UK Anti-Corruption Strategy 2025: What It Means for Accountants

In December 2025 the UK government published a new Anti-Corruption Strategy, presented to Parliament by the Home Secretary as CP 1454. It sits alongside the UK's anti-money laundering (AML) framework rather than replacing it, but it matters to accountants for two reasons: it names professional enablers as a priority, and it repeats the decision to move AML supervision of accountants to the Financial Conduct Authority (FCA). This guide summarises what the Strategy says, using the GOV.UK document. One caution first: the extract of the document that we could read was cut off partway through the second pillar, so we cover the parts we could see and say what we could not confirm.

The three pillars

According to the Strategy, its aims are organised in three pillars, with a cross-cutting strand on implementation, evidence, transparency and oversight:

• Corrupt actors: "combat corrupt actors and their funds in the UK and overseas" (Objective 1), covering justice and accountability, disrupting access and corrupt funds;
• Tackling UK vulnerabilities: tackling vulnerabilities to corruption in the UK (Objective 2), covering politics and government, the public sector and business integrity;
• Global resilience: building global resilience to corruption, covering international partnerships and international standards.

The foreword is signed by the Deputy Prime Minister, the Security Minister and the Anti-Corruption Champion, Baroness Hodge.

What it says about professional enablers

The Strategy defines professional enablers as individuals or organisations providing professional services that enable criminality. It refers to the National Crime Agency's Professional Enablers Strategy 2024 to 2026 and to a Taskforce on Business Ethics and the Legal Profession, which reported in April 2025 and proposed a "Legitimate Provenance of Wealth Test" for law firms. The commitments it lists include funding a dedicated professional enablers coordinator, consulting on new regulated activities under the money laundering regulations, and expanding sanctions against enabler networks. For the underlying enforcement strategy, see our guide to professional enablers and the economic crime strategy.

Supervision of accountants

The Strategy records the announcement of 21 October 2025 that the FCA will take over AML and counter-terrorist financing supervision of lawyers, accountants and trust and company service providers. It says this consolidates the functions of 22 professional services supervisory bodies, that implementation will take several years, and that the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) keeps its existing powers in the interim. A consultation on the FCA's powers was published on 6 November 2025. For the timetable and what it means for your firm, see our guide to the UK AML and Asset Recovery Strategy 2026 to 2029.

Funding and figures the Strategy cites

These figures are the government's, as stated in the Strategy:

• the Economic Crime Levy is described as raising over £100 million per year;
• the second Economic Crime Plan includes an uplift of 475 full-time equivalents across threat leadership, intelligence, investigation and prosecution for money laundering and asset recovery;
• over £389 million was recovered for grand corruption under Proceeds of Crime Act powers between March 2019 and March 2025;
• the National Crime Agency assesses a realistic possibility that over £100 billion is laundered annually through the UK or UK corporate structures.

Other tools it mentions

The Strategy lists unexplained wealth orders and account freezing orders among the innovative tools that help identify suspected proceeds of corruption, and cites the 2023 legislation that strengthened the company register and transparency over company and property ownership. For how unexplained wealth orders interact with politically exposed persons, see our guide to unexplained wealth orders.

Dated commitments

• a Countering Illicit Finance Summit hosted by the UK in 2026;
• a new Anti-Money Laundering and Asset Recovery Strategy to follow in 2026;
• Crown Dependencies to implement beneficial ownership registers aligned with the EU's July 2026 deadline.

What we could not confirm

• The sections of the Strategy beyond the first part of the second pillar, including anything on the failure-to-prevent-fraud offence or the changed identification doctrine.
• Whether the dated commitments above have all been delivered, as we have not checked each one.
• Any detail on how the Strategy will affect individual accountancy firms in practice.

What accountants should do: our suggestions

These are our suggestions, not government requirements.

1. Read the sections of the Strategy that relate to professional enablers and supervision in full.
2. Check that your firm-wide risk assessment considers bribery and corruption, not only money laundering.
3. Plan for the supervisory transition by keeping your policies, training records and risk assessment ready for review.
4. Review how you handle politically exposed persons and source of wealth, since these are the points the Strategy keeps returning to.

Frequently asked questions

Does the Strategy create new legal duties for accountants?

In the parts we read, it sets out government aims and commitments rather than creating duties directly. Duties come from legislation and your supervisor.

Who will supervise accountants?

The Strategy records the decision that the FCA will take over, with a transition over several years and OPBAS keeping its powers in the meantime.

Who is the Anti-Corruption Champion?

Baroness Hodge, who signs the foreword.

This guide is general information, not legal advice.