'All Mouth And No Trousers'? The New Focus On The Fight Against Economic Crime, Illicit Finance And Serious And Organised Crime In The Integrated Review

• Published date: 28 April 2021
• Subject Matter: Finance and Banking, Government, Public Sector, Criminal Law, Financial Services, Money Laundering, White Collar Crime, Anti-Corruption & Fraud
• Law Firm: BCL Solicitors LLP
• Author: Mr Michael Drury and Caroline Mair

1. In its first review of the UK's security capabilities both at home and abroad since 2015, the Government in its 'Integrated Review' (IR) sets out its policy agenda in respect of security, defence and foreign policy for the next four years to 2025. Significantly, we see for the first time in such a review, that the fight against "economic crime" (as well as the inextricably linked issues of "illicit finance" and "serious and organised crime") is identified as one of the government's top "priority actions", recognising that such issues pose a real national security threat to the UK, given the fact they are not confined to the UK's borders but can arise from any bad actor worldwide and particularly so given the continued rise of cybercrime.

2. The IR has a distinctly optimistic tone and reads like a wish-list of hoped-for outcomes. In respect of how the government proposes to tackle "economic crime" and "illicit finance", sharp focus has been given to the 2019 Economic Plan which intends to "overhaul" the Suspicious Activity Report (SAR) regime; "bolster" the National Economic Crime Centre (NECC); and introduce new legislation "that tackles economic crime, including the use of UK corporate structures in facilitating high-end money laundering" as well as a reform of Companies House registration. A total of '83 million has been pledged to implement such measures. In contrast, when it comes to addressing "serious and organised crime" (which is inexplicably, dealt with in the IR as a separate threat to "economic crime" and "illicit finance"), no new funding has been promised, despite the fact that the government proposes to "strengthen" the National Crime Agency (NCA) and increase policing capacity within Regional Organised Crime Units amongst other aims. Although an investment of '275 million has been promised to the Criminal Justice System (CJS) "to help bring more offenders to justice" no further detail has been given as to how those funds will be apportioned within the CJS or how exactly that ambitious aim will be achieved.
3. It might also be said that these suggested new measures are simply not needed as there are already plenty of tools available to the UK authorities in detecting and punishing economic crime...