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Last month, the UK government published its first Outcomes Progress Report on the Economic Crime Plan 2 (ECP2), assessing how effectively the UK is tackling fraud, money laundering and kleptocracy since the plan’s launch in 2023. The findings paint a concerning picture, particularly around fraud, which continues to rise despite new legislation and enforcement powers.

While the report highlights important structural reforms and fresh investment in the UK’s response to economic crime, it also reveals that progress towards measurable outcomes remains inconsistent. In this article, we explore the key findings from the report, especially in relation to fraud, and what they mean for organisations seeking to strengthen their financial crime prevention frameworks.

Background

Originally published in March 2023, the Economic Crime Plan 2 (ECP2) set out to strengthen the UK’s defences against economic crime by uniting the public and private sectors to cut fraud, protect national security and support legitimate economic growth.

The first Outcomes Progress Report, released last month, provides an update on progress against these goals and highlights where improvement is still needed. Developed by the Home Office with input from law enforcement, regulators and industry, the framework focuses on reducing money laundering, recovering criminal assets, enforcing sanctions and, crucially, cutting fraud.

Backed by £400 million in government funding and a levy on regulated firms, ECP2 was billed as a “whole system” approach designed to protect the UK’s position as a trusted global financial centre. Two years on, the results suggest that ambition has outpaced delivery, particularly in the fight against fraud.

Fraud Rising Threat, Limited Progress

Fraud continues to dominate the UK crime landscape. Incidents recorded in the ONS Crime Survey rose by around 30 % over the past year, driven by digital channels. Although overall loss values have stayed broadly stable, more victims are being affected, suggesting individual losses may be smaller on average.

The introduction of the Failure to Prevent Fraud (FtPF) Offence in September 2025 was a landmark moment. It represents a fundamental shift in responsibility from enforcement agencies to the private sector, requiring large organisations to take proactive steps to prevent internal and associated fraud.

Yet the offence is aimed squarely at corporate misconduct, not the wave of consumer scams and authorised push payment (APP) frauds that continue to hit individuals and SMEs. The result is a fragmented landscape where prevention efforts are improving in some areas but leaving others exposed.

Money Laundering and Asset Recovery Weak Returns

The report paints a concerning picture of declining outcomes across the anti-money laundering (AML) regime. Convictions for money laundering offences have fallen, and the total value of criminal assets recovered in 2024 dropped by nearly 30% to £243 million.

Suspicious Activity Reports (SARs), a key mechanism for intelligence gathering, led to the denial of around £240 million in assets last year, below the three-year average. Given the significant compliance burden SARs create, these figures raise questions about efficiency and proportionality.

Sanctions and Kleptocracy

While progress has been made in strengthening the UK’s sanctions framework, enforcement remains uneven. Fewer detected breaches suggest continuing gaps in monitoring and detection rather than improved compliance outcomes.

For regulated firms, the focus should be on assurance. Screening tools, data quality and escalation processes all need to deliver effective results. As regulators place greater emphasis on governance, ownership and accountability, sanctions compliance must be embedded across financial crime frameworks rather than treated as a technical exercise.

Structural Reforms Underway

Despite the mixed results, several positive reforms are in motion:

  • Companies House transformation, introducing stronger verification and transparency requirements
  • SARs Reform Programme to streamline reporting and improve intelligence value
  • Expansion of crypto-asset regulation and stronger oversight of virtual asset service providers
  • Additional funding for OFSI to enhance sanctions enforcement

These initiatives could significantly strengthen the UK’s defences in the years ahead, but for now they remain largely aspirational.

Enforcement on the Horizon

While short-term outcomes may appear weak, enforcement pressure is building. The Serious Fraud Office (SFO), HMRC and the Insolvency Service have all signaled a more assertive approach, and early prosecutions under the FtPF and tax evasion regimes are expected to set precedents.

Organisations should not wait for enforcement activity to increase before reviewing their internal frameworks. The expectation is now clear: prevention not reaction.

What This Means for Businesses

With enforcement intensifying and regulatory expectations rising, organisations should:

  • Conduct a formal FtPF risk assessment to map exposure across business units, subsidiaries and third-party relationships.
  • Reinforce governance and reporting structures, ensuring fraud prevention and financial crime controls are owned at board level.
  • Review AML and sanctions frameworks for effectiveness, proportionality and data quality.
  • Test response and recovery capabilities, including fraud incident handling and whistleblowing procedures.
  • Embed ongoing training and awareness to ensure staff at every level understand their responsibilities.
How AJC Can Help

At AJC, we work with organisations across financial services, fintech and critical infrastructure to help them build resilience against financial crime and regulatory risk.

We have extensive experience in fraud prevention, compliance, and risk management. Our team includes leading specialists who have worked at the forefront of economic crime policy, regulation, and enforcement. 

We support organisations across sectors to: 

  • Assess fraud risks and identify vulnerabilities
  • Develop and implement proportionate and effective fraud prevention procedures
  • Embed ethical standards and an anti-fraud culture across all levels of the business
  • Deliver practical training that raises awareness and strengthens response readiness
  • Design robust governance and oversight frameworks to meet evolving regulatory requirements 

Whether you’re looking to review existing frameworks or prepare for upcoming regulatory changes, AJC provides the independent insight, practical tools and sector expertise to help you act with confidence.

Contact us on 020 7101 4861 or email us at info@ajollyconsulting.co.uk if you think we can help.

 

Sources:
https://www.gov.uk/government/publications/economic-crime-plan-2-outcomes-progress-report/economic-crime-plan-2-outcomes-progress-report

(https://www.ons.gov.uk/peoplepopulationandcommunity/crimeandjustice/bulletins/crimeinenglandandwales/yearendingmarch2025)

Image accreditation: Getty Images for Unsplash.com+. Last accessed on 13th October 2025. Available at: https://unsplash.com/photos/a-large-building-with-a-clock-on-the-top-of-it-67T3Bxl4Uro

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