Last year, the UK Government launched a five year anti-corruption strategy (due to run until 2022). For those unfamiliar with the strategy, it is comprised of 134 actions that the Government has pledged to complete by the end of the five years and covers a very wide range of commitments, from implementing the Criminal Finances Act 2017 to a more nebulous aim to "support other countries, bilaterally and at multilateral fora, to actively implement international Anti-corruption standards, especially the OECD Anti-Bribery Convention" and a diverse range of issues in between.
Yesterday (12 December) the year 1 update was published by Ben Wallace MP, the Minister of State for Security and Economic Crime and John Penrose MP, the Prime Minister's Anti-Corruption Champion. This summarises the progress made so far and sets out some of the priorities for 2019. Of particular interest:
- Ben Wallace MP reiterated his determination that more should be done to tackle "facilitators" (including lawyers) who enable criminals and money launderers to access the UK's property markets, businesses and sporting institutions;
- the Government explicitly recognises that "the UK cannot tackle corruption on its own and that creating a level playing field needs international cooperation and coordination". We can therefore expect to see a greater emphasis on cross-border co-operation in the future. The update specifically highlights that, as part of planning for the UK’s departure from the European Union, strengthening international cooperation and continuing to work with partners to bolster global efforts to tackle corruption will be a priority;
- there is a commitment to strengthening the evidence base for anti-corruption in the future by bringing together evidence in government, civil society and academic literature. We should hopefully benefit from an increasing number of publications focusing on this important and fast-changing area in the coming years; and
- the Government appears confident that it is meeting its commitments. There is not a single commitment that has been marked as being expected to miss (or at serious risk of missing) its deadline.
Ben Wallace MP understandably makes reference in the report to the recent glowing report by the Financial Action Task Force on the UK's anti-money laundering and terrorist financing arrangements. As we reflect back on 2018, the UK Government doubtless deserves much credit for how it has implemented its strategy and the effects that it has had. It has been very interesting to track the development of Unexplained Wealth Orders and the shifting tactics of the Serious Fraud Office, among many other things. However, this is only the end of year 1 and, as the Prime Minister's Anti-Corruption Champion himself warned in his foreword to this report…
We cannot afford complacency; the price of freedom is eternal vigilance, after all!