This United Kingdom Dashboard is in the 2023 format from Financial Crime News, which includes, for example approx 150 data points which have been collected and are represented in the 2 page Financial Crime Dashboard. It informs as to the nature of the financial crime threats, the main vulnerabilities, how resilient the UK is to these threats and its overall level of response, with more KRI and KPI data than ever before, all from publicly available sources albeit assessed and analysed for accuracy and relevance by FCN. For a copy of the 2023 UK Financial Crime Dashboard see HERE: FCN U.K. Dashboard 14:03:23 Pbd
FCN Country Risk Scores & Ratings: The UK is rated 35/100 Moderate – High Threats, 73/100, Very High Response & 54/100 Moderate overall Risk, using the FCN Methodology. This is the overall equal 25th best risk score of 39 FATF Member Countries (including UAE and Indonesia), largely due to the very significant threat level that the UK is subject to, which is somewhat but not sufficiently mitigated by one of the best overall response ratings.
“The UK authorities have a robust understanding of its money laundering (ML) and terror financing (TF) risks.” The UK’s position as “the largest financial services provider in the world,” made it exceptionally vulnerable to money laundering, and “as a result of the exceptionally large volume of funds that flows through its financial sector, the country also faces a significant risk that some of these funds have links to crime and terrorism.” The UK “has implemented an AML/CFT system that is effective in many respects”…however, “major improvements are needed to strengthen supervision & implementation of preventive measures, and ensure that financial intelligence is fully exploited.” – FATF 2018 MER.
The UK’s 1st Economic Crime Plan 2019-2022 is likely to be succeeded by a 2nd which will build on the recently enacted Economic Crime (Transparency and Enforcement) Act, with the passing of the Economic Crime and Corporate Transparency (ECCT) Bill and include a new Anti Fraud Strategy & Action Plan. The 2nd Economic Crime Plan is due imminently and even perhaps to be published by the end of March, 2023.
Financial Crime Threats
The annual social & economic cost of serious & organised crime was estimated to be £37 billion, which included £20 billion from drugs crimes, including drug-related deaths and hospital treatments, and £8 billion from economic crime (2015–16) – Sources: UK Government.
The main domestic threats are from fraud and cybercrime, drug trafficking, organised crime, acquisitive crime, tax offences including smuggling, human trafficking, organised immigration crime, & illegal wildlife trafficking. International threats are from corruption, fraud and TBML.
In addition sanctions and sanctions circumvention and or non compliance is likely to be a significant threat which postdates the NRA 2020. Terrorism has remains an important threat in particular radical islamic related terrorism, with the current threat level at “Substantial” (5 levels that range from “low” “moderate” substantial” “severe” and “critical”.
Sectoral Vulnerabilities & Risks: A number of sectors were considered vulnerable to money laundering. “High” ratings in the NRA 2020 were given for retail banking, wholesale banking, wealth management and private banking. “High” ratings were also given to MSBs, lawyers, accountants, entities (companies & partnerships), trust & company service providers, properties, cash & the art market. “Medium” ratings were given to: payment services and e money, real estate agents, letting agents and high value goods dealers.
The UK is Compliant 23/40 Recommendations, Largely Compliant in 15/40 Recommendations, Partially Compliant in 2/40 Recommendations and Non Compliant in 0/40 Recommendations. Recommendations for Partially Compliant Ratings are R13 (Correspondent Banking) & R29 (FIU).
On Effectiveness, the UK received 4/11 Highly Effective Ratings, 4/11 Substantially Effective Ratings & 3/11 Moderately Effective Ratings. The ME ratings were for IO3 (Supervision), IO4 Preventative Measures & IO6 (Financial Intelligence).
Whilst there is little doubt the UK has one of the strongest responses in terms of ratings from FATF and from other rating agencies, such as Transparency International, Basel AML Index etc, there are important questions raised about the overall effectiveness of the UK approach, in particular the effectiveness of the UK FIU, and, as with most other countries, in particular as far as securing convictions for third party professional money laundering and asset recoveries. Fraud is also a major growing issue, which awaits a comprehensive response.
Key Outcomes Performance Data:
FIU Staffing: 118 in 2020.
SARs Reported: 573K in 2020.
SAR Conversion Rate: 6% in 2018.
PPP: Yes JIMLIT since 2015 (& Others).
NRA: Yes latest AML in 2020 and PF in 2021.
ML Convictions: 1,505 in 2015.
Human Trafficking Convictions: 332 in 2021.
Foreign Bribery Convictions: 13 between 2018-2021.
Assets Seized: US$1.2B (1.4% of estimated financial crime proceeds @ 2.7 % of GDP – POC/ML) in 2021/22.
Assets Confiscated: US$409M (0.48% of estimated financial crime proceeds @ 2.7% of GDP – POC/ML) in 2021/22.
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