The UK Government (the Government) has recently published the first update on its Anti-Corruption Strategy 2017-22 (the Strategy).
The Strategy seeks to provide a framework to guide the Government’s anti-corruption policies and actions with a particular focus on economic crime. It provides a set of objectives covering a number of different areas, including bribery and corruption, money laundering, law enforcement, and guidance for both the public and private sectors and overseas. The update tracks the Government’s progress in reaching those objectives during 2018.
Progress in 2018
The key updates for 2018 are as follows:
1. Objective: Increasing the transparency and integrity of the UK as a financial centre.
In July 2018, the Government published the Registration of Overseas Entities Bill for the establishment of a public register containing the beneficial ownership of overseas legal entities. Earlier in the year, the Government also published a review of existing arrangements for sharing the beneficial ownership information held by overseas territories with UK law enforcement agencies.
2. Objective: Bringing a stronger law enforcement, prosecutorial and criminal justice action.
The Government has now established a range of new entities for handling economic crime, including: a new National Economic Crime Centre, a ministerial role of Security and Economic Crime Minister, a Ministerial Economic Crime Strategy Board and an Economic Crime Delivery Board. The Government is also strengthening cooperation with international partners and supporting the investigation and prosecution of financial breaches, for example, through building the International Anti-corruption Co-ordination Centre.
3. Objective: Enhancing anti-money laundering and counter-terrorist financing capability.
In January 2018, the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) became operational. OPBAS is hosted by the FCA and aims to ensure that professional anti-money laundering supervisors are complying with the high standards required of them under the Money Laundering Regulations 2017.
4. Objective: Strengthening public-private partnership, information sharing and targeting of those posing greatest risks.
In 2018, the Government established a three to five-year programme to make the Suspicious Activity Reports regime more efficient and effective. In addition, the Government has supported the “Flag It Up” anti-money laundering campaign for the legal and accountancy professions to help prevent their involvement in money laundering.
5. Objective: Promoting integrity across the public and private sectors.
In October 2018, the Government launched the “Counter-Fraud Profession”. This is a structure for practitioners across fraud, anti‑corruption and economic crime working in central government to ensure they have the necessary skills to identify and mitigate internal bribery and corruption risks. In the same month, the Government Standards for Counter Fraud, Bribery and Corruption were published. These set out the core components that a government organisation needs to protect it from fraud, bribery and corruption.
6. Objective: Increasing protection for whistleblowers.
In July 2018, the Government implemented the revised Freedom of Information Act Code of Practice, which aims to improve understanding of best practice for all public authorities and bodies responding to freedom of information requests. In addition, in May 2018, the Employment Rights Act 1996 (NHS Recruitment – Protected Disclosure) Regulations 2018 came into force. This legislation is designed to protect previous whistleblowers seeking new employment opportunities in the NHS from discrimination.
7. Objective: Reducing corruption in public procurement and grants.
In December 2017, the Government published a Procurement Policy Note, which provides updated guidance on transparency and publication of tender and contract documents. A review of the procurement risks in local government is set to finish in mid-2019.
8. Objective: Improving the business environment at a global level.
The Government reiterated its commitment to reduce the impact of corruption on trade and investment internationally by ongoing bilateral and multi-lateral engagement with international partners and active participation at global fora, including through the OECD Anti-Corruption Convention. In 2018, the Government worked with the G20 Anti-Corruption Working Group to negotiate and publish a set of High-Level Principles on Preventing Corruption and Ensuring Integrity in State-Owned Enterprises. UK Export Finance has also been working on a new OECD Recommendation on Bribery and Officially Supported Export Credits to promote higher standards of anti-bribery due diligence. The text of the new Recommendation is expected to be published in early 2019.
9. Objective: Cooperating with other countries to fight corruption.
The Government has stated its support for organisations and entities such as the International Budget Partnership, the Extractive Industries Transparency Initiative, the Natural Resource Governance Institute, and Transparency International UK that are working to enhance international transparency, especially in beneficial ownership, extractives, public finance and contracting.
10. Objective: Reducing insider threat in four high risk domestic sectors (borders, prisons & probation, policing and defence).
In 2018, the Government strengthened its approach to insider threat by introducing a national vetting standard on a statutory footing and a new Police Barred List to prevent individuals who have been dismissed from re-joining the police service and certain law enforcement bodies. The Government also extended disciplinary proceedings to former officers in cases of the most serious misconduct. Through the Centre for Protection of National Infrastructure, the Government has tackled insider threat by helping organisations develop insider risk programmes.
Objectives for 2019
The update also sets out the Government’s objectives for 2019:
- Raising international standards for business integrity as a critical step for the nation’s prosperity. Continuing the development of the Business Integrity Hub to provide a signposting mechanism for companies looking for support on business integrity, and finalising an approach to free trade agreements.
- Promoting hostility to illicit finances. Increasing efforts to ensure the UK’s financial sector does not engage with illicit finances.
- Strengthening evidence base for anti-corruption. Working on developing a better understanding of the threat posed by economic crime, both in international and domestic corruption.
- Addressing insider threat. Securing a more strategic approach to tackle corruption in high risk public sectors.
- Reinforcing international partnerships. Maintaining relationships with international partners through international fora, bilateral action and civil society initiatives.
Read the full update here.