Economic Crime Plan Online Tracker

What is the Economic Crime Plan?

The Economic Crime Plan (2019-2022) was launched in July 2019 and sets out the UK government’s response to a range of economic crimes impacting the UK, including money-laundering, fraud, market abuse and bribery. It is the first plan of its kind in the UK to set out a public-private response to these problems.

The Economic Crime Plan sets contains 52 actions under seven priorities areas (as set out below) with deadlines for achieving these actions. This online tracker provides a tool by which the progress of the Plan can be monitored. 

This tracker was most recently updated on 20 September 2020.  Click on each individual action below to review the progress made as of that review date.

Progress Completion

Completed

23%

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Completed

23%

In progress

59%

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In progress

59%

Overdue

9%

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Overdue

9%

No due date

3%

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No due date

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Inactive

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Strategic Priorities

actions 1-5
Understanding the threat and performance metrics
actions 1-5
action 1
Undertake collective threat assessments
No due date
Due: Ongoing
Overview:

A clear understanding of the nature and scale of the threat is important for informing the operational and policy response. The plan commits the National Assessment Centre (NAC), in partnership with the NECC and private sector colleagues, to undertake public-private threat assessments on key themes and sectors.

Progress:

The first public/private threat assessment on economic crime was completed in July 2019. Two further public/private threat assessments (on Money Service Businesses and Trust and Company Service Providers) are in train.
Updated June 2020. 

Two further public-private threat assessments have been completed (Money Service Businesses and Trust and Company Service Providers) and circulated to the private sector. 
Updated September 2020. 

Responsible Organisations:

NAC with support of NECC, UK Finance, Legal Sector Affinity Group (LSAG), Accountancy Affinity Group (AAG), HM Treasury (HMT), Home Office 

Last updated: September 14, 2020

action 2
Develop a fully operational performance system to measure what works
Completed
Due: July 2020
Overview:

It is important to understand the impact of different interventions linked to the plan in order to inform future strategies. The Home Office has committed to developing an outcome-based performance measurement system to fulfil this need.

Progress:

A framework of key performance questions and measures has been developed. There are current plans in place to introduce the new performance measurement system in July 2020. 
Updated June 2020. 

The framework of key performance measures has been adopted and will be updated as new information sources emerge.
Updated September 2020. 

Responsible Organisations:

Home Office, UK Finance, NECC, JFT

Last updated: September 14, 2020

action 3
Conduct new National Risk Assessments on money laundering, terrorist financing and proliferation financing
In progress
Due: July 2020
Overview:

It is a requirement of the FATF standards that countries produce a National Risk Assessment (NRA) on money laundering, terrorist financing and proliferation financing. HM Treasury and the Home Office are leading on producing the third UK NRA.

Progress:

HM Treasury is currently consulting with stakeholders on the National Risk Assessment on Money Laundering and Terrorist Financing and the National Risk Assessment on Counter Proliferation Financing. 
Updated June 2020. 

Resourcing pressures due to COVID-19 have delayed the publication of the National Risk Assessments on Money Laundering and Proliferation Financing. They are now due for publication in early autumn 2020.
Updated September 2020.

Responsible Organisations:

HMT, Home Office

Last updated: September 14, 2020

action 4
Better understand the threat and performance in combatting public sector fraud
No due date
Due: Ongoing
Overview:

The Cabinet Office is working with public sector bodies to help them develop fraud risk assessments and performance frameworks to measure their impact.

Progress:

The Cross-Government Fraud Landscape Report 2019 was published in February 2020.  This report is the main means of tracking government knowledge and performance in this area.
Updated June 2020. 

Responsible Organisations:

Cabinet Office

Last updated: September 14, 2020

action 5
Resolve evidence gaps through a long-term research strategy
Completed
Due: December 2019
Overview:

The evidence base on economic crime is currently weak and there are a number of research gaps. The Home Office is leading on developing a long-term research strategy to improve understanding of the threat and what works in the countering of it.

Progress:

The Home Office Serious Organised Crime Research Analysis team has conducted surveys and workshops to map and better understand the evidence gaps in the UK's understanding of economic crime. This action is overdue due to delays caused by the 2019 general election and COVID-19. However a strategy is being finalised for distribution in summer 2020. 
Updated June 2020. 

The research strategy has now been adopted and circulated to a select group in the academic community. There are plans to publish the strategy in autumn 2020.
Updated September 2020. 

Responsible Organisations:

Home Office, with support of NECC, HMT, Ministry of Justice

Last updated: September 14, 2020

actions 6-10
Better information-sharing
actions 6-10
action 6
Review barriers to information- sharing, powers and gateways
Completed
Due: March 2020
Overview:

Legally compliant information-sharing is essential to countering money-laundering and wider economic crime. The Home Office, HM Treasury, the NECC, UK Finance and the Information Commissioners Office (ICO) have established the Information Sharing Working Group. This group has committed to mapping barriers to information sharing between public and private sectors on economic crime.

Progress:

Complete. The Information Sharing review completed as planned in March 2020. The review identified a number of recommendations which are currently being progressed and it is expected that improving Information Sharing gateways will be a continued focus of Economic Crime reform. 
Updated June 2020. 

Responsible Organisations:

Home Office, HMT, with support of NECC, UK Finance, Information Commissioner’s Office,28 LSAG, AAG, Department for Digital, Culture, Media and Sport

Last updated: September 14, 2020

action 7
Promote sharing of information in corporate groups
Completed
Due: March 2020
Overview:

The legal and regulatory position regarding the sharing of data between geographically distinct affiliates within the same corporate group has been unclear to date. The Home Office and HM Treasury has committed to clarifying the UK government’s position on this issue to promote greater international consistency.

Progress:

This action has been completed and a statement was published on 12 May. 
Updated June 2020. 

Responsible Organisations:

Home Office, HMT

Last updated: September 14, 2020

action 8
Expand and enhance public-private information-sharing through JMLIT
In progress
Due: July 2020
Overview:

The JMLIT, established in 2015, is the UK’s public-private information sharing platform working to increase operational coordination between UK law enforcement and financial institutions on countering money-laundering. The NECC has committed to reviewing the JMLIT in 2020 to consider its future development, including considering additional sectors, technology requirements and information dissemination.

Progress:

JMLIT expanded in 2020 to include an insurance sector sub-group. New Expert Working Groups have been established, including in relation to fraud. Membership continues to expand on an ongoing basis.
Updated June 2020. 

The governance arrangements for the JMLIT have seen expanded to reflect the expanded membership. The first meeting of the new governance board will be in autumn 2020. The board will oversee the development of a new public-private strategy, which utilises the collective assets of members.
Updated September 2020. 

Responsible Organisations:

HMT, Home Office

Last updated: September 14, 2020

action 9
Improve information-sharing between AML/CTF supervisors and law enforcement
In progress
Due: Ongoing
Overview:

The flows of information between the UK’s 25 anti-money laundering (AML) supervisors and between these bodies and law enforcement has traditionally been sub-optimal. This action seeks to review to current system to improve information flows relating to the supervisory landscape.

Progress:

OPBAS have established Accountancy and Legal Sector Intelligence Sharing Expert Working Groups (ISEWGs) under the auspices of the JMLIT. RUSI is also partnering with OPBAS and HM Government colleagues to support this action, although this work is currently suspended due to the COVID-19 crisis.
Updated June 2020. 

Responsible Organisations:

NECC, UKFIU, OPBAS, with support of AML/CTF supervisors, LSAG, AAG

Last updated: September 14, 2020

action 10
Promote information-sharing in relation to fraud
In progress
Due: December 2020
Overview:

The Home Office has committed to updating the list of ‘Specified Anti-Fraud Organisations’ (SAFOs) (Serious Crime Act 2007) and the related Code of Practice to provide an improved legal footing for private sector information sharing. The Cabinet Office will use the Digital Economy Act 2017 to pilot data-sharing between organisations around fraud losses.

Progress:

The Home Office is currently reviewing the legislation relating to 'Specified Anti-Fraud Organisations' (SAFO) to ensure it remains fit for purpose. Furthermore, the Cabinet Office is using the Digital Economy Act 2017 to pilot data-sharing between other private sector organisations.
Updated June 2020. 

The Home Office is in the process of reviewing SAFO legislation to ensure this remains fit for purpose. A Fraud Ministerial Board has been established to review legislation, intelligence sharing and lessons from the COVID-19 experience.
Updated September 2020. 

Responsible Organisations:

Home Office, Cabinet Office

Last updated: September 14, 2020

actions 11-19
Powers, procedures and tools
actions 11-19
action 11
Implement the Asset Recovery Action Plan
In progress
Due: July 2022
Overview:

The Asset Recovery Plan is a separate but linked plan launched at the same time as the Economic Crime Plan. It covers the measures the government plans to take to freeze, seize and confiscate/recovery the proceeds of crime through the range of legal tools available in the Proceeds of Crime Act 2002. 

Progress:

Key deliverables of the ARAP, such as the reviews of the Proceeds of Crime Centre and the Asset Recovery Incentivisation Scheme are currently in train. The Law Commission review on confiscation was due to report in September 2019, but was delayed with a report now due in summer 2020. 
Updated June 2020. 

Delivery of the ARAP is still ongoing. Key deliverables, such as a review of the Proceeds of Crime Centre (training function within the NCA) have been complete and a report will be published in the autumn. HMCTS and HO continue to look for solutions relating to unenforced confiscation orders. The Law Commission review on confiscation remains unpublished. 
September 2020. 

Responsible Organisations:

Home Office, law enforcement agencies

Last updated: September 14, 2020

action 12
Consider legislative changes to improve the Proceeds of Crime Act
In progress
Due: December 2021
Overview:

The Law Commission, the independent reviewer of the law in England and Wales, was commissioned by the Home Office in 2017 and 2019 respectively to review the law as it relates to money-laundering and criminal confiscation as contained within the Proceeds of Crime Act 2002. In 2019 the Law Commission delivered its report on money laundering. The report on confiscation is due to report in early 2020 after which the Home Office will consider changes to the Proceeds of Crime Act 2002.

Progress:

The Home Office is currently considering whether legislative changes are needed to reform the Suspicious Activity Reporting (SARs) regime and improve the response the fraud. The Law Commission review into confiscation legislation, overdue since September 2019, will also inform future changes to POCA in 2020.  
Updated June 2020. 

The Home Office is in the early stages of identifying which aspects of the Economic Crime Plan may require potential changes to legislation. Potential proposals relating to Information Sharing and AML effectiveness are being developed through a public-private Expert Working Group. A Law Commission review into POCA (Part V) will also inform future changes to POCA and is due to start consultation in the Autumn.
Updated September 2020. 

Responsible Organisations:

Home Office

Last updated: September 14, 2020

action 13
Transpose the Fifth Money Laundering Directive
Completed
Due: January 2020
Overview:

The UK was obliged to transpose the EU Fifth Anti-Money Laundering Directive (5MLD) into UK law by January 2020. Key changes included the incorporation of crypto-asset providers, letting agents and art dealers into the regulated sector.

Progress:

The regulations transposing the 5th Anti-Money Laundering Directive into UK law were laid before Parliament in December 2019 and came into force in January 2020. 
Updated June 2020. 

The trust registration measures were not included in the original transposition to allow time for further consultation. This was run early in the year and the legislation will be laid before Parliament in September. 
Updated September 2020. 

Responsible Organisations:

HMT

Last updated: September 14, 2020

action 14
Implement the Disclosure Review recommendations
Overdue
Due: December 2019
Overview:

Digital technologies have presented challenges to the UK’s ‘disclosure regime’ (a legal regime implemented in 1996 to reduce miscarriages of justice), particularly in economic crime cases which often have huge volumes of data. The Attorney General’s Office led a review of the regime in 2018. The government has committed to implementing its findings.

Progress:

The Disclosure Review was published by the Attorney General in 2018. The subsequent consultation on the new proposed guidelines was published in February 2020 (after the initial deadline in the Economic Crime Plan). Due to COVID-19 the timeline for responding to the consultation has been extended to July 2020. The Attorney General's Office plans to implement changes by late 2020. 
Updated June 2020. 

The public consultation closed on 22 July 2020. The Statutory Instrument (SI) is due to be laid in parliament in September 2020. The Attorney General's Office plans to implement changes by late 2020.
Updated September 2020. 

Responsible Organisations:

AGO, CPS, NPCC

Last updated: September 14, 2020

action 15
Consider tactical targeting orders
In progress
Due: July 2020
Overview:

The UK is considering whether powers analogous to the US ‘Geographic Targeting Order’ (a power which allows law enforcement to direct specific businesses to report all transactions over a certain threshold in order to fill intelligence gaps) may be appropriate in the UK.

Progress:

The Home Office is currently consulting law enforcement colleagues on scope of the potential powers. Separately RUSI is conducting an independent policy paper looking at a comparison with US Geographic Targeting Orders due to publish in late summer 2020. 
Updated June 2020.

RUSI is providing technical policy support to the Home Office to support its consideration of the powers in the UK context.
Updated September 2020.

Responsible Organisations:

Home Office, HMT, UKFIU

Last updated: September 14, 2020

action 16
Develop framework to repatriate funds to victims of fraud
In progress
Due: December 2021
Overview:

The Home Office, Joint Fraud Taskforce and UK Finance are committed to developing the technical and legal frameworks to allow the repatriation of fraudulent funds from criminals back to victims.

Progress:

The Home Office has established a working group to consider the legal and regulatory barriers to fraud fund repatriation.
Updated June 2020. 

Work has commenced with the legal sector to explore the legal ramifications of fund repatriation. The Home Office is working closely with law enforcement and the banking sector on pilots to explore use of funds held in suspended accounts to compensate fraud victims. 
Updated September 2020. 

Responsible Organisations:

Home Office, with support of JFT, UK Finance

Last updated: September 14, 2020

action 17
Clarify sanctions supervision powers
In progress
Due: July 2020
Overview:

HM Treasury, working with AML Supervisors, are considering whether guidance is necessary to clarify supervisor’s powers to take enforcement action in relation to deficiencies relating to the monitoring of financial sanctions.

Progress:

HM Treasury is currently reviewing the systems and controls in place under the UK's AML supervisory regime to monitor sanctions compliance prior to progressing work with the individual supervisors based on this review.
Updated June 2020. 

Responsible Organisations:

HMT, with support of AML/CTF supervisors, LSAG, AAG

Last updated: September 14, 2020

action 18
Review the criminal market abuse regime
In progress
Due: July 2021
Overview:

The criminal market abuse regime sets out the UK’s criminal sanctions for insider dealing and market manipulation. The FCA and HM Treasury are committed to reviewing the criminal market abuse regime to ensure it remains fit for purpose.

Progress:

The FCA and HM Treasury have developed the terms of reference for this project. The initial analytical work is planned for 2020. 
Updated June 2020. 

The initial assessment of the current regime has been completed. The issues identified in the initial assessment are under review by the FCA and HMT. Final recommendations for updating the regime will then be developed.
Updated September 2020. 

Responsible Organisations:

FCA, HMT

Last updated: September 14, 2020

action 19
Investigate power to block listings on national security grounds
Overdue
Due: June 2020
Overview:

HM Treasury is considering whether a power to block listings on national security grounds is appropriate in the UK. If it is found to be desirable, a full consultation will follow.

Progress:

Analysis is underway to consider this issue. 
Updated June 2020. 

Responsible Organisations:

HMT

Last updated: September 14, 2020

actions 20-32
Enhanced capabilities
actions 20-32
action 20
Continue to develop the NECC as a genuine public-private hub for combatting serious and organised economic crime
In progress
Due: July 2021
Overview:

The NECC was established in December 2018 to coordinate the law enforcement response to economic crime. The intention is that the NECC will be established as the lead economic crime law enforcement agency by July 2021.

Progress:

The NECC has continued to develop since the publication of the Economic Crime Plan. It has established a public-private fusion cell to look specifically at the economic crime impacts of COVID-19. However, no publicly available statement is available regarding the long-term strategy for the NECC and it's place in the UK counter-economic crime law enforcement landscape. 
Updated June 2020. 

In September 2020 the NECC adopted a new governance structure and it is adopting a new public-private partnership strategy. However there continues to be no publicly available, long-term strategy for the NECC setting out its role in the law enforcement landscape. 
Updated September 2020                                                      

Responsible Organisations:

NECC

Last updated: September 14, 2020

action 21
Understand and enhance capabilities
In progress
Due: July 2020
Overview:

The NECC and UK Finance have committed to mapping the capabilities of law enforcement and major financial institutions to tackle economic crime in order to inform future public-private working. 

Progress:

The NECC is working with public and private sector partners to map and develop capabilities to combat economic crime across the public and private sector. 
Updated June 2020. 

Responsible Organisations:

NECC, Cabinet Office, UK Finance

Last updated: September 14, 2020

action 22
Develop public-private action plans to combat economic crime threats
Completed
Due: January 2020
Overview:

Building on the public-private threat updates (Action 1) the NECC, Home Office and HM Treasury have committed to developing public-private action plans to combat economic crime.

Progress:

In December 2019, the NECC established the first public-private action plan to tackle fraud under Project OTELLO. This covers a 12-month period of operational activity across public and private sectors. There is currently no information to evidence the development of further public-private action plans in other areas.
Updated June 2020. 

All new action plans developed by the NECC now consider public-private aspects as standard.
Updated September 2020. 

Responsible Organisations:

NECC, Home Office, HMT, UK Finance

Last updated: September 14, 2020

action 23
Develop a sustainable, long-term resourcing model for economic crime reform
Overdue
Due: March 2020
Overview:

The Home Office, HM Treasury and NCA have committed to developing a long-term, sustainable resourcing model to support economic crime reform, including the UKFIU, the SARs regime and the Register of Bank Account Ownership.

Progress:

In the March 2020 Budget it was announced that the Government intends to introduce an Economic Crime Levy which could raise as much as £100m a year to pay for economic crime reform and to support the resourcing of the NECC. This Levy will be consulted on in 2020 and will not be introduced until this has been done. However, the funding model for the wider policing response to economic crime is currently unclear. 
Updated June 2020. 

The Economic Crime Levy consultation was launched on 21st July 2020 with a closing date for responses of 14th October 2020. This relates to a proposed private sector levy to fund economic crime reform in the UK. The government's autumn spending review should add clarity regarding the public sector contribution to economic crime reform.
Updated September 2020. 

Responsible Organisations:

Home Office, with support of HMT, NCA, UK Finance, Cabinet Office

Last updated: September 14, 2020

action 24
Launch flagship economic crime court in central London
In progress
Due: Ongoing
Overview:

HM Courts and Tribunal Service (HMCTS) is working with the City of London Corporation to develop the UK’s first economic crime central court in Central London.

Progress:

This project has been initiated and is now in the high-level design phase. Work is underway to identify a suitable location for the court.
Updated June 2020. 

The City of London Corporation has published its plans for a new economic crime court at Fleet Street. The Fraud Advisory Panel, in consultation with leading legal and civil society experts, is drafting a white paper to submit to government with proposals regarding issues to consider in relation to the proposed Economic Crime Court.
Updated September 2020. 

Responsible Organisations:

HM Courts and Tribunal Service, Ministry of Justice, with support of City of London Corporation

Last updated: September 14, 2020

action 25
Consider how the payments systems can help tackle economic crime
In progress
Due: 2021
Overview:

The New Payments Architecture (NPA) – a new interbank payment system – is expected to go live in 2021. Pay.UK, the body responsible for the system, is considering how the design of the NPA can help to tackle economic crime.

Progress:

Various strands of activity are currently in train to support this action, including implementation of the 'confirmation of payee' scheme, the issuing of a consultation relating to New Payments Architecture and the development of new 'Transaction Data Analytics' by Pay.UK.
Updated June 2020. 

Various strands of activity continue to be progressed to support this action, including embedding of the Confirmation of Payee service, the on-going work relating to the New Payments Architecture and the development of Transaction Data Analytics by Pay.UK.
Updated September 2020. 

Responsible Organisations:

Pay.UK, with support of Payment Systems Regulator, FCA, HMT, UK Finance; Bank of England

Last updated: September 14, 2020

action 26
Improve the policing response to fraud
Overdue
Due: March 2020
Overview:

The Home Office is working with the City of London Police and the NECC to address the current deficiencies in the law enforcement response to fraud, including by improving capabilities, strengthening reporting, clarifying responsibilities and improving the support to victims.

Progress:

Progress has been made to respond to the 2018 HMICFRS review of the policing response to fraud. However the reform progress is not complete. In particular it is not clear how national, regional and local responses delineate and how the response for victims be improved. More work is needed, in particular, to develop a public plan to respond to Sir Craig Mackey's 2020 reports on Action Fraud and Serious and Organised Crime.
Updated June 2020. 

Progress has been made on addressing the findings of the HMICFRS review of fraud policing . However, the long-term funding model and structure for fraud policing remains unclear. The Spending Review, planned for Autumn 2020, is likely to offer more clarity on the response.
Updated September 2020. 

Responsible Organisations:

Home Office, with support of City of London Police, NECC

Last updated: September 04, 2020

action 27
Improve support for victims of fraud
In progress
Due: August 2020
Overview:

The Home Office, working with key partners, will consider an updated model for supporting the victims of fraud at local, regional and national levels. This will be informed by the existing Economic Crime Victims Case Unit model.

Progress:

The Home Office and City of London police are working together on a phased rollout of 'Economic Crime Victim Case Units', which is part of the response. The plan for an updated model for victim support at local, regional and national level is due for delivery in August 2020.
Updated June 2020. 

Work is ongoing to bolster existing 3rd sector pilot schemes via National Trading Standards/ support hubs and to deliver a nationwide rollout of the currently piloted Economic Crime Victim Care Unit (ECVCU) ​on a phased basis and bolster local police force victim support​.
Updated September 2020. 

Responsible Organisations:

Home Office

Last updated: September 14, 2020

action 28
Close the vulnerabilities that criminals exploit to conduct fraud
In progress
Due: December 2020
Overview:

The Joint Fraud Taskforce has committed to leading a programme of work to address the vulnerabilities that criminals exploit to conduct fraud, including through working with the telecommunications sector.

Progress:

The Joint Fraud Taskforce are currently focusing on defining and addressing the vulnerabilities in the telecommunications and banking sectors that make them vulnerable to fraud.
Updated June 2020. 

The Joint Fraud Taskforce are currently focusing on defining and addressing the vulnerabilities in the telecommunications and banking sectors that make them vulnerable to fraud with work ongoing to develop and deliver a specific portfolio of actions to meet the ECP action. Online Harms legislation, led by DCMS, is progressing towards publication of a full government consultation response, with scope to be defined.
Updated September 2020. 

Responsible Organisations:

JFT

Last updated: September 14, 2020

action 29
Build our Government Counter Fraud Profession
In progress
Due: April 2021
Overview:

The Cabinet Office is continuing to develop the Government Counter Fraud Profession. It has committed to exploring the extension of the profession to other sectors and to reviewing the powers available to public sector investigators.

Progress:

There are currently 6,300 members of the Government Counter Fraud Profession. However, the long-term funding plan to enable the growth of the programme remains unclear.
Updated June 2020.

Responsible Organisations:

Cabinet Office

Last updated: September 14, 2020

action 30
Deliver first tranche of SARs IT transformation and design the target operating model for the future of the SARs regime
In progress
Due: December 2020
Overview:

The SARs Transformation Programme has committed to agreeing the next iteration of the target operating model for the SARs regime, alongside delivering the first tranche of IT reform.

Progress:

Work is underway to design the replacement SARs IT system and to design a new operating model within law enforcement.
Updated June 2020. 

The SARs Outline Business Case was approved by the Home Office Portfolio Investment Committee in August 2020.

A public-private Expert Working Group has been established to review the 'Consent' (DAML) process. Recruitment is underway for additional Financial Investigators in Regional Organised Crime Units (ROCUs) to increase the analysis of SARs intelligence.  Guidance work is ongoing to develop improvements to industry guidance.
Updated September 2020. 
 

Responsible Organisations:

SARs Transformation Programme, NCA, Home Office, with support of HMT

Last updated: September 14, 2020

action 31
Deliver greater feedback and engagement on SARs
In progress
Due: 2020
Overview:

The SARs Transformation Programme will seek to enhance the capability of the UKFIU to deliver feedback to reporters on SARs. It is envisaged that this will be delivered through improved IT and increased outreach capability.

Progress:

The recruitment of additional staff to the UK Financial Intelligence Unit has included additional posts relating to external engagement, which will help to deliver this action.
Updated June 2020. 

Additional staff have been recruited in the UK Financial Intelligence Unit and OPBAS have formed a committee to examine greater provision of guidance to the regulated sector.
Updated September 2020. 

Responsible Organisations:

SARs Transformation Programme, UKFIU, Home Office

Last updated: September 14, 2020

action 32
Ensure the confidentiality of the SARs regime
Overdue
Due: December 2019
Overview:

The material contained within SARs is confidential and requires protection. The protection of this material from disclosure in criminal proceedings is clear, but not in civil proceedings. The Home Office, UKFIU and HM Treasury are working together to develop options to protect SARs material from being disclosed in civil proceedings.

Progress:

A Home Office circular is currently in draft form clarifying the confidentiality of SARs in civil proceedings. Once issued, the effectiveness of the circular in addressing the issue will need to be kept under review.
Updated June 2020. 

The Home Office circular remains in draft form due to delays caused by the COVID-19 situation. 
Updated September 2020. 

Responsible Organisations:

Home Office, UKFIU, with support of HMT

Last updated: September 14, 2020

actions 33-41
Risk-based supervision and risk management
actions 33-41
action 33
Review the MLRs and OPBAS regulations
Inactive
Due: June 2022
Overview:

HM Treasury will lead a review of the Money Laundering Regulations (MLRs) and OPBAS Regulations to measure their impact and proportionality. The review will commence in 2021.

Progress:

The review will commence in 2021.
Updated June 2020. 

Responsible Organisations:

HMT

Last updated: September 14, 2020

action 34
Enhance FCA supervision and engagement
In progress
Due: March 2021
Overview:

The FCA is working to enhance its risk-based approach to AML/CTF supervision in response to the FATF Mutual Evaluation Report (2018). It is also committed to increasing industry outreach, working with the Pensions Regulator to reduce pensions scams and enhancing efforts to tackle market abuse.

Progress:

This action is currently progressing along a number of lines: The FCA is trialling a new data-led AML Supervision model; its ran a ScamSmart investment scams campaign in November 2019 and continues to run an education programme on market abuse with market participants.
Updated June 2020. 

The FCA has re-run its SMARTSCAM investment campaign in July 2020 in conjunction with the Pensions Regulator and has commenced a campaign relating to high-risk investments using social media and search engine optimisation techniques.
Updated September 2020. 

Responsible Organisations:

FCA, with support of Pensions Regulator

Last updated: September 14, 2020

action 35
Enhance HMRC supervision
In progress
Due: March 2021
Overview:

HMRC has committed to delivering an enhanced risk-based approach to AML/CTF supervision. This will include a tightened registration process, a full review of the HMRC Supervision Operating Model and implementation of a new sanctions framework. HMRC will also carry out an annual self-assessment of its supervisory alignment to the OPBAS sourcebook standards.

Progress:

HMRC is developing a new risk-based approach to supervision, it has launched a new sanctions framework, it has created a new joint working group with OPBAS and has expanded its supervision team.
Updated June 2020. 

Responsible Organisations:

HMRC, with support of OPBAS, HMT

Last updated: September 14, 2020

action 36
Strengthen the consistency of professional body AML/CTF supervision
In progress
Due: March 2021
Overview:

OPBAS has committed to working with accountancy and legal professional body supervisors to ensure they have appropriate plans in place to address the OPBAS first year report and will monitor their progress against these on a continual basis.

Progress:

OPBAS launched it's 2nd Annual Report in April 2020. All Professional Body Supervisors (PBS) now have AML strategy plans in place. OPBAS have now moved into the next phase, which will test the effectiveness of PBS' supervision.
Updated June 2020. 

OPBAS are in the process of starting inspection visits to assess the effectiveness of PBS strategies. OPBAS are working with HM Treasury on designing a process in the event that a supervisor is removed from the Schedule 1 list of approved supervisors. This work is nearing completion, but has been delayed to autumn 2020 by the Covid-19 situation.
Updated September 2020. 

Responsible Organisations:

OPBAS, accountancy and legal professional body supervisors

Last updated: September 14, 2020

action 37
Establish the FCA as the supervisor of the future cryptoassets AML/CTF regime
Completed
Due: January 2020
Overview:

The FCA has committed to establishing itself as the supervisor of crypto-assets, as required by the 5th Anti-Money Laundering Directive.

Progress:

The FCA became the supervisor of crypto-assets in the UK in January 2020. 
Updated June 2020. 

Responsible Organisations:

FCA

Last updated: September 14, 2020

action 38
Support innovation in regulatory compliance for AML/CTF
In progress
Due: Ongoing
Overview:

The FCA is committed to supporting innovation as relates to AML/CTF. It will aim to do this by allowing firms to test innovative tools in its ‘Regulatory Sandbox’ and through running TechSprints, which explore new data-sharing technologies. In addition, the Government has committed to establishing a new ‘Innovation Working Group’ to promote innovation.

Progress:

The first meeting of the Innovation Working Group was held on the 24th January 2020, the Group plans to continue to meet. The FCA continues to work with the private sector via its TechSprint and Project Innovate lines of work.
Updated June 2020. 

The Innovation Working Group met on 25th August to discuss privacy enhancing technologies and their role in transforming the response to economic crime. The FCA's regulatory 'sandbox' initiative continues to support innovation in the financial sector.
Updated September 2020. 

Responsible Organisations:

FCA, HMT, UK Finance with the support of Home Office, Corporation of the City of London

Last updated: September 14, 2020

action 39
Enhance firms’ holistic response to economic crime
In progress
Due: Ongoing
Overview:

UK Finance and other relevant industry associations has committed to working with  firms to help the industry to bolster their own defences, including through enhancing counter-fraud efforts improving consistent use of financial crime compliance systems. This will include the promotion of industry best practice, such as the Authorised Push Payment voluntary code.

Progress:

UK Finance are working to promote a variety of operational projects, including relating to money mules and the response to COVID-19 fraud.
Updated June 2020. 

Responsible Organisations:

UK Finance, with support of other relevant industry associations

Last updated: September 14, 2020

action 40
Promote digital identity services
Completed
Due: October 2019
Overview:

HM Treasury has committed to working with the new Digital Identity Unit and public and private partners to promote digital identity services. This will include working with FATF to produce new guidance clarifying the application of FATF’s customer due diligence requirements.

Progress:

The government worked extensively with the Financial Action Taskforce to produce guidance on the use of digital identities, which was published in March 2020.
Updated June 2020. 

Responsible Organisations:

HMT, with support of the Digital Identity Unit, Joint Money Laundering Steering Group, HMRC, Gambling Commission, LSAG, the Consultative Committee of Accountancy Bodies

Last updated: September 14, 2020

action 41
Education and awareness-raising on economic crime threats and the recovery of criminal assets
Completed
Due: December 2019
Overview:

The NECC, UK Finance and the Home Office, working with partners, have committed to developing an enhanced approach to education and awareness-raising of economic crime threats, with a particular focus on deterring money mules. Also, as set out in the Asset Recovery Action Plan (ARAP), the Home Office will consider how best to empower communities to identify high end criminal assets.

Progress:

The government has established a Strategic Communications Steering Group to deliver the objectives of the Economic Crime Strategy Communications Plan.
Updated June 2020. 

The Strategic Communications Steering Group has been established and is now meeting regularly to discuss delivery of the Economic Crime Strategic Communications Plan. UK Finance is working with HM Government partners to deliver financial sector aspects of the plan. 
Updated September 2020. 

Responsible Organisations:

NECC, UK Finance, Home Office with support of LSAG, AAG

Last updated: September 14, 2020

actions 42-44
Transparency of ownership
actions 42-44
action 42
Reform Companies House
In progress
Due: Ongoing
Overview:

BEIS is consulting on wide-reaching reforms of Companies House, the UK registrar of companies. The proposals include verification of director’s identities and company presenters and a more active role for Companies House in the UK’s regime to counter economic crime.

Progress:

In May 2019 the government published a consultation on Corporate Transparency and Register reform, which included draft reforms to Companies House. The consultation closed in August 2019. The response to the consultation was expected in March 2020, but is yet to be published.
Updated June 2020. 

Responsible Organisations:

BEIS, with support of Companies House

Last updated: September 14, 2020

action 43
Introduce a requirement to report discrepancies of beneficial ownership information
Completed
Due: January 2020
Overview:

HM Treasury has committed to legislating to require regulated firms to report discrepancies between beneficial ownership information available at Companies House and information they obtain through their compliance checks. 

Progress:

The government introduced a mechanism to report discrepancies in data held by Companies House in January 2020.
Updated June 2020.

Responsible Organisations:

HMT

Last updated: September 14, 2020

action 44
(i) Enhance transparency of overseas ownership of UK property and (ii) reform limited partnerships
In progress
Due: (i) 2021 (ii) Ongoing
Overview:

The Government’s Register of Overseas Entities Bill, if enacted, establishes a new beneficial ownership register of overseas entities which own UK property. Furthermore, the Government has committed to reform limited partnerships, including by requiring that limited partnerships maintain an ongoing connection with the UK.

Progress:

The Register of Overseas Entities Bill was announced in the December 2019 Queen's Speech. The draft legislation has not yet been introduced to Parliament.        
Updated June 2020. 

The Government provided an update to the House of Commons via a written statement on 21st July regarding progress towards introducing legislation to the House.
Updated September 2020. 

Responsible Organisations:

(i) BEIS, with support of Companies House
(ii) BEIS

Last updated: September 14, 2020

actions 45-49
International Strategy
actions 45-49
action 45
Improve understanding of the nature and impact of the international threat
In progress
Due: Ongoing
Overview:

This action sets out a range of commitments relating to improving understanding of the international threat, including through public-private threat assessments (NECC), engagement with the Egmont Group (UKFIU) and the establishment of a single coordinated UK government response to international illicit finance (Home Office, HM Treasury, DFID).

Progress:

Work on this action has commenced along a number of strands and is coordinated by a cross-government International Illicit Finance Working Group, which works with the SOCnet international law enforcement and DFID networks.
Updated June 2020. 

Responsible Organisations:

NECC, UKFIU, Home Office, DFID

Last updated: September 14, 2020

action 46
Joint work on meeting international standards
In progress
Due: Ongoing
Overview:

The Government has committed to increasing the UK’s engagement with multi-lateral standard setting bodies to improve international standards, including the OECD, FATF and UNODC. It has also committed to increasing bi-lateral engagement with priority jurisdictions, including increasing technical assistance and capacity-building and increasing engagement with multi-lateral private sector and civil society forums.

Progress:

Work has commenced along a number of lines including: work to progress the UK's compliance with the UN Convention Against Corruption (UNCAC) and £3 million in funding to support FATF-Style Regional Bodies.
Updated June 2020. 

Further to the actions above the government is due to publish a full report on compliance with UNCAC in late 2020 and a report considering progress against recommendations made by the OECD Working Group on Bribery in March 2021.
Updated September 2020. 

Responsible Organisations:

Home Office, HMT, UK Finance, DFID, with support from Corporation of the City of London, FCO, Government Digital Service

Last updated: September 14, 2020

action 47
Enhance overseas capabilities
In progress
Due: Ongoing
Overview:

The Government has committed to enhancing its overseas illicit finance platform. This includes the establishment of an International Centre of Excellence (DFID), creating a new Global Financial Investigators Academy (DFID), international supervisory coordination (all statutory supervisors), law enforcement placements overseas (NECC) and engagement with the International Public Sector Fraud Forum (Cabinet Office). 

Progress:

Work has commenced along a number lines including; the development of an International Centre of Excellence is in the design phase and is due to deliver in summer 2020; the design of a new Global Financial Investigators Academy has commenced but has been stalled by the COVID-19 crisis; statutory AML supervisors and OPBAS are exchanging information with overseas counterparts; and the International Fraud Forum was hosted in the UK in February 2020 (UK, US, New Zealand, Australia and Canada) and has developed four products for counter fraud professionals to use globally. 
Updated June 2020. 

Working is in train along a number of tracks including: The Intelligence Centre of Excellence design phase which is now complete; the sharing of best practice in tackling public sector fraud with 5 eyes partners; the launch of an AML/CTF Technical Assistance to support partner countries to implement the FATF Standards; regular regulatory engagement with supervisory partners overseas; engagement in the FATF Supervisors Forum and working group on DNFBP guidance; funding of UNODC programme on UNCAC implementation. 
Updated September 2020. 

Responsible Organisations:

DFID, International Centre of Excellence, Home Office, DFID, FCO, FCA, HMRC, Gambling Commission, HMT, OPBAS, NECC, UKFIU, Cabinet Office

Last updated: September 14, 2020

action 48
Strengthen capability to investigate and prosecute bribery and corruption overseas
In progress
Due: Ongoing
Overview:

UK Aid has committed to increase funding to the International Corruption Unit (NCA) and the CPS to increase staffing levels. The FCO has committed to continue funding the International Anti-Corruption Co-ordination Centre.
Updated June 2020


A new phase of funding for the International Corruption Unit commenced in April 2020 however ODA cuts mean that funding has remained at  similar levels to previous years, rather than increasing, so NCA have not been able to scale up staffing as fast as planned. 
Updated September 2020

Progress:

DFID continue to fund the International Corruption Unit at the NCA. Additional funding has been allocated to increase the staffing by 20. ​The long-term funding position for the International Anti-Corruption Centre is currently unclear.
Updated June 2020. 

Responsible Organisations:

DFID, NCA, CPS, FCO

Last updated: September 14, 2020

action 49
Promote integrity in business internationally
Inactive
Due: Ongoing until 2021
Overview:

The Business Integrity Initiative was launched in 2018 to support UK businesses seeking to build a base in emerging markets, by offering guidance on bribery and human rights. The government (DFID, DIT, FCO, Corporation of the City of London) has committed seed funding to this initiative until 2021. The FCO will continue to support the OECD’s to improve business integrity.

Progress:

The Business Integrity Initiative launched in 2018 to help companies guard against bribery and corruption when trading in developing countries, it is currently paused in response to the COVID-19 crisis. 
Updated June 2020. 

The Business Integrity Initiative is being reconfigured in response to the COVID-19 situation.
Updated September 2020.

Responsible Organisations:

DFID, Department for International Trade, FCO, with support from Corporation of the City of London

Last updated: September 14, 2020

actions 50-52
Governance and public-private partnership
actions 50-52
action 50
Review the economic crime governance
Completed
Due: September 2019
Overview:

The Home Office and HM Treasury have committed to reviewing economic crime governance to ensure it is able to effectively implement the actions set out in the plan. This will include considering the balance of representation and transparency regarding the public-private composition of the governance arrangements.

Progress:

A governance review was completed in September 2019 and concluded that the original structures should be retained. The Civil Society Organisations Steering Group (see action 52) continue to advocate for the addition of an independent observer function into the Economic Crime Strategic Board to provide greater transparency and oversight of public-private decision-making.
Updated June 2020. 

Responsible Organisations:

Home Office, HMT

Last updated: September 14, 2020

action 51
Develop stronger public-private and private-private partnerships
In progress
Due: Ongoing
Overview:

The Home Office, HM Treasury and the NECC have committed to better engaging with sectors and organisations not currently represented in the economic crime governance landscape, including smaller and geographically diverse organisations. UK Finance will also work with other financial and payment organisations to enhance cross-sectoral cooperation.

Progress:

Some private sector organisations are embedded in Economic Crime governance and engaged in key working groups such as Information Sharing and Sustainable Resourcing. This is particularly the case with the financial sector. Discussions continue with other sectors, including the accountancy and legal professions, on key areas such as implementation of the 5th Anti-Money Laundering Directive. However more work is needed to develop stronger alliances outside of the financial sector.
Updated June 2020. 

Work to develop stronger alliances outside of the financial sector continues. This included the chairing of a Ministerial meeting with the legal, accountancy and telecommunications sectors in July 2020.
Updated September 2020. 

Responsible Organisations:

Home Office, HMT, UK Finance with support from LSAG, AAG, Corporation of the City of London

Last updated: September 14, 2020

action 52
Enhance engagement with civil society
Completed
Due: Ongoing
Overview:

The Government has committed to increasing formal links with representatives from non-government organisations, academia, victims groups and civil society, through the creation of a civil society-led mechanism to engage on policy and operational issues.

Progress:

In March 2020 the Civil Society Organisations Steering Group met for the first time. The Group is comprised of a range civil society organisations, including Global Witness, Transparency International, Fraud Advisory Panel, Spotlight on Corruption and RUSI. This body offers a mechanism via which CSOs can both actively comment on the work of the ECP and ECSB but also proactively raise issues which it thinks the ECSB should consider. 
Updated June 2020. 

The second meeting of the CSOSG was held on September 11th 2020. The meeting discussed key priority areas, such as corporate transparency reforms. Additionally the CSOSG provided informal feedback on the proposed Economic Crime Levy (see action 23).
Updated September 2020. 

Responsible Organisations:

Home Office, HMT

Last updated: September 14, 2020

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Kayla Izenman
Research Analyst

Centre for Financial Crime and Security Studies

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Helena Wood
Associate Fellow

Centre for Financial Crime and Security Studies

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Isabella Chase
Research Fellow

Centre for Financial Crime and Security Studies

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About CFCS

The Centre for Financial Crime and Security Studies (CFCS) is dedicated to addressing the challenges of financial crime and threat finance to the UK and international security and the important role finance can play in identifying and disrupting a range of globally recognised threats. Established in 2014, the CFCS is a research programme of the Royal United Services Institute (RUSI), the world’s oldest security and defence think tank.

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