The government has finally published the UK Anti-Corruption Strategy 2025, a five-year plan that sits alongside the Economic Crime Plan and the new Failure to Prevent Fraud offence. On paper it is ambitious. It talks about professional enablers, sets out plans for new enforcement tools and promises better protection for public money.
At the same time, many of the commitments are high level, with timelines, funding and scope still to be worked out. Civil society groups have welcomed the direction of travel, but they are already warning that gaps on political integrity and party funding risk undermining the wider package.
While this admittedly may not be a “game changing” moment anti-corruption advocates had hoped for, it is still a clear signal of where policy is heading. What exactly is in the strategy, where are the gaps, and what steps should organisations take now?
Why a new strategy?
The strategy sits against a difficult backdrop. The National Crime Agency estimates that more than £100 billion is laundered through or within the UK each year, and that UK businesses were offered around 117,000 bribes in the past year, worth more than £300 million.
In response, the strategy sets three broad aims over the next five years:
- strengthen enforcement against corruption
- support industry to prevent and identify corrupt activity
- tackle weaknesses in sectors that are vulnerable to corrupt actors, including football, public procurement and other high-risk areas
There is also a strong international angle, with commitments to use sanctions more actively against corrupt actors and to work with allies on illicit finance.
In other words, this is an attempt to pull together existing laws and initiatives into a single narrative, fill some obvious gaps and signal political intent. It is not a complete overhaul of the UK’s anti-corruption framework, and the government’s message is clear: the path to improvement lies primarily in better enforcement, stronger supervision and more coordinated oversight, rather than a wave of new legislative duties.
Enforcement, professional enablers and public procurement
Although much of the strategy is restating or repackaging existing work, there are some areas where organisations should pay attention.
1. Stronger domestic enforcement
The strategy confirms plans to expand the Domestic Corruption Unit (DCU) in the City of London Police, alongside continued support for the National Crime Agency’s International Corruption Unit and the International Anti-Corruption Coordination Centre.
There is an explicit commitment to:
- scale up the use of sanctions against corrupt actors
- increase coordination across law enforcement
- explore the use of artificial intelligence, including a prototype “corruption investigation assistant”, to speed up Serious Fraud Office investigations
None of this changes the law overnight, but it does reinforce a trend. Enforcement bodies are being encouraged to use the tools they already have, supported by new technology and more specialist teams. This sits neatly alongside the government’s broader shift toward tightening supervision rather than expanding statutory obligations.
2. Professional enablers and the AML supervision shake-up
The strategy continues a theme that has become familiar since the Russia sanctions regime was strengthened: focus on so-called “professional enablers” such as lawyers, accountants and financial intermediaries who facilitate dirty money.
Building on the separate decision to move AML supervision of law and accountancy firms to the Financial Conduct Authority, the strategy commits to consolidating the AML and CTF supervisory functions of 22 professional services supervisors. This consolidation is central to the government’s stance: stronger, more consistent supervision is presented as the route to higher standards across the regulated sector.
This will not happen quickly. The strategy talks about reforming the system and consulting on changes to the Money Laundering Regulations, rather than setting fixed dates. Yet for firms in legal, accountancy and corporate services, the direction is clear: closer, more consistent supervision, with less tolerance for weak controls or tick-box compliance. The emphasis is very much on making existing rules bite.
3. Public procurement, fraud and training
For the public sector, the strategy places renewed emphasis on the Procurement Act 2023, which aims to tighten regulations around supplier conduct. While the Act itself isn’t new, the strategy introduces a fresh focus on strengthening its application and monitoring. Specifically, it highlights measures to exclude suppliers with a history of fraud, bribery, or corruption, alongside efforts to mitigate conflicts of interest in procurement processes.
A key aspect of the strategy is its commitment to improving procurement training and culture. The government promises to:
- Monitor participation rates in procurement training and evaluate the effectiveness of learning and development products
- Review the effectiveness of the debarment regime for unfit suppliers
- Analyse commercial data to generate insights into corruption risks in contracting
Elsewhere, the strategy acknowledges that the uptake of fraud and corruption training among civil servants is currently low, positioning this as a problem that needs addressing.
This has two significant implications: First, public bodies can expect renewed pressure to evidence their training programmes, particularly around procurement and conflicts of interest. Second, suppliers bidding for government contracts can anticipate increased scrutiny of their own anti-bribery and corruption training, especially for staff involved with high-risk contracts or working closely with public officials.
Where does it fall short?
Civil society groups have welcomed many of these elements. Transparency International UK calls it “the most ambitious anti-corruption plan in years”, pointing to useful commitments on beneficial ownership, professional enablers and a stronger Domestic Corruption Unit.
But they also highlight a central weakness. The strategy largely sidesteps some of the most politically sensitive parts of the UK’s corruption risk profile, including:
- the influence of large donations on political parties
- gaps in transparency and enforcement around campaign spending
- the lack of robust, binding rules on conflicts of interest at the very top of government
While the government claims this strategy will improve enforcement by consolidating resources and focusing on better supervision, critics note that it lacks the specific, concrete new rules needed to tackle these critical areas.
The UK Anti-Corruption Coalition welcomes the strategy as a “major opportunity” yet urges rapid implementation plans, clear timelines and resourcing to avoid another cycle of ambitious promises without follow-through.
In practical terms, the document is still light on:
- concrete deadlines for key reforms
- detailed plans for resourcing and staffing the new and expanded units
- clarity on how political integrity and party funding risks will be addressed in the medium term
So this is better viewed as a framing document than a sudden escalation in liability.
So why should we care?
If the strategy does not rewrite the rulebook, why should compliance teams care?
Because it confirms and strengthens three trends that are already shaping enforcement and expectations.
- Professional services and financial centres are under particular scrutiny. The repeated references to professional enablers, supervisor consolidation and sanctions against facilitators make it clear that firms in law, accountancy, corporate services and finance will continue to be in the spotlight.
- Public procurement standards are rising. The combination of the Procurement Act and the strategy’s focus on excluding unfit suppliers means more rigorous checks on past conduct, beneficial ownership and conflicts of interest.
- Training and culture are becoming measurable expectations, not soft add-ons. Once the government starts monitoring participation rates in procurement and corruption training for its own staff, it becomes harder for public bodies or suppliers to treat anti-bribery training as a one-off exercise.
With the UK positioned as a global financial and professional services hub, the responsibility to lead by example is real, even if the policy language in this strategy is cautious. No need for panic or drastic changes; instead, it’s an ideal moment to review anti-bribery frameworks, strengthen due diligence, and embed integrity in everyday decisions.
Practical steps for compliance and training teams
Against that backdrop, a measured response might look like this.
1. Revisit your anti-bribery and corruption risk assessment
Make sure your assessment is up to date and aligned with current realities, including:
- exposure to public sector procurement, grants or concessions
- reliance on third-party intermediaries, consultants or introducers
- higher-risk jurisdictions and sectors flagged in recent National Risk Assessments
This should feed directly into your Bribery Act “adequate procedures” framework and, where relevant, your compliance with the Failure to Prevent Fraud offence.
2. Put procurement and public-sector touchpoints under the microscope
If you are a public body, the strategy is a reminder that central government will be watching procurement, training and debarment procedures more closely over the next five years.
If you are a supplier, ask:
- do your teams dealing with tenders, bid writing and contract management receive specific anti-bribery and conflicts-of-interest training, rather than generic content
- do your policies give clear guidance on hospitality, facilitation payments and sponsorships in a public-sector context
- could you evidence this quickly if a contracting authority asked
For many organisations, a course that focuses specifically on “anti-bribery in procurement” for public officials and those who work with them will become easier to justify in the coming year. The strategy’s own language on low training uptake creates a ready-made case for improvement.
3. Strengthen whistleblowing and speak-up channels
The strategy signals that the government will explore options to reform the whistleblowing framework, including possible financial incentives.
That does not change existing obligations yet, but it reinforces a message that is already coming from the Serious Fraud Office and regulators: firms that surface issues early, protect whistleblowers and self-report are more likely to receive leniency than those that ignore internal warnings.
Now is a good time to test whether staff understand how and where to raise concerns, and whether those channels are trusted in practice.
4. Join the dots across economic crime
The strategy is part of a wider patchwork that also includes:
- the Economic Crime Plan
- the Failure to Prevent Fraud offence under the Economic Crime and Corporate Transparency Act
- ongoing reforms to AML supervision and sanctions enforcement
Compliance teams will be better placed if they treat these as one evolving landscape rather than as separate policy silos. That means mapping ownership, data, sanctions, fraud and bribery risks across the business and making sure training and controls are consistent.
A moment to lead by example
The UK Anti-Corruption Strategy 2025 is not a revolution. It does not introduce a new offence, a new regulator or a sudden shift in corporate liability. It is a policy framework that confirms where the enforcement pressure points will be over the next five years and signals renewed political focus on corruption, everyday bribery and illicit finance.
For organisations, the sensible response is to use this moment to lead by example rather than wait for the next scandal or enforcement action to dictate priorities. That means:
- assessing exposure to bribery and corruption
- updating and testing policies and procedures
- investing in targeted training, especially around procurement and public-sector interactions
- making it easier for staff and third parties to raise concerns
Handled in that way, the strategy becomes less about political messaging and more about a useful prompt to strengthen controls, refresh training and show stakeholders that integrity is not a slogan confined to ministerial forewords.
