The Government, in conjunction with UK Finance, has published its 2019-2022 economic crime plan, setting out how it proposes to progress the priorities agreed by the Economic Crime Strategy Board in January. The key and critical actions include:
- reforming the SARs regime and the UK FIU;
- enhancing risk-based supervision and private sector risk management; and
- the Companies House reforms.
The plan stresses the importance of providing a holistic response to the widest definition of economic crime, and also includes recovery of criminal and terrorist assets – but does not focus on tax evasion and related fiscal fraud except in relation to the money laundering elements of the offending. Cyber-related economic crimes are within scope, but need more work to assess how economic crime governance aligns with broader cybercrime governance.
The wide ranging and ambitious plan also calls out specific areas of concern, including:
- the continuing use of professional enablers;
- how to measure the scale of sanctions contravention (noting that OFSI has started to release figures based on reports made to it); and
- the continuing payment of bribes by UK contractors in overseas business, particularly in the mining and extractive industries.
The plan has 52 specific action points, under the headings of:
- understanding threat and performance metrics;
- better information sharing;
- powers, procedures and tools (which include improvements to POCA, MLD5 implementation and review of the criminal market abuse regime) ;
- enhanced capabilities (including SARS IT transformation);
- risk-based supervision and risk management (including regulators’ powers generally, and FCA being set up as the supervisor of the future cryptoassets AML/CFT regime, and the promotion of digital identity services);
- transparency of ownership (Companies House reform, overseas property ownership and reforming limited partnerships);
- international strategy; and
- governance and public-private partnership