UK Economic Crime Act Two Years In: Enforcement, Gaps, and What Comes Next

The Economic Crime and Corporate Transparency Act has now been in force long enough to assess its real-world impact. The reforms to Companies House, the failure-to-prevent fraud offence, and the expanded identity verification requirements represented the UK's most ambitious anti-economic-crime reform package in decades.

Two years on, the picture is mixed. Transparency has improved in measurable ways. Enforcement capacity has expanded. But structural weaknesses in verification, cross-agency coordination, and the treatment of professional enablers continue to blunt the Act's full potential.

What the Act Has Delivered

Companies House now has the power to reject suspicious filings, require identity verification from directors and persons with significant control, and share information with law enforcement and regulators at a scale that was previously impossible. The removal of over 100,000 suspicious company records has disrupted long-standing laundering typologies that relied on UK corporate veneers.

The failure-to-prevent fraud offence has shifted board conversations. Large organisations have invested meaningfully in fraud risk assessments, policy frameworks, and monitoring capabilities to establish the 'reasonable procedures' defence. This investment is producing real reductions in internal fraud exposure, even where enforcement activity remains limited.

Where Gaps Remain

Identity verification at Companies House is improving but remains uneven, particularly for overseas directors and beneficial owners accessing UK structures through authorised corporate service providers. Criminals continue to exploit these intermediary pathways, often with only marginal changes to existing typologies.

Cross-agency coordination has improved but remains frustrating in practice. Intelligence sharing between regulators, law enforcement, and international counterparts is still subject to friction that determined criminals routinely exploit. The Act's information-sharing provisions are legally strong but operationally constrained.

Professional Enablers Under Pressure

The Act introduced new tools for the SRA, FCA and other professional regulators to act against enablers. Enforcement has ticked upward, with high-profile cases involving law firms, accountancy practices, and corporate service providers. However, the capacity of professional regulators to pursue complex cases end-to-end remains limited relative to the scale of the problem.

Compliance teams in regulated professional firms are increasingly expected to maintain risk assessment standards closer to those of banks. The reputational cost of being named in an enabler enforcement action is now severe enough to drive behaviour change in ways that fines alone had not achieved.

What the Next Wave of Reform Might Look Like

Policy discussion has shifted toward expanding corporate criminal liability frameworks, accelerating the digital identity verification agenda, and strengthening the powers of the National Crime Agency. The failure-to-prevent fraud offence may be extended to additional predicate crimes, following the model already in place for bribery and tax evasion facilitation.

The UK government has signalled interest in a more coherent approach to sanctions evasion, trade-based money laundering and proceeds of crime recovery. Whether legislative capacity exists to deliver these reforms in the current parliamentary cycle remains an open question.

Implications for Regulated Firms

Firms should treat the Act's maturation not as a completed compliance exercise but as a baseline upon which further expectations will be built. Risk assessments should be refreshed annually at minimum and expanded to reflect the evolving typology landscape. Board reporting on economic crime should include leading indicators, not only incident counts.

Engagement with Companies House, the NCA and relevant regulators is increasingly viewed as a mark of mature governance rather than an administrative burden. The firms that invest in these relationships tend to navigate enforcement cycles more successfully than those that do not.

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