


































Economics, Law and Policy 
ISSN 2576-2060 (Print) ISSN 2576-2052 (Online) 

Vol. 7, No. 3, 2024 

www.scholink.org/ojs/index.php/elp 

43 
 

Original Paper 

Effectiveness of the UK AML System and Strategies for 

Improvement 

Chenyang Liu
1
 

1
 Newcastle University, UK 

 

Received: October 10, 2024    Accepted: October 18, 2024    Online Published: October 20, 2024 

doi:10.22158/elp.v7n3p43              URL: http://dx.doi.org/10.22158/elp.v7n3p43 

 

Abstract 

As the cost of anti-money laundering (AML) compliance in the UK continues to rise, financial crime 

rates have not fallen. This study assesses the effectiveness of the UK’s anti-money laundering (AML) 

system and proposes strategies for improvement. The research examines the current legal framework, 

including the Proceeds of Crime Act (POCA) and the Money Laundering Regulations 2017 (MLR2017), 

assessing their role in preventing and combating financial crime. Analyzing case studies and statistical 

data, the findings suggest that while the UK AML system has been effective in identifying and deterring 

money laundering, significant challenges remain. Insufficient sharing of information between agencies, 

uneven allocation of resources, and inconsistent regulatory enforcement hinder overall effectiveness. 

To address these shortcomings, the study makes several strategic recommendations: strengthening 

inter-agency cooperation, leveraging advanced technological solutions for data analysis and reporting, 

improving training and awareness programmes for financial institutions, and improving the legal 

framework to adapt to emerging threats. Implementing these recommendations could strengthen the 

UK’s anti-money laundering (AML) efforts, making them more robust and responsive to the evolving 

financial crime landscape. Ultimately, this study aims to contribute to the current debate on the 

effectiveness of AML and to make recommendations for improving the AML system’s response to the 

complexities of money laundering in order to strengthen the UK’s position in the global fight against 

money laundering. 

 

1. Introduction 

The financial burden of anti-money laundering (AML) compliance in the UK has been steadily 

increasing for over a decade. Instead of decreasing, financial crime rates have continued to rise despite 

significant investment. This situation prompts a critical investigation into the effectiveness of current 

AML measures at an operational level. A review of whether the existing AML framework is 



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fundamentally flawed and no longer able to effectively address the challenges it was designed to 

address is therefore necessary. Such a reassessment could provide a path for identifying the necessary 

reforms or alternatives to improve the effectiveness of anti-money-laundering efforts in the fight 

against financial crime. 

Money laundering is itself a crime (Note 1). Money laundering is an illegal activity carried out by 

criminals which occurs outside of the normal range of economic and financial statistics (Note 2). 

According to the definition of International Compliance Association (ICA), money laundering is the 

generic term used to describe the process by which criminals disguise the original ownership and 

control of the proceeds of criminal conduct by making such proceeds appear to have derived from a 

legitimate source (Note 3). However, with the rapid advancement of modern technology, this 

illegitimate money can be transferred to any part of the world through electronic transfers. It‟s 

extremely harmful to the financial system, not only leading to market distortions that prevent normal 

economic activities from taking place in a fair market environment, but also creating additional 

compliance costs and reputation risks for financial institutions. 

The cost of anti-money laundering compliance in the UK has been rising disproportionately for more 

than a decade, but financial crime rates have continued to rise. According to data released by the HM 

government, the number of people sentenced for money laundering offences is on a slow upward trend 

from 2018 to 2022 (data as of 2022) (Note 4). A serious concern arises in the current situation, which is 

is the present AML system broken and no longer fit for purpose? As Whitehouse concludes that „The 

cost of compliance is increasing rapidly but it would be a brave person who steps up to say that it is too 

high a price to pay for countering terrorism and serious crime‟ (Note 5). Indeed, the AML system has a 

number of problems and challenges, but it has not been broken and still carries out a key role in 

deterring and detecting money laundering. 

This essay will initially consider the challenges for the AML system, secondly it will critically assess 

the effectiveness of the AML system in combating financial crime and property recovery and finally 

make some recommendations on the current system. 

 

2. Challenges to AML Compliance 

The cornerstone of the United Kingdom‟s anti-money laundering legislation is the Proceeds of Crime 

Act (POCA), complemented by foundational regulations such as the Money Laundering Regulations 

2017 (MLR2017). The Financial Conduct Authority (FCA) enforces these provisions in strict 

accordance with the established legal framework. The regulatory environment has been further 

strengthened with the introduction of Unexplained Wealth Orders (UWOs) under the Criminal 

Finances Act 2017 (CFA 2017). Unexplained Wealth Orders (UWOs) have proved to be an important 

tool in the investigation of individuals whose assets are disproportionate to their known legitimate 

income, and are particularly important in cases involving international corruption and money 

laundering. In addition, the Economic Crime (Transparency and Enforcement) Act 2022 reinforces 



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AML as a framework by increasing transparency requirements for foreign companies investing in UK 

real estate, thereby strengthening the government‟s ability to monitor money laundering and facilitate 

asset recovery. This includes mandatory registration and disclosure of beneficial ownership information, 

which enables authorities to more effectively trace the source of funds used in real estate transactions. 

Enhanced access to data allows for improved risk assessment, improves investigative capacity and 

ultimately helps to identify and recover illicit assets. While the Money Laundering Reporting Officer 

(MLRO) plays a crucial role in monitoring compliance within financial institutions—such as banks, 

insurance companies, investment firms, casinos, and high-value dealers—responsibility for oversight is 

not limited to the MLRO alone. Other designated professionals, such as Money Laundering 

Compliance Officers (MLCOs), also contribute to ensuring adherence to anti-money laundering 

regulations. These professionals play an important role in complying with anti-money laundering 

regulations, employing advanced technology for continuous monitoring, and ensuring that all 

employees are trained in the latest anti-money laundering practices to combat evolving criminal tactics. 

In addition, they are responsible for the critical task of generating and filing Suspicious Activity 

Reports (SARs) with the National Crime Agency (NCA) whenever signs of potential money laundering 

are detected. Despite the fact that the UK‟s anti-money laundering system is fairly well developed, it 

still suffers from a certain range of challenges. 

2.1 Excessive Consumption of Labour Costs 

With the digitalization of finance, the internationalization of the modern financial system requires the 

implementation of anti-money laundering (AML) compliance measures globally, which increases the 

workload of Customer Due Diligence (CDD). The requirement for CDD to carry out detailed 

background checks on new versus existing customers requires financial institutions to have a certain 

level of competence in terms of financial and human resources. To comply with CDD regulations 

effectively, financial institutions must invest in robust systems and processes that enable 

comprehensive customer assessments. This includes implementing advanced technology solutions for 

data analytics, transaction monitoring, and risk profiling, which require significant financial resources. 

Furthermore, institutions need to ensure they have adequately trained staff capable of interpreting 

complex regulatory requirements and analyzing customer data accurately.  

In addition, human resources are critical in establishing a culture of compliance within the organization. 

This involves not only hiring specialized personnel, such as compliance officers and risk analysts, but 

also providing ongoing training and professional development to enhance the skills of existing 

employees. Such training programs should focus on the latest trends in financial crime, evolving 

regulatory expectations, and best practices for conducting due diligence. 

Moreover, the CDD process demands that financial institutions maintain detailed records of customer 

information and transaction histories. This necessitates a well-organized infrastructure for data 

management, ensuring that staff can efficiently access and analyze relevant information. Even many 

organizations have had to expand their compliance departments to cope with the workload created by 



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more comprehensive AML obligations. But this constant training is also a recurring cost for 

organizations.  

The National Crime Agency (NCA) estimates the cost of money laundering to the UK economy to be 

in the hundreds of billion pounds a year (Note 6). In the True Cost of Compliance 2023 report 

published by LexisNexis, it was revealed that Customer due diligence (CDD) processes remain by far 

the largest single operational cost, representing two-thirds (67 per cent) of total financial crime 

compliance costs in 2022, an increase from 53 per cent in 2020 (Note 7). The largest share of CDD 

spend is represented by Know Your Customer (KYC) onboarding checks, accounting for just a third of 

overall CDD costs. Identity verification costs are also rising rapidly, partly as a result of increasing 

customer volumes and more consumers demanding a fast, seamless onboarding experience, and partly 

as firms work to improve their digital and remote onboarding solutions. The report indicates that 60 per 

cent of AML costs are spent primarily on personnel and training, with only 30 per cent invested in 

technology. And compliance costs will continue to increase over the next three years, with staffing 

costs growing slightly faster than technology costs. However, observing the matter through the 

economics lens again, these compliance costs have to be somehow recovered (Note 8).  

Therefore, it is not difficult to conclude that these costs will be ultimately passed to end user, the 

customer. For example, the transaction fees charged by banks to asset managers and the costs of 

analysts‟ research reports are ultimately passed on to the clients of asset managers. Hence, higher costs 

may discourage customers from taking full advantage of banking services, thereby reducing the overall 

liquidity of the financial system. And in order to avoid the higher costs associated with formal financial 

channels, individuals and businesses may choose to underreport or not disclose their income or 

transactions, leading to increased shadow economy activity. It can further contribute to an increase in 

the rate of financial crime. 

2.2 The Increasing Levels of Crime 

While the cost of AML compliance in the UK has continued to rise in recent years and into the future, 

yet the level of financial crime has not fallen. According to an assessment by the UK‟s National Crime 

Agency (NCA), the UK is likely to generate more than £10 billion in criminal cash each year (Note 9). 

Traditional fraud, while still prevalent, is generally on the decline (Note 10). However, as digitization 

and networking deepen, there has been a marked increase in forms of crime such as 

cryptocurrency-related crime, cyber fraud and identity theft. For example, the anonymity and 

cross-border nature of cryptocurrencies makes them a new tool for money laundering. In statistics 

released by the UK government in 2023, it was revealed that the UK‟s Financial Intelligence Unit (FIU) 

received 901,255 Suspicious Activity Reports (SARs) between 2021 and 2022, which represents a 21 

per cent year-on-year increase compared to previous years (Note 11). One of the reasons for the 

increase is the growing fintech and cryptocurrency sector, which has led to the emergence of new types 

of criminal practices.  



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In the UK, for example, some bank account holders have become money laundering „mules‟ through 

the misuse of digital technology and social media. According to records from 2017, 8,500 money mule 

accounts owned by young people were identified by a number of UK banks and there has been a 35 per 

cent increase in the involvement of the 14-21 age group in this type of money laundering (Note 12). 

This is because young people often have no criminal history of financial crime, so they are more likely 

to be trusted by banks unless other suspicious transactions are analyzed. Furthermore, according to the 

data released by Cipher Trace in 2019, 65% of the 120 most popular cryptocurrency transactions have 

poor and weak KYC requirements (Note 13). Despite the enforcement of strict customer due diligence 

(KYC) in the UK and compliance with the Fifth Anti-Money Laundering Directive, which strictly 

regulates cryptocurrency activity, and the proposed rules for cryptocurrency regulation by the FCA, 

technology continues to evolve, and cryptocurrency money laundering methods are becoming more 

complex and undetectable. 

Thus, despite the significant increase in AML compliance costs, the persistence of high crime rates 

reflects the fact that existing measures may not be fully effective in practice. 

 

3. Assess the Effectiveness of AML System 

An initial question that should be considered before analyzing the effectiveness of AML systems is 

what is effective? Effective means that the outcome is expected to fulfil the original purpose (Note 14). 

So what is the purpose of anti-money laundering? The objective of anti-money laundering is clearly to 

reduce money laundering and the incidence of money laundering offences. It is also to combat the flow 

of funds for the financing of terrorism and to protect the integrity of financial markets. However, as 

noted earlier, the cost of anti-money laundering compliance continues to rise, but the rate of financial 

crime has not fallen. As a result, it has been argued that the anti-money-laundering system has been 

undermined. In the perspective of this essay, however, the AML system has not been broken. How 

should damage be defined? Is it the elimination of all financial crimes that can be said not to have been 

damaged? Obviously this is impossible. The purpose of anti-money laundering is to combat money 

laundering, but the money laundering to 0 crime can not exist. Although the AML system has not 

prevented an increase in the rate of financial crime, which it has to a certain extent, it has also 

combated financial crime, and therefore has not been broken.  

For instance, the UK introduced Unexplained Wealth Order (UWO)—a regime designed to forfeit the 

proceeds of crime using civil, rather than criminal power from 2017. The UWOs are seen as a solution 

to both the problems of organized crime and the high levels of corruption that arise from a reign of 

thievery. When a property is issued with an Unexplained Wealth Order (UWO), the owners are 

obligated to provide an explanation regarding the origins of wealth used for its purchase. Failure to 

comply with this requirement establishes a legal presumption that the property has been obtained 

through criminal proceeds, thereby enabling subsequent civil recovery proceedings for confiscation 

under the provisions of the Proceeds of Crime Act (POCA) (Note 15).  



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In 2019 the NCA froze 3 properties as it suspected that they were the proceeds of crime transferred to 

the three properties by Rakhat Aliyev (RA), a Kazakhstani national, and asked the respondents to 

explain the source of the wealth. However the High Court overturned all three UWOs, finding the 

assumptions expressed by the NCA that RA was the source of the funds to be unreliable and finding the 

underlying assumptions and reasoning of the NCA to be unreliable and flawed (Note 16). 2020 The 

NCA appeal was refused. This case is one of four known UWO cases to have failed completely. In 

particular, when applying for the UWO, NCA claimed that some of Hajiyeva‟s assets were of dubious 

origin, and therefore asked her to explain how she could afford them. However, the key issues in the 

case centred on whether NCA had used the UWO tool correctly and whether its judgement on 

Hajiyeva‟s property complied with the law. The court found the NCA procedurally improper in some 

respects, particularly in relation to the question of beneficial ownership of the property and the 

associated legality, for which it did not provide sufficient evidence. This was largely due to disputes 

over the legality of the source of the RA property, the complexity of ownership of RA assets, and 

issues of procedural justice. NCA had failed to adequately prove a reasonable suspicion of illegality 

with respect to certain of Hajiyeva‟s assets in the case. Hajiyeva‟s team of lawyers successfully 

challenged NCA‟s assertion that the property had not been acquired by illegal means, and that the 

UWO should therefore not have been applied. The court was sceptical of NCA‟s chain of evidence and 

reasoning, finding them insufficient to support the decision to freeze the property.  

Another key factor was the complex ownership structure involved in some of the property owned by 

Hajiyeva. Some of the assets were not owned by her directly, but through trusts or corporate holdings. 

This made it difficult for the court to determine whether the property should be attributed to Hajiyeva, 

finding that NCA had failed to accurately identify who the true owner of the assets was. The court also 

challenged NCA‟s procedures in applying for the UWO, finding that some of the procedural 

deficiencies may have violated Hajiyeva‟s legitimate legal rights. For example, in some instances, 

NCA may have failed to give Hajiyeva an adequate opportunity to respond to the allegations or may 

have failed to follow certain required legal procedures, resulting in the decision to freeze some of the 

assets being deemed unlawful. The use of the UWO in the RA case thus reveals the potential of the tool 

for tracing unexplained wealth, but also exposes its limitations at the legal and procedural levels. While 

the UWO offers the UK government a new way to effectively combat money laundering and corruption, 

its successful implementation depends on the specific complexity of the case, the structure of the asset 

holdings, and the ability of law enforcement agencies to adhere strictly to legal procedures. The RA 

case demonstrates that, while the UWO is a potent tool, there are a number of legal and practical 

hurdles that still need to be overcome in practice.  

It has been argued that UWO has failed as a specific tool in the AML regime (Note 17). However in the 

Asset Recovery Statistical Bulletin published by the UK Government 2023 (for the financial year 

ending March 2018 to March 2023), it is shown that in the financial year 2022-2023, £62.9 million was 

recovered under civil recovery orders, a growth rate of 544 per cent from £9.8 million in the previous 



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financial year (Note 18). Thus, rather than looking at a handful of failures and judging the 

ineffectiveness of AML tools, we can start with the data to see if the AML system is actually fulfilling 

the original purpose of anti-money laundering. Which means that if the anti-money laundering system 

combats money laundering and achieves certain results, then it is effective. 

 

4. How to Improve AML System? 

4.1 Focus on Regtech 

As mentioned previously, AML compliance costs account for only 30% of technology investment, with 

the majority of costs spent on labour and compliance training costs, demonstrating the problem of 

under-investment in technology. Consequently, the UK should invest more in regtech, using artificial 

intelligence and big data analytics to automate the process of detecting and reporting suspicious 

transactions. Regtech is an abbreviation for regulation and technology, meaning it is a reliance on 

technology for regulatory and compliance purposes (Note 19). Regtech can better detect criminals by 

automating the identification of suspicious transactions. Meanwhile regtech will also simplify the KYC 

and CDD process as it provides tools that are aligned with the digital transformation of the financial 

services industry. And regtech will enable regulators to respond adequately to emerging financial risks 

by providing more accurate and timely data reporting. Between 2013 and 2019, Westpac, the second 

largest bank in Australia, was accused of 23 million breaches of the worst money laundering and 

terrorist financing laws in the country‟s history (Note 20). According to the investigation, most of the 

breaches were linked to the bank‟s failure to report international transfers in a timely manner to the 

Australian Transaction Reporting and Analysis Centre (AUSTRAC), which claimed that 12 individuals 

used the system of Westpac to conduct nearly 3,000 transactions that may have been related to child 

exploitation, as well as child sex shows. Moreover, the group included a customer who had been 

previously convicted of child exploitation offences. Yet Westpac did not implement an automated 

detection programme, but instead monitored risks through other channels. As a result, Westpac failed 

to detect transactions on its customer‟s account related to child exploitation. This case illustrates the 

potential for the use of regtech, in other words, the increased use of regtech will reduce the risk of 

human error to a certain extent. 

In the UK, the FCA has set up regulatory sandboxes with the aim of providing a safe testing 

environment for new financial services and technologies that do not pose a potential risk to the 

financial system as a whole or to the consumer community until they are fully compliant with 

regulatory requirements (Note 21). The Regulatory Sandbox provides an experimental platform for 

regtech, allowing firms to test and optimise technologies, such as trade regulation tools, compliance 

management systems, etc., in real market environments, which promotes innovation in regtech. Whilst 

the UK regtech environment is sufficiently robust, it still has a few issues that need to be improved. For 

example, data privacy and security issues. the UK has been strictly observing the General Data 

Protection Regulation (GDPR), which has largely increased the security and transparency of personal 



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data processing. However, in regtech applications, it is often necessary to co-operate with third parties, 

which involves data sharing. As a result, when mishandling or inconsistency in compliance with 

co-operating parties occurs, these personal data will face privacy and security issues. Hence, the UK 

should focus more on the regtech aspect, which needs to be addressed through more comprehensive 

policies, more optimal management and continuous regulatory innovation. 

4.2 Enhanced International Cooperation 

The FCA established the Global Financial Innovation Network (GFIN) in early 2018 on top of a 

proposal to create a global sandbox, and officially launched it in January 2019 (Note 22). The GFIN 

serves as a platform for international regulatory and financial innovation collaboration, and aims to 

provide innovative firms with a more effective way of interacting with regulators and to help them 

navigate between different countries as they seek to promote new ideas. GFIN enhances the joint 

regulation of AMLs globally by creating a collaborative network of multinational regulators for 

information sharing. In October 2020 GFIN published the first official Cross-Border Testing Lessons 

Learned (CBT). The report shows that participating companies must demonstrate that the product or 

service they are involved in testing meets the eligibility criteria of each regulator in the jurisdiction 

(Note 23). However, due to the widely varying eligibility criteria of participating regulators, it poses a 

significant challenge for many companies, which leads to difficulties in collaborating and aligning. In 

addition, as the Internet continues to evolve, the means of laundering digital currencies across borders 

has become more insidious. The UK should give more professional resources and support to develop a 

unified framework and policy to promote uniform international regulatory standards. And track 

transnational money laundering activities by strengthening compliance information sharing and 

coordination between countries. 

 

5. Conclusion 

The original purpose of the AML system was to combat financial crime. Whilst the cost of AML 

compliance in the UK continues to rise at the same time as the level of financial crime is rising, it does 

not indicate that the AML system is ineffective. According to some data and reports, the AML system 

is effective in combating financial crime and achieving the original purpose of the system. Which 

means that the system is not broken, it just has some issues that need to be improved. 

Firstly AML‟s compliance costs are disproportionately high in terms of staff and compliance training 

costs, and smaller in terms of technology. It means less investment in innovative regulation and less 

automation of regulation. The second is that as technology continues to progress, so does the level of 

crime. The money laundering methods of criminals have also become more sophisticated and difficult 

to track. In addition, the effectiveness of the AML system is demonstrated through data released by the 

government as well as case studies. It also explains why the AML system cannot be judged to be 

ineffective just because the level of crime has increased. 



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This essay also makes some recommendations for the improvement of the AML system so that it can 

better address the increasingly complex problem of money laundering regulation. 

 

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„Global Financial Innovation Network (GFIN)‟ (FCA, 29 January 2019) 

<https://www.fca.org.uk/firms/innovation/global-financial-innovation-network> accessed 17 April 

2024 

„Money Laundering and Illicit Finance‟ (19 March 2024) 

<https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/money-laundering-and-illicit-fina

nce> accessed 13 April 2024 

„“Money Mules”: Rising Numbers Are in Middle Age‟, BBC News (18 June 2019) 

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„Q2 2019 Cryptocurrency Anti-Money Laundering Report‟ (Ciphertrace) 

<https://ciphertrace.com/q2-2019-cryptocurrency-anti-money-laundering-report/> accessed 15 April 

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„Regulatory Sandbox‟ (FCA, 1 March 2022) 

<https://www.fca.org.uk/firms/innovation/regulatory-sandbox> accessed 17 April 2024 

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accessed 21 April 2024 

„Westpac accused of 23 million breaches by money laundering watchdog‟(The Sydney Morning Herald, 

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„Your Career in Anti Money Laundering‟ 

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Notes 

Note 1. Rehana Parveen, „Impact of Anti-Money Laundering Legislation in the United Kingdom and 

European Union‟ (2020) 5 IJEMS 118. 

Note 2. Ibid. 

Note 3. „Your Career in Anti Money Laundering‟ 

<https://www.int-comp.org/learn-and-develop/subject-areas/career-pages-anti-money-laundering/> 

accessed 13 April 2024. 

Note 4. Home Office, Economic Crime Plan 2 2023-2026, (Vision 6, 2023). 

https://risk.lexisnexis.co.uk/insights-resources/white-paper/true-costs-of-compliance


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Note 5. Antony Whitehouse, „A Brave New World: The Impact of Domestic and International 

Regulation on Money Laundering Prevention in the UK‟ (2003) 11 Journal of Financial Regulation and 

Compliance 138. 

Note 6. „Money Laundering and Illicit Finance‟ (19 March 2024) 

<https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/money-laundering-and-illicit-fina

nce> accessed 13 April 2024. 

Note 7. „Report: True Cost of Compliance 2023 | LexisNexis Risk Solutions‟ (LexisNexis Risk 

Solutions | Transform Your Risk Decision Making) 

<https://risk.lexisnexis.co.uk/insights-resources/white-paper/true-costs-of-compliance> accessed 13 

April 2024. 

Note 8. Igor Sumkovski, „The Optimal Level of Anti-Money Laundering Regulation for the UK 

Banking Sector. Banks‟ Cost of Compliance, De-Risking Problem and How to Implement Effective 

AML Systems and Controls‟ (master thesis, University of London 2017) 

<https://sas-space.sas.ac.uk/6873/> accessed 21 April 2024. 

Note 9. National Crime Agency, National Strategic Assessment of Serious and Organised Crime 2021, 

(CP 992, 2023). 

Note 10. „Crime outcomes in England and Wales 2021 to 2022‟ (GOV.UK) 

<https://www.gov.uk/government/statistics/crime-outcomes-in-england-and-wales-2021-to-2022/crime

-outcomes-in-england-and-wales-2021-to-2022> accessed 15 April 2024. 

Note 11. „Suspicious Activity Report 2022‟, 

https://nationalcrimeagency.gov.uk/who-we-are/publications/632-2022-sars-annual-report-1/file 

Note 12. „“Money Mules”: Rising Numbers Are in Middle Age‟ BBC News (18 June 2019) 

<https://www.bbc.com/news/uk-48671542> accessed 15 April 2024. 

Note 13. „Q2 2019 Cryptocurrency Anti-Money Laundering Report‟ (Ciphertrace) 

<https://ciphertrace.com/q2-2019-cryptocurrency-anti-money-laundering-report/> accessed 15 April 

2024. 

Note 14. Joras Ferwerda, „The Effectiveness of Anti-Money Laundering Policy: A Cost-Benefit 

Perspective‟ in Colin King, Clive Walker and Jimmy Gurulé (eds), The Palgrave Handbook of 

Criminal and Terrorism Financing Law (Springer International Publishing 2018).  

Note 15. John Heathershaw and Tom Mayne, „Explaining Suspicious Wealth: Legal Enablers, 

Transnational Kleptocracy, and the Failure of the UK‟s Unexplained Wealth Orders‟ (2023) 26 Journal 

of International Relations and Development 301. 

Note 16. NCA v Baker [2020] EWHC 822 (Admin).  

Note 17. John Heathershaw and Tom Mayne, „Explaining Suspicious Wealth: Legal Enablers, 

Transnational Kleptocracy, and the Failure of the UK‟s Unexplained Wealth Orders‟ (2023) 26 Journal 

of International Relations and Development 301. 

https://www.gov.uk/government/statistics/crime-outcomes-in-england-and-wales-2021-to-2022/crime-outcomes-in-england-and-wales-2021-to-2022
https://www.gov.uk/government/statistics/crime-outcomes-in-england-and-wales-2021-to-2022/crime-outcomes-in-england-and-wales-2021-to-2022


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Note 18. „Asset Recovery Statistical Bulletin: Financial years ending March 2018 to March 2023‟ 

(GOV.UK). 

<https://www.gov.uk/government/statistics/asset-recovery-statistical-bulletin-financial-years-ending-20

18-to-2023/asset-recovery-statistical-bulletin-financial-years-ending-march-2018-to-march-2023 

https://www.gov.uk/government/statistics/asset-recovery-statistical-bulletin-financial-years-ending-201

8-to-2023/asset-recovery-statistical-bulletin-financial-years-ending-march-2018-to-march-2023> 

accessed 17 April 2024 

Note 19. Alexandros A. Papantoniou, „Regtech: Steering the Regulatory Spaceship in the Right 

Direction?‟ (2022) 6 Journal of Banking and Financial Technology 1. 

Note 20. „Westpac accused of 23 million breaches by money laundering watchdog‟ (The Sydney 

Morning Herald, 20 November 2019) 

<https://www.smh.com.au/business/companies/westpac-accused-of-large-scale-breaches-by-money-lau

ndering-watchdog-20191120-p53c8o.html> accessed 17 April 2024. 

Note 21. „Regulatory Sandbox‟ (FCA, 1 March 2022) 

<https://www.fca.org.uk/firms/innovation/regulatory-sandbox> accessed 17 April 2024. 

Note 22. „Global Financial Innovation Network (GFIN)‟ (FCA, 29 January 2019) 

<https://www.fca.org.uk/firms/innovation/global-financial-innovation-network> accessed 17 April 

2024. 

Note 23. „Cross-Border Testing‟ (GFIN) <https://www.thegfin.com/crossborder-testing> accessed 17 

April 2024. 

 


