UK Economic Crime Progress Report: A mixed picture

The new Outcomes Progress Report, published on 2 September 2025, acknowledges that “making a robust assessment of overall progress is currently challenging.” It points to positive indicators in some areas and stresses that major reforms will take time to bed in. But the data paints a different picture. Across each of the Plan’s objectives, the trajectory is flat or negative. For a strategy explicitly billed as “outcomes-focused”, the reliance on activity measures risks obscuring the extent to which the Plan is actually delivering on its goals.

One bright spot is the arrival of the failure to prevent fraud (FtPF) offence, which came into force on 1 September 2025. Billed as the government’s flagship new tool against corporate fraud, it joins failure to prevent bribery and facilitation of tax evasion in a trio of offences that place the burden on organisations to maintain adequate or reasonable prevention procedures. Its timing is striking: introduced just as the Progress Report reveals how far there is to go, it signals a determination to put corporate responsibility at the centre of the UK’s fraud response.

A step change, or stagnation?

The first Economic Crime Plan (2019-22) was widely described as a step change in the UK’s approach, securing public-private collaboration and delivering measures such as the Register of Overseas Entities. ECP2 promised to go further, with a sharper outcomes focus and longer-term funding. Against that backdrop, the current trajectory looks disappointing. Far from demonstrating cumulative progress, the latest data shows regression on key measures.

Fraud surging in the UK

Nowhere is this clearer than on fraud. Fraud offences rose by 31% in the year ending March 2025. The government is keen to note that the overall value of losses has remained broadly stable – implying that more victims are being defrauded of smaller amounts. But for the pensioner down the road who has lost her savings to an authorised push payment scam, or the ordinary consumer duped into handing over their bank details, the fact that the “average” loss has gone down is hardly reassuring. Fraud remains the most common crime experienced by the public, and its continuing rise suggests that systemic interventions under the Plan have not yet had tangible impact.

The new FtPF offence is aimed at fraud committed for the benefit of large organisations, not the day-to-day scams that afflict individual consumers. That distinction underlines the two tracks of the UK’s fraud challenge: consumer-facing fraud where prevention remains weak, and corporate-facing fraud where the compliance burden is shifting decisively onto companies themselves.

Money laundering convictions and asset recovery

The picture on money laundering is similarly underwhelming. Convictions for money laundering as a principal offence have fallen compared with the previous year. At the same time, asset recovery – a central pillar of ECP2 – has gone into reverse. The total value of recovered assets fell by 29% year-on-year, with only £243.3 million recovered in the year ending 2024. That represents a sharp decline from the record levels achieved in 2021-22, and underscores the challenge of turning legislative change and operational investment into sustainable results.

Suspicious Activity Reports (SARs) – long described as the cornerstone of the UK’s anti-money laundering regime – provide a further illustration. The report highlights that SARs assisted in asset denials totalling £240 million in 2023-24. While this figure is significant, it is well below the three-year rolling average and raises broader questions about efficacy. Given the substantial compliance burden SARs impose on the regulated sector, it is legitimate to ask whether the current regime delivers proportionate value to the system as a whole.

Sanctions and kleptocracy

On sanctions evasion and illicit finance linked to kleptocracy, the picture is more static than transformational. The report notes an increase in the number of designated persons and the aggregate value of frozen funds, but also records a decrease in identified breaches. This may suggest improved compliance, but equally could reflect under-detection or a plateau in enforcement activity. Either way, the data does not indicate a step change in capability.

Structural reforms in play

It is right to acknowledge that several major reforms are underway and in the pipeline. Companies House transformation, the SARs Reform Programme, new crypto-asset regulation and expanded OFSI resources are all highlighted in the report. Each could yield material benefits in time. But for now, their contribution is prospective rather than demonstrable, leaving businesses to navigate an enforcement environment where risks remain high and results uneven.

Resourcing and failure to prevent

The mixed picture also reflects questions of capacity. Enforcement agencies face rising expectations with limited resource, and falling asset recovery levels may be symptomatic of operational limits rather than lack of political will.

At the same time, the legislative environment is tightening.

Most notably, the new FtPF offence came into force on 1 September 2025, joining the existing failure to prevent bribery and facilitation of tax evasion offences. Together, these measures considerably expand corporate exposure.

And there are signs that the tide may be turning. HMRC has, at last, brought its first corporate prosecution under the failure to prevent facilitation of tax evasion offence. The Insolvency Service has announced a more assertive economic crime enforcement strategy. And the Serious Fraud Office has been talking tough on how it will deploy FtPF. The convergence of these developments suggests a system preparing to move beyond planning and into enforcement.

Implications for business

For corporates, several implications follow:

1. Fraud risk remains acute. Businesses should not assume that public-sector interventions will reduce exposure in the short term. Proactive investment in fraud prevention – particularly in digital channels, internal financial controls and customer-facing platforms – remains critical.
2. AML compliance under pressure. Despite doubts over the value delivered by SARs, regulators are unlikely to ease their expectations around reporting. Firms should continue to focus on data quality, internal escalation processes, and ensuring SARs add as much operational value as possible. The FCA continues to bring enforcement actions in the AML systems and controls space, and supervisors are expected to intensify scrutiny of how firms assess and report suspicious activity.
3. Asset recovery in focus. With recovery rates falling, agencies may look to high-profile test cases to demonstrate effectiveness. Companies facing investigation should anticipate closer attention to asset confiscation and restraint alongside traditional prosecution risk.
4. Expanding corporate liability. The arrival of FtPF significantly raises the bar for prevention frameworks. Boards should revisit compliance procedures holistically, aligning anti-fraud, anti-bribery and anti-facilitation of tax evasion controls under a consistent governance structure. At a minimum, organisations should:

• Conduct a dedicated FtPF risk assessment, mapping exposure through employees, subsidiaries and third parties.
• Review contracts with agents, distributors, franchisees and outsourced providers to reflect fraud prevention expectations.
• Strengthen whistleblowing channels, training programmes and board-level oversight to demonstrate reasonable procedures.
• Monitor and refresh controls regularly, particularly in high-risk functions such as sales, procurement and finance.

5. Sanctions compliance is non-negotiable. Even if progress feels static, the government has invested heavily in OFSI and supervisory oversight. Firms should expect continued emphasis on sanctions screening, reporting and audit trails, and prepare for further regulatory engagement.

Conclusion

The Outcomes Progress Report provides a useful stocktake, but its most striking feature is the gap between ambition and delivery. ECP2 set out to “cut crime, protect national security, and support legitimate growth.” Two years in, fraud is rising, asset recovery is falling, sanctions enforcement is largely static, and the UK’s ranking in Transparency International’s Corruption Perceptions Index is at an all-time low.¹

At the same time, the arrival of FtPF may prove a turning point. Unlike consumer fraud prevention, which remains elusive, FtPF directly targets corporate benefit and places responsibility firmly on large organisations.

With HMRC pursuing its first corporate failure to prevent facilitation of tax evasion case, the Insolvency Service signalling a more aggressive stance, and the SFO and CPS preparing to test FtPF in practice, the enforcement environment is hardening.

Businesses cannot afford to wait for clarity: they should be acting now to embed risk assessments, contractual protections and a culture of prevention. The message is clear – the fightback against economic crime has begun, and FtPF will be at its centre.

Authored by Claire Lipworth, Liam Naidoo, Olga Tocewicz, and Reuben Vandercruyssen.