From strategy to action: What the UK's new anti-corruption plan gets right (and where it falls short)

Today, the UK Government launches its new Anti-Corruption Strategy. 

Overall, this is the most wide-ranging and ambitious effort to tackle the threat of corruption to the UK in years, although a lack of concrete action on some areas - such as political integrity and political finance - leaves critical weaknesses in the UK’s defences. 

Let’s dive in. 

There’s a lot to welcome here. This strategy acknowledges that corruption isn't just something that happens elsewhere—it threatens our economy, our security, and our democracy right here at home. The Government is pretty candid about the challenge facing the UK, with compelling case studies highlighting recent instances of domestic corruption. 

The expansion of the Domestic Corruption Unit to investigate corruption cases nationwide is also a welcome move, as well as the corruption evidence hub, which is essential to understand the scale of the problem, and how to respond to it.  

Local government  

The changes proposed to tackle local government corruption are notable. We welcome the Government’s adoption of Transparency International UK’s recommendation to re-introduce a stronger mandatory code of conduct for elected local government officials, including robust sanctions for breaches. The establishment of an independent Local Audit Office in England is also a positive step towards undoing the damage caused by the abolition of the Audit Commission over a decade ago. What’s not clear here is whether lessons from Teesworks have been learnt, with a need for stronger governance over devolution arrangements remaining, especially those involving Mayoral Development Corporations. 

Asset ownership 

This publication also includes the announcement of a major new government review of asset ownerships and beneficial ownership. It aims to identify vulnerabilities that can be exploited by criminals to hide their dirty money and will make recommendations on how to fix this.  

Given the National Risk Assessment noted the importance of complex legal arrangements and opaque structures to hide wealth, this review is timely. It is unfortunate that this paper doesn’t recognise in more detail how these structures play a key enabling role in facilitating money laundering, which ends up hidden in property held in the UK. Our most recent research found £2.5 billion worth of dirty money invested in the property market, hidden behind trusts. And a little over £64bn of properties owned through trusts, and for which the owner remains secret.  

The Anti-Corruption Champion’s review should be broad, and include ambitious recommendations to tackle remaining loopholes, including trusts, legal arrangements, and limited partnerships, as well as looking at how to make our registers more inter-operable to make it easier to identify the ultimate owners of properties around the country. 

The Government is also looking to publish an Anti-Money Laundering and Asset Recovery Strategy next year, so we’ll expect to see additional commitments on this area there.   

Crown Dependencies and Overseas Territories 

In its strategy, the UK Government sets out red lines, making clear how it expects the Crown Dependencies and Overseas Territories to ‘implement a legitimate interest access regime that ensures broad access to beneficial ownership data.’, which should include repeated and open access to the data for journalists, civil society organisations and academics.   

However, after an almost seven-year delay, the absence of clear enforcement mechanisms or new creative approaches to enhance delivery, prospects for a timely and effective implementation aren’t encouraging.  

Professional enablers 

The Strategy hosts a new commitment to fund a coordinator to tackle the role of professional enablers in laundering dirty money, alongside the recent commitment to reform the system of supervision. This is hugely welcome, and we urge the Government to ensure existing supervisors actively police the sector during the transition, that the FCA has the resources it needs as well as adequate powers to properly regulate the legal sector.   

It’s also a good sign that the Government is looking to broaden out the scope of regulated sectors, and we would strongly advise that new remit includes property developers – currently a major loophole for money laundering. 

The elephant in the room: political integrity 

The Strategy talks about restoring trust in government as “the great test of our era”. Yet on political integrity and finance, it just summarises changes that have been announced over the last year – changes which so far have been largely superficial and have not dealt with the core issues at hand. These include the elephant in the room: the corrupting influence of big money in our politics. 

The UK still has no donation caps and retains an exceedingly high spending limit which is driving a funding arms race between political parties. Meanwhile, the revolving door between government and private interests remains wide open. And Westminster is still less transparent than many of our international peers. 

The Strategy is also a missed opportunity for the Government to commit to placing ethics bodies on a statutory footing. I worry that this demonstrates a lack of willingness to future proof any of these reforms and the standards landscape in general.  

Global resilience 

It’s good to see renewed commitment to investigative journalism, civic space and international partnerships in the Strategy. The geopolitical environment has become more complex, and with increasing attacks on civil society and reduced engagement in traditional multi-lateral fora, there is space for serious, informal collaborations between jurisdictions.   

 By hosting an illicit finance summit, the UK Government showcases its ambition to lead on anti-corruption, but it must ensure that its offshore jurisdictions do not undermine its credibility as a champion in tackling dirty money. 

 Many of the world's biggest economies still harbour systems that facilitate the laundering of corrupt wealth - whether that's through the local property market, with the use of anonymous companies or enabled by professionals. The Summit presents a vital moment for the UK and others to show leadership in tackling this head on with ambitious commitments. 

Collaboration with devolved governments 

It’s worth noting that elements of this strategy overlap with devolved responsibilities. Corrupt actors make swift work of what’s left in the gaps, so it’s important to be clear how protections work across and between systems so those holes cannot be exploited. We encourage the government to collaborate with the devolved administrations to ensure a consistent approach across the UK. Scotland recently committed to publish its own Anti-Corruption Strategy, which we will be following closely. 

Oversight 

The governance structure outlined for the Strategy is excellent. As someone who followed the first Anti-Corruption Plan in 2014, then the previous Strategy launch in 2017, this Strategy has by far the most comprehensive accountability mechanisms in place, with multiple layers of scrutiny. The Government has agreed to provide regular updates on progress, including to Parliament, and set up an external working group to monitor delivery which will involve civil society, academia and the private sector. Separate delivery boards for ministers and senior officials will also be put in place. 

Of course, the proof is always in the pudding. The Strategy lays out a comprehensive framework to work with and, overall, the government has set some ambitious goals. Good. We'll hold them to those standards, and keep encouraging them to be more ambitious. Because a strategy is only as good as its implementation—and we'll be pushing for concrete actions, clear timelines, and real delivery.