New national risk assessment finds UK professionals and companies remain a major money laundering threat

Transparency International UK welcomes the publication of a new National Money Laundering Risk Assessment today, laying bare the UK’s persistent vulnerabilities – particularly the use of opaque UK companies and trust structures, and the role of professional enablers. 

As criminals, kleptocrats and drug trafficking gangs become more sophisticated and new technologies emerge, the assessment, last updated in 2020, will be critical for law enforcement agencies and professionals at the forefront of anti-money laundering efforts.  

It also underscores how emerging technologies amplify money-laundering risks, making it essential that the Chancellor’s plans for growth and deregulation be carefully balanced against emerging threats to the UK’s national security. 

Rachel Davies, Advocacy Director, Transparency International UK said: 

“The risk assessment is an important publication, which gives an up-to-date picture on the evolving money laundering threat faced by the UK.  
 
As those involved in criminality and corruption continually seek new ways to circumvent rules, it is vital that law enforcement, regulators and the private sector, our first line of defence, use these insights to inform a robust, risk-based response.” 

The assessment found that kleptocrats, organised criminals and sanction evades frequently exploit tools such as trusts and opaque corporate structures to sidestep UK transparency rules. Transparency International UK’s own investigation found over 170 UK properties, collectively worth around £2.5 billion, have been purchased with illicit funds through complex trust arrangements.  These properties have ties to sanctioned individuals, politically exposed persons (PEPs) from high-corruption-risk countries, and individuals charged or accused of corruption-related offences. 

The report also highlights the growing threat of alternative payment mechanisms, raising the risk posed by electronic money institutions (EMIs) to “high”. This follows our research which found more than one in three UK registered EMIs had money laundering red flags relating to their owners, directors or activities.   

Finally, professional service firms – including lawyers, accountants, trust and corporate service providers as well as wealth managers – remain ‘high risk’ for facilitating money laundering. A patchwork of under-resourced and ineffective regulators is holding back efforts to tackle the enablers of corruption and sanctions evasion. These were weaknesses already identified in the UK’s previous FATF evaluation and requires urgent reform.  

Margot Mollat, Senior Researcher and Policy Manager, Transparency International UK said:  

“Though we welcome the Government's analysis of evolving threats, we have yet to see meaningful reductions in the risks posed by complex corporate networks involving trusts and offshore entities, often with the assistance of professional enablers. Addressing these challenges will require closing remaining transparency gaps, strengthening regulation and oversight of enablers, and ensuring consistent, robust enforcement. Only then can the Government confidently declare ‘the golden age of money laundering’ to be over."

As this Government prepares to host an International Summit on Illicit Finance and prepares for its next round of evaluation by the Financial Action Taskforce, it should:  

• Tighten and improve the oversight and guidance of the UK’s regulated sector so that professional services can reduce their vulnerability to money laundering  
• Prevent criminals from exploiting secretive trusts to purchase properties by broadening the scope of the UK’s trust register to include those that acquired property here before 2020, along with more public access to ownership information on this register. 

The National Risk Assessment can be found here: Improving the effectiveness of the Money Laundering Regulations - GOV.UK

The document gives a comprehensive breakdown of a range of money laundering threats facing the UK.