As the UK aims to position itself as a leader in global anti-corruption efforts, cracks are emerging in its own extended backyard. British overseas territories (BOTs), long under pressure to increase transparency, have now missed their final deadline to implement public registers of company ownership, a move critical to combatting tax evasion, money laundering, and the concealment of illicit wealth.
Despite years of promises and international commitments, these territories, including major financial secrecy hubs like the British Virgin Islands, Cayman Islands, and Bermuda, failed to meet the UK’s end-of-June 2025 deadline to establish fully public beneficial ownership registers. This failure severely undermines the UK’s credibility in the fight against financial crime and exposes serious weaknesses in the global enforcement chain.
Long-promised transparency delayed
Back in 2018, under mounting political and public pressure, BOTs committed to making company ownership transparent by 2023. In a spring 2024 manifesto, MPs called for tougher enforcement, stronger Companies House powers, and new failure to prevent offences. Crucially, they also flagged overseas territories as a major weak spot. That deadline for transparent company ownership was extended to June 2025, but now that deadline has come and gone, and the registers are still not in place.
This is not just a missed deadline: it’s a missed opportunity to clamp down on the enablers of economic crime. According to Transparency International UK, public registers are essential for ensuring that law enforcement, journalists, and civil society can identify the true owners behind anonymous shell companies. These vehicles have been used repeatedly to facilitate tax evasion, hide the proceeds of corruption, and fund terrorism.
The case for consequences
With the deadline now missed, anti-corruption experts are calling for firmer action. There is a growing consensus that the UK cannot allow its overseas territories to ignore binding transparency commitments without repercussions. If diplomatic pressure has failed, the government must consider stronger tools, including legal or financial levers, to ensure compliance. The message is clear: when international agreements are breached, there must be consequences.
What’s at stake for the UK?
This failure also collides with growing expectations for a tougher stance on economic crime. Parliamentarians have called for a stronger legislative and enforcement framework to tackle fraud, money laundering, and financial secrecy. This includes:
- Enhanced enforcement of the Economic Crime and Corporate Transparency Act (ECCTA)
- Faster implementation of failure to prevent fraud offences
- Increased resourcing for Companies House and enforcement agencies
But these domestic ambitions are undermined when the UK’s own territories remain safe havens for the very crimes it seeks to prevent.
Reputational and regulatory risk for business
Firms must be alert: doing business in or through jurisdictions with lax transparency standards brings significant risk. These include:
- Exposure to unknowingly facilitating tax evasion or money laundering
- Reputational damage from association with blacklisted jurisdictions
- Regulatory penalties, especially as UK regulators ramp up scrutiny
Due diligence and enhanced risk assessments are more essential than ever when engaging with companies registered in BOTs. Regulated entities should also track developments around UK sanctions and financial crime law, particularly any future government response to BOT noncompliance.
What should happen next?
For compliance professionals, the question is no longer whether the UK will act — but how, and how soon.
The UK government now faces a critical decision: continue tolerating noncompliance from its overseas territories, or enforce meaningful consequences. For businesses operating in or through these jurisdictions, uncertainty carries compliance risk.
Potential government responses include:
- Legislating directly to impose public registers on the British Overseas Territories
- Imposing financial penalties or trade restrictions tied to transparency failures
- Blacklisting noncompliant jurisdictions, triggering enhanced due diligence requirements
From a compliance standpoint, this is a live regulatory exposure. If the UK enforces these measures — or if international bodies like the FATF or EU escalate in response — firms may need to rapidly reassess client relationships, risk ratings, and onboarding processes.
Doing nothing is no longer tenable. The UK cannot credibly lead the global fight against illicit finance while parts of its own system provide safe haven for secrecy and abuse. For compliance teams, now is the time to prepare for stricter rules, tougher scrutiny, and higher expectations around beneficial ownership transparency.
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