In a wide-ranging document setting out proposals, and reiterating why the fight against dirty money is important, the government is casting its net over fields as varied as UK-related offshore centres to the world of professional football.

This week, the UK government unveiled a new set of measures to fight financial corruption. The scope of action even includes professional football.

The new Domestic Corruption Unit (DCU) in the City of London Police will be expanded, and the government said it will continue to back the International Corruption Unit (ICU) and the International Anti-Corruption Coordination Centre (IACCC) in the National Crime Agency (NCA).

The proposals were set out in a 121-page document, UK Anti-Corruption Strategy 2025.

Media reports (Bloomberg, 8 December, for example) said the taxpayer is putting £15 million ($20 million) into the formation of a specialist police taskforce; it set out plans to widen sanctions. 

The document said corruption hurts the UK economy and weakens national security. The strategy comes at a time when the UK has had to disentangle from commercial relations with Russia, and manage flows of money into and out of the UK via regions such as the Middle East and Asia. The fight against dirty money is global, with jurisdictions such as Singapore cracking down on KYC and AML rule breaches, for example. In the US, to give another case, there is the Corporate Transparency Act, as discussed here.

“Tackling corruption matters to British businesses, with 7 per cent of internationally-trading UK businesses with employees believing they have lost a business opportunity overseas to competitors offering bribes in the last 12 months,” it said. “Tackling corruption also matters to our reputation, with the UK placing at its lowest ever score of 20th in Transparency International’s Global Corruption Perceptions Index in 2024.”

The document acknowledged that a raft of laws and measures have been enacted in recent years in the UK to weed out corruption. A new “failure to prevent fraud” law in the UK took effect from the start of September this year. Its reach, which can stretch globally, adds to firms’ compliance burdens, including those in the wealth sector. The UK Bribery Act was introduced in 2010.

For 2026, the government said it wants to reform how potential corruption in the UK is reported; expand the National Economic Crime Centre Bribery and Corruption clearing house; and consider findings of the Independent Review of Disclosure and Fraud Offences.

AI on the case
In 2027, the proposals include piloting a prototype AI “corruption investigation assistant.”

“Through this strategy, we will strengthen enforcement against corruption, by expanding the new Domestic Corruption Unit in the City of London Police and harnessing the power of artificial intelligence to accelerate investigations,” David Lammy, deputy prime minister, said in the report's introduction. “We will simplify and improve a complex regulatory system by consolidating the anti-money laundering and counter-terrorist financing supervisory functions of the UK’s 22 professional services supervisory bodies.”

“We will increase our efforts to dismantle kleptocratic networks in the UK by scaling up our capacity to pursue the professional enablers who make corruption and broader economic crimes possible,” Lammy added.

Reports said the UK is trying to bear down on more than £100 billion of illicit cash that the National Crime Agency estimates is laundered through the UK, as well as the 117,000 bribes worth £300 million which the government says UK businesses faced in the past year. Lammy has suggested that these measures will help efforts to hamper Russian President Vladimir Putin in his war with Ukraine.

Lammy, who is also Secretary of State for Justice and Lord Chancellor – heading the UK’s legal system – has also controversially proposed reducing the number of crimes that can be tried by a jury, claiming that the system has become heavily delayed. As a saying goes, justice delayed is justice denied. However, critics say reducing the use of juries could lead to wrongful covictions and deepen a sense that the general public are being squeezed out of active involvement in the judicial system. The jury system dates back more than 1,000 years and is used in a number of jurisdictions. However, Lammy – who in the past has been a vocal defender of juries – is pressing ahead; he said they aren’t suitable for topics such as complex fraud.

Football and overseas territories
The proposals identified professional sports – and the English Premier League in particular – as vulnerabilities. The commercial success of domestic UK football has also drawn in bad actors, the government's document said.

“The government has therefore included English football clubs and agents in the latest National Risk Assessment of Money Laundering and Terrorist Financing,” it said. 

Legislation has created the Independent Football Regulator to protect the sport from “unsuitable” ownership. (Editor’s comment: This could lead the government into difficult territory: several English clubs are owned by sovereign wealth funds and ruling families in the Middle East, for example. A question is whether a sport that has run successfully for about 150 years must be now overseen by a dedicated regulator at all, rather than rely on existing law enforcement bodies. There is a danger with all such initatives that it leads to a proliferation of government bureaucracy, bloated costs, and the eventual tempations of rent-seeking behaviour by the industries they oversee. We shall see.)

Offshore
The document said more must be done to improve beneficial ownership transparency in Crown Dependencies (Jersey, Guernsey and Isle of Man) and British Overseas Territories (such as the Cayman Islands, British Virgin Islands, Bermuda, and Gibraltar).

“It remains the UK’s ultimate expectation that all CDs and OTs will implement publicly accessible registers,” it said, referring to the point that registers of beneficial ownership should be made available to the public – with certain guardrails.

“The UK expects the CDs and OTs to implement a legitimate interest access regime that ensures broad access to beneficial ownership data. This access should be available to a wide range of users – including journalists, civil societies and academics – through an inclusive and straightforward process for demonstrating legitimate interest,” it said. “Access must be timely, granted either for free or for a reasonable cost and duration, and supported by a transparent, impartial, decision-making process. The privacy of those requesting access should be safeguarded, with no notification to the subjects of the data. Information on the register must be accurate and regularly updated, and it should enable effective interrogation of the data and proactive investigations,” it added. (There remains a tension between the argument over whether financial transparency can sit easily alongside respect for legitimate privacy.)

Media reports said Lammy also wants to crack down on the practice known as Slapps – strategic lawsuits against public participation. Excessive legal threats have been used in several cases in an attempt to silence reporting on Russian oligarchs (Guardian, 8 December.)