Unexplained Wealth Orders (UWOs) were introduced under the Criminal Finances Act 2017 as a way to pierce through complex ownership structures and compel explanations for suspicious wealth. They were initially hailed as a game changer for tackling illicit finance but their use has been limited, and in some cases, controversial.
The Serious Fraud Office’s (SFO) first successful UWO in 2025 is a turning point, and compliance professionals should take note.
The SFO’s first win: Why it matters
In January, the SFO secured its first-ever UWO against a Lake District property linked to convicted fraudster Timothy Schools. The £1.1 million recovery from the sale of Hope Springs House, which was owned by his ex-wife, demonstrates how UWOs can be used to claw back proceeds of crime even when assets are held by associates or family members.
One of the key compliance takeaways here is that proceeds of crime don’t need to be directly owned by the fraudster. Any asset that appears disproportionate to known income and where links to serious crime can be established may fall within scope.
How UWOs work
Unlike traditional confiscation orders under the Proceeds of Crime Act (POCA), UWOs:
- Do not require a prior conviction
- Apply to assets valued at more than £50,000
- Shift the burden of proof. The respondent must demonstrate legitimate ownership or risk forfeiture
- Can be accompanied by freezing orders to prevent assets being sold during investigations
For compliance officers, this underscores the importance of source of wealth (SoW) and source of funds (SoF) checks. Weak or incomplete documentation could leave clients exposed if questioned under a UWO.
Lessons from Baker Street
The saga of 221b Baker Street, Sherlock Holmes’ fictional home turned real-world money-laundering riddle, illustrates both the potential and the limits of UWOs.
Investigations revealed that the property, worth £140 million, was owned by Dariga Nazarbayeva, daughter of Kazakhstan’s long-time ruler. Ownership was deliberately obscured through shell companies in the British Virgin Islands, Panama and Abu Dhabi.
The National Crime Agency attempted to use UWOs against Nazarbayeva’s London assets but faced significant setbacks. Courts accepted arguments that complex ownership structures were “normal practice” in international investment, and her elite legal team successfully defended against forfeiture.
Among the main compliance takeaways from this case was that sophisticated clients with global corporate structures will be harder to challenge, but not immune. Transparency obligations are tightening, and professional advisers are increasingly under scrutiny as potential “enablers.”
Compliance implications
For law firms, financial institutions and regulated professionals, UWOs highlight three areas of focus:
- Enhanced due diligence (EDD): Ensure SoW and SoF checks are rigorous, particularly for high-net-worth clients with political exposure or offshore structures.
- Documenting decision making: Keep clear audit trails when onboarding clients. If challenged, being able to show you queried unusual wealth and obtained satisfactory explanations is critical.
- Managing reputational risk: Clients involved in UWO proceedings face public scrutiny. Firms associated with opaque structures, whether or not unlawful, risk reputational damage.
What’s next?
SFO Director Nick Ephgrave has made clear that UWOs will be used more aggressively going forward. While the Schools case shows their effectiveness in recovering domestic fraud proceeds, the Baker Street mystery shows how difficult they can be against global elites.
It’s clear that compliance professionals can expect more scrutiny of wealth provenance. UWOs are no longer theoretical. They’re in play, and regulators will expect firms to demonstrate they have robust frameworks in place to identify, assess and escalate risks.
Or as Sherlock Holmes might have said, when it comes to unexplained wealth, “the game is afoot.”
Want to understand more about UWOs? Read our explainer blog, What is the Unexplained Wealth Order?
