should look at:

This review should be undertaken with stakeholder participation, and be published in a timely fashion and prior to the government undertaking the review of the Money Laundering Regulations (MLR) and Office of Professional Body Anti-Money Laundering Supervision (OPBAS) regulations which it has committed to do by June 2022.



Spotlight on Corruption is concerned that the ongoing uncertainty and insufficiency ofresourcing for tackling money laundering and economic crime creates an inequality of arms between law enforcement bodies and those who commit economic crime.


Spotlight on Corruption recommends that a full analysis of law enforcement fundingneeds for economic crime be developed for the next multi-year spending review and that there is transparency about this analysis. Any analysis of funding needs must take intoaccount.

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