London Daily

Focus on the big picture.
Thursday, Nov 13, 2025

Building the Basis of a Transatlantic Response to Illicit Finance

Building the Basis of a Transatlantic Response to Illicit Finance

Despite years of technical efforts led by the Financial Action Task Force (FATF), the global anti-financial crime standard setter, the challenge of illicit finance endures.

In fact, its impact seems ever more insidious. Illicit finance is not merely the domain of criminals; it also supports kleptocrats and those engaged in grand corruption both for their own gain and, increasingly, for national advancement.

Central to this proliferation of dirty money is the role played by leading global financial centres as facilitators of, and safe harbours for, the money generated by kleptocrats and other malign actors. Chief among these havens are the US and the UK, where the realisation is dawning that illicit finance not only undermines the integrity of their economies, but it also threatens national security, notably being used to erode democracy.

Against this backdrop of increasing political support for greater action against illicit finance, RUSI’s Centre for Financial Crime and Security Studies held the first meeting of its Taskforce on a Transatlantic Response to Illicit Finance (TARIF) in late July. This meeting focused on how the US and the UK can shore up their domestic foundations, to plug the gaps that are all too often exploited by malign actors to facilitate flows of illicit finance around the globe.

TARIF also considered how the US and the UK – as key members of a range of relevant anti-financial crime and security communities – must collaborate to draw attention to the widespread failings of the contemporary global counter-illicit finance regime.

Fixing the Home Base


To ‘fix the home base’, TARIF members put forward the following starting points:

1. Central to advancing the response to illicit finance must be an acknowledgement by leading policymakers in the US and the UK that both countries have domestic vulnerabilities – with international consequences – that must be remedied. As the UK’s Economic Crime Plan (ECP) notes, ‘strong domestic action will underpin our efforts to combat economic crime and illicit financial flows at the international level’.

2. Supervision of ‘professional enablers’ – such as lawyers, accountants and real estate agents that provide the services that facilitate the moving and storing of funds – must be strengthened. Greater use should be made of technology to support supervision in both jurisdictions. In the UK, the CEO of the Financial Conduct Authority has talked of becoming a ‘data-led regulator’ – but what does this mean, and how does it become a reality? Smaller regulated entities must be subject to far more muscular supervision and enforcement to promote greater responsibility and cultural change. In both countries this will require a close look at the structure of the supervisory regime, ensuring that those responsible for supervision have no conflict of interest between their status as a membership organisation and supervisory responsibilities for those same members. In the US, this means supervising lawyers by making use of FinCEN’s (the US financial intelligence unit) existing authorities. This failure to regulate lawyers in the US, in particular, undermines the credibility of the US as a global leader in tackling illicit finance.

3. Furthermore, both countries must dedicate more attention to the supervision of real estate and private equity, asset classes favoured as havens for the proceeds of corruption. In the US, smart intelligence gathering tools, such as Geographic Targeting Orders, that require real estate title insurers to collect and report certain financial crime related information to FinCEN, should be placed on a permanent footing. In the UK, where a similar tool has been under consideration as part of the ECP, this should be introduced via reforms to the UK’s Proceeds of Crime Act to boost the paucity of financial crime intelligence currently gathered.

4. Vehicles that have proved to be loopholes in illicit finance defences, such as private schools and universities, as well as those that facilitate citizenship and residency schemes, should be subject to much greater scrutiny and potentially brought under anti-financial crime regulations. In this regard, the recent suggestion in the EU’s proposed new anti-money laundering (AML) regulation that companies offering investor residency schemes should also be covered by AML obligations is worthy of note.

5. Without strong enforcement, regulations and laws are meaningless. This shortcoming is particularly evident in the UK. Thus, a concerted effort must be made to greatly enhance the enforcement response to meet the current illicit finance threat. Where greater financial resources are needed, a new funding model may be required which could make use of the soon to be introduced Economic Crime Levy in the UK, but is likely to require more radical thinking – for example, increasing investment via the expanded use of seized criminal assets. Laws may also need adapting. For example, corporate criminal liability should be introduced to target enablers of illicit finance. Furthermore, to mitigate the fact that UK law enforcement currently faces situations in which it cannot risk the potential costs associated with pursuing high-value illicit finance cases, close consideration should be given to the introduction of cost-capping in civil cases.

An Honest Assessment


Alongside acknowledging their domestic vulnerabilities, the US and the UK should lead an honest international discussion about the state of the current anti-financial crime system, a system that – to a great extent – does not work effectively. Given the countries’ positions in the G7, G20, the FATF and the UN Security Council, and their combined role as cheerleaders for the global effort to strengthen financial integrity, such a discussion would carry significant weight and mitigate legitimate accusations of double standards.

In addition, the US and the UK should commit to reforming the global anti-financial crime system focusing on outcomes – for example, clear impact on profit-motivated crimes such as human trafficking – and not outputs. This should be based on a whole-of-system approach, with responsibility in the private sector distributed in terms of risk, covering all professions (such as lawyers and real estate agents, not just banks) that contribute to financial crime.

Cross-border information sharing must lie at the heart of any meaningful recasting of the response to illicit finance. While domestic information sharing to fight financial crime has improved considerably in the past five to seven years, international sharing remains nascent. As they have done domestically, the US and the UK should lead the way by developing a transatlantic public–private information sharing partnership. This must include more private–private sharing, which is tactical, real-time and moves towards a shared data format so that resources can be most effectively deployed. This must also include greater involvement from intelligence agencies, an essential step for tackling illicit finance linked to kleptocracy.

Information sharing should not be restricted to traditional private sector actors but must also embrace social media providers, and consideration should be given to whether these new facilitators of illicit finance should also be placed within the regulated perimeter, requiring them to play a central part in the response to illicit finance.

Time for a Radical Rethink


No other countries have invested so much in developing the global policy architecture for combatting illicit finance. Now it is time for the US and the UK to unequivocally commit to getting their houses in order and lead by example. They should provide no excuses to those that have historically been able to point to US and UK shortcomings to justify their own failings. Washington and London should collaborate to use their positions of influence in the financial crime community to lead a radical rethink in the international response to illicit finance.

Newsletter

Related Articles

0:00
0:00
Close
UK Upholds Firm Rules on Stablecoins to Shield Financial System
Brussels Divided as UK-EU Reset Stalls Over Budget Access
Prince Harry’s Remembrance Day Essay Expresses Strong Regret at Leaving Britain
UK Unemployment Hits 5% as Wage Growth Slows, Paving Way for Bank of England Rate Cut
Starmer Warns of Resurgent Racism in UK Politics as He Vows Child-Poverty Reforms
UK Grocery Inflation Slows to 4.7% as Supermarkets Launch Pre-Christmas Promotions
UK Government Backs the BBC amid Editing Scandal and Trump Threat of Legal Action
UK Assessment Mis-Estimated Fallout From Palestine Action Ban, Records Reveal
UK Halts Intelligence Sharing with US Amid Lethal Boat-Strike Concerns
King Charles III Leads Britain in Remembrance Sunday Tribute to War Dead
UK Retail Sales Growth Slows as Households Hold Back Ahead of Black Friday and Budget
Shell Pulls Out of Two UK Floating Wind Projects Amid Renewables Retreat
Viagogo Hit With £15 Million Tax Bill After HMRC Transfer-Pricing Inquiry
Jaguar Land Rover Cyberattack Pinches UK GDP, Bank of England Says
UK and Germany Sound Alarm on Russian-Satellite Threat to Critical Infrastructure
Former Prince Andrew Faces U.S. Congressional Request for Testimony Amid Brexit of Royal Title
BBC Director-General Tim Davie and News CEO Deborah Turness Resign Amid Editing Controversy
Tom Cruise Arrives by Helicopter at UK Scientology Fundraiser Amid Local Protests
Prince Andrew and Sarah Ferguson Face Fresh UK Probes Amid Royal Fallout
Mothers Link Teen Suicides to AI Chatbots in Growing Legal Battle
UK Government to Mirror Denmark’s Tough Immigration Framework in Major Policy Shift
UK Government Turns to Denmark-Style Immigration Reforms to Overhaul Border Rules
UK Chancellor Warned Against Cutting Insulation Funding as Budget Looms
UK Tenant Complaints Hit Record Levels as Rental Sector Faces Mounting Pressure
Apple to Pay Google About One Billion Dollars Annually for Gemini AI to Power Next-Generation Siri
UK Signals Major Shift as Nuclear Arms Race Looms
BBC’s « Celebrity Traitors UK » Finale Breaks Records with 11.1 Million Viewers
UK Spy Case Collapse Highlights Implications for UK-Taiwan Strategic Alignment
On the Road to the Oscars? Meghan Markle to Star in a New Film
A Vote Worth a Trillion Dollars: Elon Musk’s Defining Day
AI Researchers Claim Human-Level General Intelligence Is Already Here
President Donald Trump Challenges Nigeria with Military Options Over Alleged Christian Killings
Nancy Pelosi Finally Announces She Will Not Seek Re-Election, Signalling End of Long Congressional Career
UK Pre-Budget Blues and Rate-Cut Concerns Pile Pressure on Pound
ITV Warns of Nine-Per-Cent Drop in Q4 Advertising Revenue Amid Budget Uncertainty
National Grid Posts Slightly Stronger-Than-Expected Half-Year Profit as Regulatory Investments Drive Growth
UK Business Lobby Urges Reeves to Break Tax Pledges and Build Fiscal Headroom
UK to Launch Consultation on Stablecoin Regulation on November 10
UK Savers Rush to Withdraw Pension Cash Ahead of Budget Amid Tax-Change Fears
Massive Spoilers Emerge from MAFS UK 2025: Couple Swaps, Dating App Leaks and Reunion Bombshells
Kurdish-led Crime Network Operates UK Mini-Marts to Exploit Migrants and Sell Illicit Goods
UK Income Tax Hike Could Trigger £1 Billion Cut to Scotland’s Budget, Warns Finance Secretary
Tommy Robinson Acquitted of Terror-related Charge After Phone PIN Dispute
Boris Johnson Condemns Western Support for Hamas at Jewish Community Conference
HII Welcomes UK’s Westley Group to Strengthen AUKUS Submarine Supply Chain
Tragedy in Serbia: Coach Mladen Žižović Collapses During Match and Dies at 44
Diplo Says He Dated Katy Perry — and Justin Trudeau
Dick Cheney, Former U.S. Vice President, Dies at 84
Trump Calls Title Removal of Andrew ‘Tragic Situation’ Amid Royal Fallout
UK Bonds Rally as Chancellor Reeves Briefs Markets Ahead of November Budget
×