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New UK Anti-Corruption Strategy – what does it mean

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The Government has announced its new anti-corruption strategy as it looks to further grow the economy, support British business and tackle the threat that corruption and illicit finance have on national security.

What is the strategy?

There are three central pillars to the strategy:

  • combat corrupt actors and other funds in the UK and overseas;
  • tackle vulnerabilities to corruption within institutions and systems;
  • build international partnerships aimed at building global resilience to corruption and broader illicit finance.

The strategy paper has over 120 commitments as well as a £15m funding package to expand forces investigating corruption. A key strand of the strategy is the focus on professionals who knowingly facilitate corrupt transactions or create complex structures with a view to hiding assets. In addition, there are commitments to champion beneficial ownership transparency and explore opportunities to reform the UK whistleblowing framework, including through potential financial incentives, as well as plans for the Domestic Corruption Unit to be expanded.

Implementation of the strategy will be overseen by Ministers across the Home Office, the Foreign, Commonwealth and Development Office, and HM Treasury, supported by the Prime Minister’s anti-corruption champion. To ensure accountability and transparency, there will be progress updates and a written ministerial statement to Parliament each year, as well as two detailed assessments in years 3 and 5 and progress updates given to an external engagement group. 

Changing corporate culture

The strategy paper comes quickly after legislation came into force in the UK seeking to hold businesses above a certain size to account if they profit from fraud committed by their employees. Under the “failure to prevent fraud” offence, a company will be liable where a specified fraud offence is committed by an employee or associated person for the company's benefit and the business lacked reasonable procedures to prevent it. This dovetails with existing “failure to prevent” legislation in place for bribery and facilitating tax evasion. Penalties include unlimited fines and criminal convictions.  There is a clear intention of ensuring that the UK is not seen as soft on fraud and to drive change in corporate culture through policy and legislation.

What has the response been?

There has generally been a positive response to the strategy paper, which came a day after it was announced that the UK would host a major international summit in June 2026 to tackle the flow of dirty money which it considers has a detrimental impact on the economy and everyday life. The strategy paper is ambitious yet recognizes the challenges that are currently being faced and attempts to make improvements to systems.  The challenge will be with enforcement, with cases for the matters mentioned above requiring significant time and financial resources to investigate and prosecute.

What might the impact be?

The strategy announcement coincides with a report by Search Acumen which notes that since the introduction of the Register of Overseas Entities in 2022, which required entities owning UK property to declare who their beneficial owners were, there has been a significant decrease in the number of property titles being registered by overseas entities. Whilst it is the case that market conditions in the three-year period have been less than ideal (e.g. falling yields, high interest rates, elections generating uncertainty, global conflicts and borrowing costs), it is possible that reducing anonymity may have directly led to certain investors focusing on other countries. 

Final thoughts

The UK has for many years positioned itself at the forefront of global efforts to tackle corruption. The new five-year strategy gives a framework for this to continue. The following months will be interesting, with details of the strategy being finalized and resources deployed, allowing for greater clarity on the practical impact on the day-to-day operations of businesses.

 

 

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