Professional enablers, such as lawyers, accountants and corporate service providers, play a central role in facilitating illicit financial flows by providing the structures, legitimacy and anonymity that allow them to move and persist. Without their involvement, kleptocrats, organized crime groups and sanctions evaders would find it far more difficult to integrate illicit wealth into the global financial system. Targeting the enablers has therefore become an increasingly important part of the UK’s response to illicit finance. The question is whether the tools now in place can be translated into effective enforcement. 

Over the past decade, successive UK governments have progressively strengthened the legislative framework for tackling illicit finance. The Bribery Act 2010, the Criminal Finances Act 2017 and the Economic Crime and Corporate Transparency Act 2023 (ECCTA) each extended the reach of UK law against those who facilitate financial crime. Under Keir Starmer, the pace of reform accelerated. His government published the Anti-Corruption Strategy 2025, appointed Baroness Margaret Hodge – a long-standing campaigner against global corruption – as the UK’s Anti-Corruption Champion, and confirmed that the Financial Conduct Authority (FCA) would consolidate anti-money laundering supervision across professional services. The ECCTA’s ‘failure to prevent fraud’ offence, which came into force in September 2025, makes large organizations criminally liable where an associated person commits fraud for their benefit, extending the logic first established by the Bribery Act to fraud for the first time.  

The scale of the challenge remains considerable, with an estimated £100 billion laundered through the UK each year, but the legal architecture to address it has never been stronger. 

Enforcement has not kept pace

Despite this solid legislative foundation, the enforcement record across multiple governments shows a persistent gap between ambition and delivery. The trajectories of two high-profile cases illustrate this. 

In 2020, the NCA pursued unexplained wealth order proceedings over three London properties worth approximately £80 million linked to Dariga Nazarbayeva, daughter of former Kazakh President Nursultan Nazarbayev, and her son Nurali Aliyev. The court discharged all three orders, finding the NCA’s case flawed by inadequate investigation. The adverse costs order of £1.5 million represented over a third of the NCA’s annual anti-corruption budget.  

More recently, in June 2026, a London jury cleared former Nigerian oil minister Diezani Alison-Madueke of all six bribery charges after a five-month trial, closing a 13-year investigation. The NCA alleged she had accepted bribes from oil industry figures holding contracts with the Nigerian state; the jury acquitted her and both co-defendants. Spotlight on Corruption identified structural failures in how the case was built, noting that charges were narrowly focused on Alison-Madueke’s alleged ‘life of luxury’ in London without presenting evidence that the tycoons who funded it had been improperly awarded contracts. Serious delays were attributed to outdated technology, skills shortages and high staff turnover within the NCA’s International Corruption Unit. ‘This case has exposed just how tough it is to investigate and prosecute alleged corruption involving political elites,’ said Zainab Saleem, a legal fellow at Spotlight on Corruption. 

Although neither case involved the prosecution of professional enablers, both illustrate the capacity constraints that UK authorities face in complex, cross-border financial crime cases. These wider enforcement constraints are also relevant to the prosecution of professional enablers, which remains exceedingly rare despite their well-documented role in facilitating major corruption. Spotlight on Corruption’s court monitoring programme found that there has been just one corporate criminal conviction of a bank for money laundering in UK legal history. The NCA’s Combating Kleptocracy Cell – established to investigate corrupt elites and high-end money laundering – is reportedly operating at only 50% capacity. The legal powers exist, but the institutional capacity to deploy them consistently against sophisticated actors does not yet match the legislation’s ambition. 

Closing the enforcement gap

There are signs that policymakers have recognized the problem. Starmer’s government confirmed that the FCA will become the Single Professional Services Supervisor, consolidating the functions of 22 professional body supervisors and addressing a weakness identified in the FATF’s 2018 mutual evaluation. The reform is significant: fragmented supervision had long produced inconsistent standards and enforcement gaps across the legal and accountancy sectors. The FCA has already issued its first-ever public censure of a professional body supervisor – an early signal that oversight of the supervisors themselves is no longer passive. On the multilateral front, the Serious Fraud Office has joined France and Switzerland in a new International Anti-Corruption Prosecutorial Taskforce, a meaningful development given that the structures used to obscure illicit finance routinely transcend national borders. 

Burnham inherits an unfinished agenda

Andy Burnham’s government inherits a strengthened legislative framework, alongside a supervisory reform programme in motion, a new multilateral prosecutorial alliance and the Countering Illicit Finance Summit scheduled for December 2026. His inaugural speech made no explicit reference to illicit finance or anti-corruption, leaving open the question of how prominently these issues will feature in his government’s priorities. What he inherits is not a blank slate but an unfinished agenda, one whose success will depend on sustained institutional capacity and political commitment. Whether his government provides that continuity will be an early test of its approach to financial crime. 

The timing makes this question particularly consequential. On 1 July 2026, the UK assumed the FATF Presidency under Giles Thomson, with a stated focus on fraud, risk-based supervision and cross-border enforcement, precisely the areas in which the UK’s own record is being tested. In 2027, the UK will assume the G20 Presidency, providing an exceptional platform to set global standards on professional enabler accountability. Over the next two years, the UK has a strategic opportunity to demonstrate global leadership in holding professional enablers to account. That leadership will ultimately be judged by the credibility of its own enforcement record.