Four Years On from Russia’s Full Scale Invasion of Ukraine, Too Many Gaps Remain in the UK's Ability to Detect and Deter Dirty Money

Tuesday 24 February 2026 – On the fourth anniversary of Russia's full-scale invasion of Ukraine, the UK Anti-Corruption Coalition is warning that despite progress, critical gaps in the UK's economic crime framework leave the UK exposed to dirty money and kleptocrats unpunished. 

Russia's invasion of Ukraine triggered a reckoning with the UK's role as a hub for illicit Russian finance. The UK Government responded with emergency legislation – the Economic Crime (Transparency and Enforcement) Act 2022 – and ambitious reform through the Economic Crime and Corporate Transparency Act. But while important steps have been taken, too many loopholes remain open and enforcement has fallen short.

While the UK has frozen over £28.7 billion in Russian assets and introduced important corporate transparency legislation, enforcement lags far behind. The UK’s sanctions regime was designed to turn off the taps for the Russian elite and slow the Kremlin’s advance in Ukraine, but a small number of lawyers, estate agents, property managers and other service providers are undermining its effectiveness. These evasion efforts invariably involve opaque corporate structures, trusts, and similar legal arrangements.

The National Crime Agency estimates that £100bn a year could be laundered in the UK, but the rate at which criminal assets are recovered is flatlining. Successful asset recoveries represent a fraction of the UK’s dirty money problem, with just £1 permanently recovered for every £4 that is frozen. 

Four years on, the Coalition calls on the Government to close remaining loopholes in company ownership registers – including in the UK’s Overseas Territories, reinvest enforcement receipts into law enforcement budgets, and set ambitious new targets for sanctions designations and asset recovery. Words must be matched with resources and results.

Mia Paukovic, Coalition Manager of the UK Anti-Corruption Coalition, said:

“If the UK is serious about confronting Russian kleptocracy, it must finish the job at home. Allowing dirty money to circulate through our system weakens democracy and undermines our credibility abroad.

As the UK prepares to host the Illicit Finance Summit and take on the G20 and FATF presidencies, that leadership must be underpinned by credible action domestically. The upcoming King’s Speech should include a new economic crime bill to reform money laundering supervision, alongside long-promised legislation to protect against abusive SLAPPs, which are increasingly used to intimidate and silence those investigating illicit finance. Without concrete action, the UK risks undermining its own leadership ambitions.”