The UK has spent years talking tough on dirty money. A new analysis suggests the results are still falling short: just 28% of frozen criminal assets have been permanently recovered over the past seven years.
That gap matters because freezing assets is often the easy part. The hard part is turning freezes, restraints and high-profile announcements into outcomes that actually deprive criminals and corrupt elites of their wealth.
A new report and data tracker from Spotlight on Corruption lays out the scale of the problem, and why it is landing at an awkward moment for the UK, with more policy attention and tougher international scrutiny on the horizon.
What the numbers show
Spotlight’s analysis of the seven-year period since the “McMafia orders” era began (the post-2017 package of tools associated with the Criminal Finances Act and the rise of Unexplained Wealth Orders) points to a consistent pattern:
- £6.8bn in suspected criminal property frozen (2018/19 to 2024/25)
- £1.9bn permanently recovered over the same period
- 28% recovery rate, meaning “barely £1 recovered for every £4 frozen”
The report also draws on a widely cited estimate that there is a realistic probability that £700bn of dirty money passed through the UK economy over seven years. On that framing, the volumes frozen and recovered are a tiny fraction of the overall problem.
That is the key point for compliance teams: the UK is not short of rules, powers, and headline-grabbing legislation. The challenge is effectiveness.
Why this matters to organisations, not only investigators
It is tempting to treat asset recovery as “something the authorities do”. In practice, weak asset recovery outcomes tend to correlate with three things that directly affect regulated firms and professional services:
- More focus on “professional enablers”
When outcomes fall short, attention shifts to who helped move, park, disguise, or legitimise the proceeds. That is why the conversation keeps returning to lawyers, accountants, trust and corporate service providers, and parts of the financial sector.
- A push towards measurable AML effectiveness
Supervisors are increasingly interested in whether controls work in the real world: Did you stop a transaction? Did you exit a client? Did you escalate internally quickly? Are your SARs actionable? What changed as a result?
- Reputational and political pressure on the UK model
When the UK is described as a magnet for illicit wealth, the knock-on effect is higher expectation on the private sector to show it is not contributing to that ecosystem.
Why 2026 makes this especially timely
This report lands just as the UK is putting asset recovery and illicit finance front and centre in its 2026 agenda.
The government has announced a Countering Illicit Finance Summit in 2026, and committed to publishing a new Anti-Money Laundering and Asset Recovery Strategy in 2026.
At the same time, UK stakeholders are already preparing for the next Financial Action Task Force mutual evaluation cycle, with sector bodies referencing the data and evidence gathering that evaluation involves.
Put simply: 2026 is shaping up to be the year the UK is asked, loudly, “what is working, what is not, and what will you change?”
What Spotlight is calling for
Spotlight’s recommendations are designed to shift the system from activity to outcomes. Among the proposals highlighted are:
- A dedicated economic crime fighting fund that reinvests fines and recovered money into enforcement capacity
- A new strategy that sets out mechanisms for targeting illicit wealth more effectively
- Specialist economic crime courts with appropriately experienced judges for complex cases
Whether or not every proposal is adopted, the direction of travel is clear: more pressure to prove that crime does not pay.
What “effectiveness” looks like in practice
Even if you are not in law enforcement, this is the moment to tighten the parts of your AML programme that regulators and prosecutors tend to test hardest, especially where your organisation could be used to layer, store, or enjoy criminal property.
1) Treat source of funds and source of wealth as “defensibility” work
For higher-risk relationships and transactions, the question is not only whether you collected documents. It is whether your decision-making holds up later.
Practical steps:
- Set clear thresholds for enhanced due diligence and approvals
- Record the rationale for proceeding, pausing, or exiting
- Make the “why” easy to evidence months later
2) Measure outcomes, not only activity
Many programmes track inputs: training completion, CDD checks done, SARs filed. Those are important, but they do not show whether controls are working.
Add a simple outcomes layer:
- Number of escalations and how quickly they were handled
- Transactions blocked or declined
- Relationships exited, and why
- Red flags that reappear in incidents, complaints, or audits
3) Strengthen internal escalation and reporting pathways
Asset recovery often begins with a good internal escalation. If escalation is slow, unclear, or culturally discouraged, suspicious activity does not surface early enough.
Focus on:
- Clear roles and ownership
- Consistent triage rules
- Documentation of decisions and next steps
- Feedback loops so teams learn from patterns
4) Train to spot the patterns that enable asset parking
The cases that end up in headlines rarely look like textbook money laundering. They look like plausible wealth, plausible structures, and plausible professional narratives.
Prioritise training that covers:
- Corporate structures and beneficial ownership complexity
- Property and high-value assets
- Use of intermediaries and third parties
- Red flags that indicate proceeds of corruption, fraud, or organised crime
A quick checklist for 2026 readiness
If you are publishing an update to your AML programme this quarter, these are the questions worth answering in writing:
- Can we explain, simply, how our controls prevent our organisation being used to store or move criminal property?
- Do we have documented thresholds for enhanced scrutiny, and do people follow them?
- Can we evidence escalation decisions and outcomes end-to-end?
- Are we tracking effectiveness measures, not only completions and filings?
- Do our teams understand the typologies that matter for our sector?
The bottom line
The story here is not only that asset recovery feels disappointing. It is that the UK is heading into 2026 with a credibility challenge: freezing assets is not the same as depriving criminals of wealth, and international and political attention is moving towards measurable outcomes.
For compliance teams, that translates into a familiar expectation: demonstrate that your programme is effective, documented, and capable of standing up to scrutiny.
