The UK anti-corruption strategy: pillar one in focus

The UK Anti-Corruption Strategy published on 8 December 2025 (“the Strategy”) sets out the myriad ways in which the presence of corruption and illicit finance in the UK has an immediate negative impact – from the health of our economy to the safety of our citizens. Declaring that: “corruption is a corrosive force that undermines growth, threatens our national security, and erodes the foundations of our democracy” it seeks to tackle this at home and abroad. 

With a focus on: combatting the influence of corrupt actors and their funds in the UK and overseas; tackling vulnerabilities to corruption in the UK; and building greater domestic resistance to corrupt influences from abroad, the theme of “corrupt influences” is a reminder of the pressing current domestic and global context. 

Building on the 2014 Anti-Corruption Strategy, this initiative is also part of the wider growth agenda to support British business, promote fair competition and uphold the rule of law domestically and globally. The breadth of its perceived impact is reflected in the scope of ambition set out in the Strategy. There are three “pillars” upon which the Strategy is based and we focus on “Pillar One: Corrupt Actors” here. This centres on the Government’s response to corruption based on justice and accountability.

Blowing the whistle?

Seeking better intelligence on the scale and source of corruption, a key action is to review the reporting system – both through improving the co-ordination of referral systems and tactical oversight (led by the Bribery and Corruption clearing house in the National Economic Crime Centre), and by focusing on early detection of corrupt practices. A 2026 priority is to assess the feasibility of introducing financial incentive schemes and support for individuals reporting economic crime. This is something the Director of the Serious Fraud Office, Nick Ephgrave, has long campaigned for, no doubt looking enviously upon other jurisdictions which, it is reported, are reaping increased “actionable intelligence” on corrupt activities and enhancing law enforcement outcomes. Ephgrave reiterated the value of such insight in transforming economic crime investigations in his remarks for the launch of the Strategy. Indeed, it is worth noting the recently launched HMRC “Strengthened Reward Scheme” for individuals who report serious tax avoidance or evasion, indicating that the UK is already moving in this direction.

At a law enforcement level, we can expect the creation of a new Domestic Corruption Unit in the City of London Police and speedier SFO investigations and outcomes. Via a more efficient investigative process and the use of artificial intelligence and machine learning on uncovering wrongdoing, the plan calls for an end-to-end review of concluded bribery cases, to identify common barriers to resolving cases.

No more enabling of the corrupt elites

The strategy sets out the government’s intention to increase efforts to dismantle “kleptocratic networks in the UK”, where, the report cites, “corrupt elites benefit from illegitimate wealth converted into legitimacy” using influence and protection provided through a network of global services.

The UK’s role as a major financial centre, combined with its economic stability and open economy, makes it vulnerable to exploitation by criminals and corrupt actors. The NCA estimates that over £100 billion may be being laundered every year through the UK or through UK corporate structures. The impact of this on the UK’s international reputation is illustrated by its lowest ever score on Transparency International’s Global Corruption Perceptions Index last year.

The intention is to scale up the pursuit of professional enablers who make corruption and broader economic crimes possible – including expanding the use of sanctions – noting that whilst most law firms comply with sanctions and anti-money laundering requirements, others represent “the beneficiaries of kleptocracy, while remaining technically compliant with current legal frameworks.”

The Solicitors Regulation Authority’s annual anti-money laundering report for 2024–2025 indicated that a significant proportion of the firms it inspected for AML compliance had fallen short.

Part of the plan to tackle anti-money laundering (AML) weaknesses is to transfer AML and Counter Terrorism Finance (CTF) supervision for lawyers and other professional services providers to the Financial Conduct Authority – a significant reform announced in October 2025. The detail of the reforms are yet to be provided, but whilst unifying AML/CTF regulation under one roof, there are concerns that it will create complexities both for the FCA and the professional adviser industry, which faces dual regulation.

The UK will seek new dynamic partnerships with global and emerging financial centres to focus on shared risks and strategies for tackling new and emerging methodologies for moving illicit funds.

Bolstering business to tackle bribery

To equip British businesses to identify and act on bribery and corruption risks, a five-year plan is set out that includes access to resources; the clarification and strengthening of incentives for self-reporting by corporates through the implementation of the recent SFO’s External Guidance on Corporate Co-operation; and, strengthening the SFO’s crime prevention capability to support companies in strengthening their protections against bribery and corruption.

Conclusion

The statement of intent is to create a formidable toolset and showcase the UK’s real ambition to tackle illicit finance and corruption in our system.

This “whole-of-Government” response to tackle corruption at local, national and international level is ambitious, but fraught with complexity. It will take significant resource to introduce measures and time for them to bed in and to see any effect. In the meantime, there will be disruption in the enforcement agencies, to business and professional services. Despite the noise and rhetoric in some quarters, financial incentivisation of whistleblowers will not be a quick or easy win and could just create different levels of complexity.

At the same time, there are other proposals to overhaul the court system, including radical proposals about trial by jury potentially impacting fraud cases, sentencing and digital transformation.

It would be a set-back if the ambitions stated in the Strategy overwhelms an already fragile system where injecting more resource into the prosecuting authorities currently tasked to apply the laws and regulations already in force would have a more immediate benefit.

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