The UK government has recently published its long-awaited Anti-Corruption Strategy. The strategy sets out a broad programme of 123 commitments aimed at strengthening integrity across public services, professional sectors and financial systems. It represents a renewed attempt to address long-standing vulnerabilities in the UK’s governance framework and to reinforce the country’s international reputation as a leader in transparency and economic crime prevention.

The strategy covers a wide range of policy areas, including public procurement, beneficial ownership transparency, whistleblowing, professional supervision, digital and crypto-asset risk, and standards in central and local government. It also sets out plans for deeper international cooperation, with the UK committing to host a major illicit finance summit in 2026 and to expand intelligence sharing with global partners.

ICAEW welcomes the publication of the strategy and the scale of its commitments, which demonstrate a clear government intention to strengthen the UK’s ability to prevent and respond to corruption. The commitment to improving the integrity of both the public and private sectors is a positive development, and the strategy’s emphasis on cross-government coordination reflects a recognition that corruption is a complex issue that cannot be tackled through isolated interventions. We especially welcome the strategy’s focus on the importance of collaboration with the private sector and look forward to supporting the government on the delivery of its objectives. Nonetheless, there are several areas where greater clarity, integration or resourcing will be essential if the strategy is to meet its objectives.

Lack of integration

The strategy states that whilst it is focused on corruption it complements and builds on Economic Crime Plan 2, as well as noting that the government’s new fraud strategy and anti-money laundering and asset recovery strategy are still to be published. 

One notable concern is the lack of integration across the government’s activity on economic crime, particularly the limited integration of fraud within the strategy. Given that fraud remains the most common crime affecting UK citizens and businesses, and given the significant crossover between fraudulent behaviour, illicit finance and corrupt practices, a more deeply integrated approach would deliver stronger outcomes. Many of the systems, controls and reporting frameworks used to prevent corruption are the same mechanisms required to detect and prevent fraud. Treating the different areas of economic crime as operationally distinct risks creating gaps, duplications or inefficiencies that could undermine the effectiveness of enforcement and regulatory oversight. 

Definition of professional enablers

A second area requiring greater attention is the strategy’s definition and treatment of ‘professional enablers’. The strategy identifies regulated professionals as potential facilitators of corrupt activity, particularly in fields such as legal services, company formation, financial advisory work and trust and corporate administration. While it is necessary for the government to address the role that certain services can play in enabling illicit wealth to move through the financial system, ICAEW is concerned that the definition used in the strategy is not sufficiently nuanced and does not adequately distinguish between the very small minority who knowingly facilitate corruption and those who form a central part of the UK’s defences against economic crime.

Chartered accountants fulfil essential roles in detecting, preventing and reporting corruption, fraud and financial misconduct. Through audit, assurance, reporting, compliance advisory work and the stewardship of ethical standards, the profession contributes significantly to the integrity of financial information and the safeguarding of markets, public services and corporate governance. The current definition risks conflating a very small number of bad actors with the wider professional community and does not fully reflect the collaborative role that accountants play in supporting enforcement agencies and regulators. ICAEW considers it important that any definition of enablers clearly differentiates between deliberate facilitation and the legitimate, often critical, functions performed by regulated professionals who act to uphold integrity and transparency.

Resourcing and delivery capability

The third potential issue is the question of resources and delivery capability. Many of the strategy’s commitments rely on increased investigative capacity, expanded supervision, enhanced data analysis and more sophisticated digital tools. There is a strong focus on bringing corrupt actors to justice, but also an acknowledgement that there is a rising backlog in the courts, leading to significant delays and cases collapsing. Enforcement bodies and regulators are expected to undertake complex work in areas such as beneficial ownership verification, high-risk sector oversight, crypto-asset analysis, cross-border information exchange and the investigation of corruption networks. These responsibilities fall to agencies and departments that have long faced pressure in terms of staffing, funding and technological capability.

ICAEW is concerned that the existing level of resourcing may be insufficient to deliver the scale of the strategy’s ambitions. If commitments are to be met in practice rather than remaining aspirational, the government will need to provide sustained investment over the full implementation period. This includes not only financial resources but also the development of specialist skills, updated regulatory systems, improved case-handling capacity, ongoing support for digital transformation and, critically, significant investment in the justice system so that corrupt actors can be brought to justice. Without a realistic assessment of what is required, there is a risk that the strategy could place significant demands on institutions without equipping them adequately to carry out their responsibilities. For this reason, ICAEW believes that resource levels will need to increase as the strategy is implemented.

Looking ahead

Despite some concerns and uncertainties around future implementation, the publication of the strategy is a positive and important step in strengthening the UK’s resilience against corruption and illicit finance. It sets out a coherent, cross-government framework and identifies clear priorities for reform in areas where vulnerabilities have long been recognised. The focus on improving transparency, enhancing ethical standards, and reinforcing the integrity of professional services aligns with many of ICAEW’s longstanding policy positions.

For the strategy to achieve its intended impact, however, it will be essential to refine certain definitions and ensure that delivery bodies are equipped with the resources necessary to carry out their work effectively. ICAEW looks forward to engaging with government throughout the implementation process to support the development of a system that protects the public interest, strengthens trust in institutions and upholds the integrity of the UK’s economic and financial environment.