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Property Ownership

The problem

There is evidence that the UK property market is being used as a safe haven for corrupt money stolen from around the world, facilitated by laws which allow UK property to be owned by secret offshore companies.

Research from Transparency International UK has identified 176 properties worth £4.4 billion in the UK that have been bought with suspicious wealth.  £1.8 billion of this is from the UAE, £940 million (a fifth of our 4.4 figure) from Russia, £762 million from Ukraine, and £252 million from Kazakhstan. We have also identified properties we believe are owned by individuals in Azerbaijan , Nigeria, Libya, Pakistan and others.

The owners of these properties were only brought to light due to leaks and court documents, so this is likely the tip of the iceberg.

What happened at the Summit

In the Summit communique, leaders agreed to

“…take steps to eliminate loopholes that allow corruption to thrive through the misuse of these entities, and work, in accordance with national law, to ensure a level playing field between foreign and domestic companies in respect of requirements to provide beneficial ownership information.”

At the Anti-Corruption Summit, the UK committed to “establish a public register of company beneficial ownership information for foreign companies who already own or buy property in the UK, or who bid on central government contracts.” Then-Prime Minister David Cameron said that public registers of beneficial ownership information were the “gold standard”, and every country should ultimately aim to have them.

This commitment was also reiterated in the UK’s Open Government Partnership 2016 – 2018 National Action Plan.

What has happened since?

The UK opened a call for evidence on a beneficial ownership register to increase the transparency of overseas investment in property and public contracts in April 2017. The results of the consultation were published in March 2018.

In January 2018 the UK Government announced that the UK would not put forward primary legislation on introducing a public register, revealing the true owners of overseas companies buying UK property, until at least summer 2019. This means the Government has missed its original deadline of April 2018.

In line with the Government’s new timetable, the Department for Business, Energy and Industrial Strategy opened a consultation on a draft bill for the register in July 2018. The consultation closed in September 2018.

A joint parliamentary committee was appointed in February 2019 to scrutinise the draft bill prior to legislation being laid in the UK Parliament. It issued a report in May 2019 urging the Government to put the draft legislation to Parliament “as soon as possible” while also noting the “need for a Register of Overseas Entities has increased”. The Government responded to this report by reaffirming its commitment to legislate for a public register of the real owners of overseas companies that own or buy property in the UK.

TI-UK and others called on the Government to include this legislation in the December 2019 Queen’s Speech. It was included with a commitment to progress legislation.

HM Government reiterated its commitment to progress legislation for the register when Parliamentary time allows in UK Anti-Corruption Strategy Year 2 Update.

What’s next?

TI-UK is calling on the Government and MPs from all parties to continue to support this register and ensure its passage through Parliament at the earliest opportunity. Every day that passes without it is another day for stolen wealth to anonymously enter our property market.

Once implemented, this register should be maintained with the highest levels of integrity, to ensure it is accurate, effective and ultimately a sharp tool in ending the UK’s role as a safe haven for corrupt money.


Rachel Davies, Transparency International UK’s Head of Advocacy, tells you everything you need to know about Unexplained Wealth Orders. Why are they needed? How do they work? What was Transparency International’s role in bringing them to law? And what is next?


Read a brief guide to Unexplained Wealth Orders here: http://www.transparency.org.uk/unexplained-wealth-orders-a-brief-guide/

International Anti-Corruption Coordination Centre


Money laundering is a cross-border problem: the recovery of corrupt assets requires international coordination and information sharing.

The International Anti-Corruption Coordination Centre will work closely with international and national organisations to support countries that are suffering from corruption at the highest levels in their institutions.


At the Anti-Corruption Summit the UK committed to “work with others to establish an International Anti-Corruption Coordination Centre and will provide people and resources to support it”.

Thirteen other countries also committed to help with the establishment of the Centre. The communique says:

“We will strengthen cross-border cooperation and information sharing between law enforcement agencies, anti-corruption bodies, integrity offices of international organisations, prosecutors and, where appropriate, judges or judicial officers, and will support developing countries’ ability to investigate, prosecute and collaborate with international partners. We welcome the proposal to establish an International Anti-Corruption Coordination Centre by interested countries, which will work closely with relevant international and national organisations, including FIUs, and support countries that have suffered from grand corruption.”


The International Anti-Corruption Coordination Centre (IACCC) was established in July 2017. The UK’s National Crime Agency will host the IACCC until 2021.

According to the UK Anti-Corruption Strategy: Year 1 Update, as a result of the work being done with nine agencies from different jurisdictions in the IACCC, “11 investigations have been progressed and, in one case, supported the arrest of a senior overseas government official suspected of corruption”.

The UK Anti-Corruption Strategy Year 2 Update states that the IACCC has now “worked on 27 cases and supported a number of high-profile arrests involving politicians and public officials across the world.”

Global forum for asset recovery


When the proceeds of corruption are laundered through the UK, it presents a criminal, reputational, and national security risk, as well as a great injustice for the countries from which the funds have been stolen. The UK has an added responsibility arising from its unique status. London’s international reputation has often attracted money launderers who find it easier to mingle their dirty funds in a larger centre with substantial flows of legitimate money.

It is therefore imperative that the UK is able to prevent money laundering and detect, seize and recover those stolen assets that do enter the country. Due to ‘London’s status as a safe haven’ and the resultant high volume of foreign capital that comes in or through the UK, this country has an opportunity to take a pro-active leadership role in the detection and recovery of the proceeds of corruption laundered through this jurisdiction.


At the Anti-Corruption Summit, the UK promised to “work with others to establish a Global Forum for Asset Recovery and provide resources to support it”.


The inaugural meeting of the Forum was co-hosted by the UK and the USA in December 2017, with support from the joint World Bank and UNODC Stolen Asset Recovery Initiative (StAR) and focusing on assistance to Nigeria, Ukraine, Tunisia and Sri Lanka.

The Forum aimed to step up international efforts on asset recovery, and at the Summit 20 other countries committed to strengthen or reinforce legislation to ensure stolen assets can be recovered.

According to the UK Anti-Corruption Strategy: 1 Year Update, the principles for transparent and accountable asset return introduced at the Global Forum on Asset Recovery began to be incorporated in 2018 by the UN in its UN Convention Against Corruption experts’ working group.

The UK Anti-Corruption Strategy Year 2 Update states that HM Government “participated in the UNODC led international expert meeting on asset return in May which agreed a set of recommendations which reinforce the GFAR Principles on Asset Recovery.”

Excluding the corrupt


Companies and individuals known to be involved with corruption all too easily slip through the global net unnoticed. A corruption conviction in one country is no deterrent or prevention to acting corruptly elsewhere. Criminal sanctions are costly and risky to apply – but administrative sanctions are not.

The threat of exclusion from public contracts is a significant deterrent for companies: a contractor may be more likely to turn away from corruption, fraud, waste and abuse at the start of a bidding process, or decline to bid entirely if that contractor cannot safely and ethically bid for and perform the contract. A debarment sanction can bar a contractor that has already engaged in corruption during a contract from the procurement process for a specified period of time. Excluding corrupt bidders from public procurement is a significant aspect of clean contracting.


At the Anti-Corruption Summit the UK committed to “introduce a conviction check process to prevent corrupt bidders with relevant convictions from winning public contracts, and is committed to exploring ways of sharing such information across borders”.

In the UK’s Anti-Corruption Strategy 2017-2022 reiterates this commitment, stating that a new conviction check would “complement existing provisions in the Public Contracts Regulations 2015 requiring proof that bidders don’t have relevant convictions.”


In June 2018 the Crown Commercial Service trialled additional conviction checks for bidders, the results of which are currently being analysed according to the UK Anti-Corruption Strategy: 1 Year Update. The Government committed to publishing its preferred approach in 2019, but has not done so yet.

We encouraged the Cabinet Office to publish the results of the conviction check trial and state publicly what next steps will be, including lessons learned. We urge the Cabinet Office to conduct a proper public or stakeholder consultation on the guidance produced.

The UK Anti-Corruption Strategy Year 2 Update states:

“In 2018 we undertook a convictions check trial to see if any public contracts had been awarded to suppliers with convictions specified under Regulation 57 the Public Contracts Regulations 2015. The trial found that this had not happened but did identify a range of issues relating to obtaining convictions data outside the UK. We are considering how we can resolve access to international data for vetting purposes, as part of a wider programme of work on data sharing arrangements now the UK has left the EU.”



Innovation against corruption


Around the world, anti-corruption activists from all backgrounds are finding innovative technological methods to better expose and understand the many ways that corruption manifests. But all too often, anti-corruption initiatives are often poorly coordinated across sectors and lack the broad audience needed to support their growth.

The Anti-Corruption Innovation Hub will connect anti-corruption stakeholders from all sectors and backgrounds, endeavouring to find solutions to the challenge of corruption more effective and inclusive than existing approaches.


At the Anti-Corruption Summit the UK committed to launch an Anti-Corruption Innovation Hub “with other countries to support social innovators, technology experts, and data scientists to collaborate with law enforcement and civil society organisations on innovative approaches to anti-corruption”. The commitment was reiterated in the UK’s 2016-2018 Open Government Partnership National Action Plan.

The goal of the Hub is to:

“Champion the use of innovative ways to report, detect and investigate corruption; collaborate on identifying and supporting, emerging anti-corruption innovations; share good practice and promote the use of anti-corruption innovations, and use established conferences and multilateral stakeholder groups to highlight innovative anti-corruption initiatives and opportunities for collaboration.”

Several countries have expressed interest in participating in the Hub: Switzerland, Indonesia, Spain, Georgia, UAE, Australia, Norway and France. The Omidyar Network will provide support to the Hub. In addition Thomson Reuters, Vodafone and Transparency International UK have also expressed interest in working with the UK during the incubation phase.


In its Anti-Corruption Strategy: 1 Year Update, the Government stated that it had “reviewed the options to develop and promote innovative approaches to combat corruption and in spring 2018 consulted with a range of stakeholders to undertake mapping of the existing landscape. We judged that there was not a compelling case for establishing a standalone initiative in this space at that time.”

It went on to say, “More broadly we continue to promote innovative ways of working, as shown in the leadership centre at the Egmont Group which was conceived and driven by us. We will continue to promote new and innovative ways to tackle corruption, including through using new technology.”

Failing to prevent


An extension of the scope of the criminal offence of ‘failure to prevent’ to economic crimes such as money laundering or fraud could see company bosses prosecuted for failing to stop their staff from facilitating these crimes. Forcing company bosses and boards to take responsibility for the actions of their employees could significantly alter the corporate culture which too often fosters an enabling environment which allows corruption to persist.

If included in legislation the criminalisation of failing to prevent economic crimes, such as money laundering, would increase the threat of conviction and, as Jeremy Wright noted, might make companies more likely to proactively discourage such offences within the organisation in the first place. And if our gatekeeping institutions are increasingly galvanised to combat money laundering, corrupt elites around the world will have fewer opportunities and avenues for hiding their ill-gotten gains.  Money meant for schools and hospitals overseas would not end up in UK property or in anonymous companies registered in one of our Overseas Territories or Crown Dependencies. Companies can and must play a critical role in reducing the UK’s role as a safe haven for corrupt assets.


At the Anti-Corruption Summit the UK stated: “the UK is introducing a penalty for UK companies that fail to prevent their employees from facilitating tax evasion, including in other jurisdictions and is launching a consultation on extending this penalty to a wider range of economic crimes, such as money-laundering, fraud and false accounting”. The Ministry for Justice pledged to launch the consultation in summer 2016.

The University College London’s Centre for Ethics and Law also published a “Professional Services Leaders’ Statement of Support for the London Anti-Corruption Summit”, in which signatories stated their commitment to “play our part in efforts to prevent the proceeds of crime and corruption from entering legitimate capital and investment markets,” stating, “the importance of this challenge has never been clearer”.


The Government opened a call for evidence in January 2017, and said that a public consultation on the detail of a firm proposal for reform may be launched later in the year, depending on the results of the call for evidence. The call for evidence closed on 31 March 2017.

The UK Anti-Corruption Strategy: Year 1 Update states that the “Government’s response to the Call for Evidence on Corporate Liability for Economic Crime will be published in 2019. Work is continuing on analysis of the evidence and future options.”

Anti-corruption groups including Transparency International UK have expressed concern that this issue was not referenced in the Government’s Economic Crime Plan, published in July 2019.

The Government has not yet released the results of its call for evidence or launched a consultation on how to reform the UK’s outdated corporate liability regime. The UK Anti-Corruption Strategy Year 2 Update states that the Government’s response to the call for evidence is still being actively considered.

Twinning and transparency


At the Anti-Corruption Summit the UK promised to “launch practitioner partnerships on institutional integrity with Nigeria, Tanzania, Kenya, Afghanistan and Georgia to share expertise in the areas of audit, financial regulation, anti-corruption, and parliamentary budget oversight.”

At least 18 countries committed to support these international practitioner partnerships. The UK’s partnerships include:

  • The UK National Audit Office and Nigeria’s Office of the Auditor General working together to strengthen organisational governance and compliance with international audit standards.
  • The National Crime Agency partnering with relevant counterpart agencies in Tanzania, Kenya and Nigeria to strengthen their anti-corruption institutions.
  • The UK committing to an institutional integrity partnership with Kenya to support the development of its financial regulatory bodies through provision of UK expertise.
  • The Office of Budget Responsibility partnering with Georgia’s Parliamentary Budget Office to strengthen budget transparency, including through improving the quality of economic and fiscal reporting.
  • The UK stands ready to provide financial and technical assistance to the newly announced Afghanistan Anti-Corruption Justice Centre, including through work with UK institutions.

International partnerships announced at the Summit include:

  • Bulgaria and Afghanistan partnering to strengthen policing and anti-corruption units.
  • Norway strengthening the integrity outcomes in its partnership with Ghana and Tanzania under its landmark Oil for Development programme.
  • Through the International Bar Association’s Programme for Excellence, the Georgian Bar Association and the Law Society of Kenya partnering with participating associations from other countries to enhance effectiveness in global legal services, the justice system and the rule of law.
  •  The Commonwealth Secretariat will establish new Anti-Corruption Networks, first in the Pacific and then Asia to promote practitioner partnerships.
  • Australia’s integrity-focused partnership in the Pacific.


According to the UK Government website:

“Drawing on expert development economist Professor Sir Paul Collier’s “twinning” approach, the new ‘Institutional Integrity Network’ will see countries partnering up to share high professional standards and best practice in vital areas of government and in professional associations; including tax, budgets, natural resource management and accountancy.”

Partnerships for Development (formerly known as GREAT for Partnership) “will leverage the skills and expertise from a range of UK institutions and supply them initially to DFID partner countries, based on tailored demand. It will initially prioritise the Extractives, Financial Accountability and Anti-Corruption sectors.” The DfID website lists Kenya and Sierra Leone as the current beneficiary countries of this project, and claims that the project is nearly 60% complete.

According to the Partnerships for Development Annual Report published in March 2019, this project was slow to start due to delays in establishing a partnership platform. However, the Annual Review also states that there has been progress made in establishing up to 15 early partnerships between The British Geological Survey, The National Crime Agency, the Oxford Policy Fellowship and their developing country counterparts. The annual report and other status updates can be found on the Development Tracker website.

In June 2020 the Prime Minister announced that there would be a merger of the Department for International Development and the Foreign and Commonwealth Office. TI-UK encourages HM Government to continue to prioritise anti-corruption projects in the new Foreign, Commonwealth and Development Office.

Fiscal Transparency Evaluation


Fiscal transparency means the publication of information on how governments raise, spend, and manage public resources.

Without fiscal transparency it can be difficult for policymakers and the public to have a well-informed and balanced debate about the plans and outcomes of public policy, and there is no accountability in place for implementation. Fiscal transparency can help to highlight risks, enabling an earlier and smoother response to changing economic conditions and reducing the severity of any unexpected crises.

Fiscal transparency can also play a role in how financial markets view a country’s fiscal track record, providing a sense of fiscal credibility for that country. The loss of market confidence in governments with underestimated or hidden deficits in the wake of the recent global economic crisis underscored the importance of fiscal transparency to global financial and economic stability.


At the Anti-Corruption Summit the UK committed to undertake an IMF Fiscal Transparency Evaluation.

The evaluation was completed in November 2016, and is available here.


Whistleblower Protection


Corruption often goes unchallenged when people do not speak out about it. Witness accounts offer invaluable insights into corruption, and are powerful tools in the fight against it. From exposing multi-million dollar financial scams to dangerous medical practices, whistleblowers play a crucial role in saving resources and even lives.

But for some, blowing the whistle can carry high personal risk – particularly when there is little legal protection against dismissal, humiliation or even physical abuse. Controls on information, libel and defamation laws, and inadequate investigation of whistleblowers’ claims can all deter people from speaking out.

Whistleblowers are less likely to report workplace misconduct when their employers do not provide clear internal reporting channels. And in some settings, whistleblowing carries connotations of betrayal rather than being seen as a benefit to the public. Ultimately, societies, institutions and citizens lose out when there is no one willing to cry foul in the face of corruption.


The Summit communique included:

“We commit to make it easier for people to report suspected acts of corruption, to protect “whistleblowers” from discriminatory and retaliatory actions, and to promote action including by law enforcement agencies where credible information is provided. We support the role that the media, including investigative journalists, the business community, and civil society can play in complementing and reinforcing corruption reporting systems including effective monitoring and follow up.”

At the Anti-Corruption Summit the UK stated: “The UK is committed to providing effective protections for whistleblowers and made recent legislative changes to make the system more transparent. The UK will review the effectiveness of these changes”.


The UK Anti-Corruption Strategy 2017-2022 reiterates and clarifies the Government’s commitment to review the effectiveness of recent legislative changes in relation to whistleblowing, stating that it would: “Review in 2018/19 the recent changes to the whistleblowing framework, as introduced by the Enterprise and Regulatory Reform Act 2013.” According to the UK Anti-Corruption Strategy: Year 1 Update, consultations targeted at key industry professionals for the review of this framework were due to commence by the end of 2019.

The UK Anti-Corruption Strategy Year 2 Update states:

“In Year 1, we reported that in 2019 we would review the changes to the whistleblowing framework as introduced by the Enterprise and Regulatory Reform Act 2013, which would incorporate a review of the effectiveness of the Whistleblowing Guidance for Employers and Code of Practice. This was put on temporary hold in 2019 while we waited to see if the new EU Whistleblowing Directive needed to be introduced ahead of EU Exit. We are currently considering the timing and scope of the review.”