Insights and Analysis

The UK’s new anti-corruption strategy – linking growth to a tougher enforcement agenda

London
London

Key takeaways

Re-map corruption risk – In any businesses in high-growth sectors or with public-sector touchpoints, re-assess corruption risk.

Stress-test procurement and third-party controls – Interrogate bid processes, pricing decisions and subcontractor relationships on public contracts and other large projects, particularly where hospitality or personal relationships feature.

Refresh whistleblowing and investigation frameworks – Ensure speak-up mechanisms are trusted and investigation protocols are robust.

Prepare for AI-enabled investigations – Assume law enforcement will use analytics and AI tools, and ensure data quality, audit trails and retention policies are in good order.

Align integrity policies with evolving standards – Update policies on gifts, hospitality, political engagement and high-value donations to reflect tightening standards around ethics in public life.

There is a clear sense that the current UK Government wants to put criminal justice reform back on the agenda – and economic crime is a big part of that. Fraud and corruption plainly cost the UK economy huge sums, yet successive governments have struggled to get to grips with either. Chronic under-resourcing of key enforcement agencies such as the UK Serious Fraud Office, relative to their international counterparts, is clearly part of the problem.

Whether this will bear fruit will be seen in years to come but the UK government is talking an ambitious game. This week, the Justice Secretary has launched a new anti-corruption strategy that seeks to highlight corruption as both a national security threat and a drag on UK growth. Built around three pillars, the plan combines expanded law-enforcement capability, reforms to political and institutional integrity, and a renewed focus on international illicit finance.

While many of the initiatives build on or simply record existing economic crime reforms, the strategy is notable for the breadth of its ambitions and the way it links tackling corruption explicitly to the government’s growth agenda. For businesses relying on UK procurement and across other “growth sectors”, this points to a more demanding enforcement landscape at home, not just for overseas dealings. More importantly, this announcement signals a clearer mandate for agencies such as the SFO to tackle international corruption as well as domestic fraud, which in turn means UK corporates should prepare for a less benign enforcement environment.

Practical takeaways for organisations 

The strategy lands against a difficult backdrop. The UK remains at a record low in Transparency International’s Corruption Perceptions Index, and public confidence has been eroded by a succession of stories involving standards in political life, opaque political donations and high-value hospitality. At the same time, the government has left key posts – such as the anti-corruption champion – vacant for extended periods in recent years, fuelling a perception that commitment has lagged behind rhetoric.

The new strategy seeks to reset that picture. It adopts a broad definition of corruption as the “abuse of entrusted power for private benefit that usually breaches laws, regulations, standards of integrity and/or standards of professional behaviour”. That definition is designed to capture both classic bribery and the subtler forms of influence-peddling and conflicts of interest that have attracted public criticism.

Crucially, the document frames corruption as a direct threat to national security and economic performance. It cites public concern about foreign corrupt actors and acknowledges that corruption undermines fair competition, deters investment and distorts access to £400 billion in annual public procurement. For a government committed to high-growth sectors – from digital infrastructure and energy transition to housing and health – the message is that tackling corruption is an economic necessity, not just a matter of ethics or reputation.

Context – stitching together a fragmented landscape

The strategy does not emerge in a vacuum. Since 2010, the UK has introduced the Bribery Act, the three corporate “failure to prevent” criminal offences (bribery, facilitation of tax evasion and now fraud) and wide-ranging reforms in the Economic Crime and Corporate Transparency Act. Economic Crime Plans 1 and 2 have set out a broad programme to cut crime, protect national security and support legitimate growth, but delivery has been uneven and asset recovery remains below its 2021–22 peak.

Recent enforcement and survey work has already highlighted where corruption pressure points sit in the UK economy. Construction, utilities, transport and storage, and public-service outsourcing feature repeatedly in bribery and procurement cases. Demolition and infrastructure bribery prosecutions, NHS patient transport contracts skewed by improper payments, and local authority corruption probes – including the high-profile Liverpool City Council investigation – all illustrate how corruption can distort markets, divert public funds and undermine trust in regeneration and housing programmes.

Against that backdrop, the new strategy attempts to bring a disparate landscape together. It draws across legislation, enforcement initiatives and governance reforms and presents them in a single framework with clear pillars, lead agencies and timelines. Several strands – from public procurement reform and football governance through to AML supervision and whistleblowing – merit detailed consideration in their own right. The value of the document lies in the way it synthesises these moving parts and places them within a coherent anti-corruption narrative.

The central organising structure comprises three pillars: combating corrupt actors and their funds; tackling vulnerabilities in UK institutions and systems; and deepening international partnerships to build global resilience to corruption and illicit finance.

Analysis – three pillars, multiple levers

(i) Corrupt actors – scaling up domestic enforcement

The first pillar focuses on improving the system’s ability to identify, investigate and sanction corrupt actors, particularly in domestic settings. Key elements include:

  • Expansion of the Domestic Corruption Unit (DCU) – The City of London Police’s DCU, piloted with Home Office support, has already processed dozens of referrals across sectors and is now earmarked for expansion to handle national and regional corruption cases, with a specific focus on high-risk sectors and support for regional organised crime units and local forces. This directly speaks to risks in construction, infrastructure and local public services, where recent prosecutions have centred on bid-rigging, inflated contracts and a culture of informal favours and reciprocal benefits around major projects.
  • Tech-enabled investigations – The strategy commits to speeding up Serious Fraud Office investigations through more efficient processes and greater use of artificial intelligence and machine learning, and – more strikingly – to piloting an “artificial intelligence corruption investigation assistant” to support regional and local police. The concept is to allow investigators to interrogate years of suspicious activity reports and other intelligence datasets in minutes rather than months, potentially transforming how domestic bribery and money-laundering networks are mapped.
  • Funding and enablers – In parallel, the government promises to explore the funding landscape for economic crime enforcement at the next Spending Review, to strengthen international taskforces and to reinforce the role of units such as the Public Sector Fraud Authority’s enforcement team. The strategy, in the Justice Secretary’s words, also aims to “target professional enablers… who help dirty money flow”, placing those in law, accounting and financial services firmly within scope as part of a broader push against proceeds of corruption and facilitators.
  • AML supervision reform – The strategy also references a redesign of the UK’s fragmented anti-money laundering supervisory regime, including consolidation of the current 22 supervisors into a smaller number of more capable bodies. The objective is more consistent, risk-based oversight across sectors, better detection of corruption and a more level playing field that supports fair competition and investment.
  • Whistleblowing – The government will review routes for reporting corruption and consider financial incentives for reporting economic crime, going beyond measures already announced by HMRC. This has obvious implications for internal investigations and speak-up cultures in high-risk sectors, where modest payments or benefits can skew contract awards, operational decisions or allocation of scarce public resources.

(ii) Vulnerabilities – raising standards in public life and business

The second pillar turns to the systems and institutions that can either prevent or enable corruption.

Politically, it commits to a new Ethics and Integrity Commission to reinforce probity in public life, alongside strengthened rules on political donations, a tighter Business Appointments regime and enhanced oversight of local government through a new statutory Local Audit Office and mandatory codes of conduct.

The coverage under this pillar is strikingly broad. The strategy extends beyond Westminster to cultural organisations, high-value philanthropy and professional football, where it explicitly references supporting the new independent football regulator’s anti-corruption capabilities.

In some of these areas, the document is more directional than detailed, signalling topics – such as the boundaries between governance, commercial sponsorship and integrity risk in sport and culture – that will need further debate and more granular guidance. The broader challenge is one of delivery rather than breadth: the strategy risks reading as a smorgasbord of ideas unless it is backed by clear priorities and implementation plans. The focus on football, for example, reflects both ministerial interest and genuine concerns about illicit finance in the game, but it is not obvious that this is a priority lever for driving growth in the wider economy when set against more systemic reforms to core economic and institutional controls.

(iii) International partnerships – the kleptocracy challenge

The third pillar acknowledges the scale of the kleptocracy challenge and the reality that an estimated tens of billions are laundered through or via the UK each year. It commits to:

  • Hosting a UK Countering Illicit Finance Summit, designed to bring together governments, multilaterals, civil society and the private sector to address shared vulnerabilities;
  • Expanding the UK’s network of overseas illicit finance experts and scaling up its International Centre of Expertise on Illicit Finance; and
  • Embedding corruption and illicit finance as a priority across foreign and development policy.

This sits alongside continued use of targeted sanctions and asset-freezing powers, and a planned review of asset ownership vulnerabilities – intended to build on, and move beyond, existing reforms such as the register of overseas entities.

Set against the commitments made under Economic Crime Plan 2 – including the creation and subsequent expansion of the NCA’s Combating Kleptocracy Cell to target corrupt elites, their wealth and their enablers – there is relatively little in this pillar that is genuinely new. Much of the substance lies in consolidating and re‑badging existing measures, with further detail on resourcing and operational priorities still to come.

On paper, these measures target kleptocrats and their facilitators, while reinforcing the message that a “clean” jurisdiction is an attractive one for long-term investment. But without clearer commitments on funding, headcount and operational priorities for agencies such as the NCA, SFO and sanctions teams, there is a risk that this strand of the strategy adds to existing frameworks without materially changing the risk calculus for kleptocrats and their enablers.

Conclusion

This strategy is more than a restatement of existing economic crime plans. It reframes corruption as a structural threat to the UK’s growth ambitions and national security, while offering a detailed roadmap of commitments that span domestic enforcement, institutional integrity and international partnerships. The ambition is considerable: to move from haphazard enforcement and fragmented reforms to a more integrated, system-level response.

The real test will lie in delivery – particularly around resourcing, supervisory reform and the practical deployment of AI and data-analytics tools.

For corporates, the direction of travel is clear. Corruption and integrity risk, especially in domestic supply chains and public-facing services, will attract closer attention. Be prepared.

 

 

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

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