Economic Crime updates – May 2025
Companies House
Implementation of new measures
The first measures under the Economic Crime and Corporate Transparency Act (2023) came into effect in March 2024. This introduced identity verification with Companies House direct, or via an Authorised Corporate Service Provider [ASCP*] to provide additional assurance about who is setting-up, running, owning and controlling companies in the UK.
* Since 8 April 2025 ACSPs can inform Companies House that they have verified someone’s identity by providing the person’s details and details of which checks and documents were used to verify them. It is the responsibility of each ACSP to make sure they meet the Companies House identity verification standards. Access guidance for ACSP’s for details.
The Office of Financial Sanctions Implementation (OFSI) update
New Threat Assessment Report
OFSI has published a new report – Legal Services Threat Assessment (April 2025). It addresses threats to UK financial sanctions compliance and aims to help UK stakeholders to develop their understanding of how to protect against threats to compliance using a risk-based approach.
The report reiterates the crucial role legal services providers play in ensuring compliance with UK financial sanctions, both within and outside the legal sector. Find out more.
Update to the OFSI General Licence
OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the United Kingdom. The current OFSI General Licence* expired on the 28 April 2025 and was replaced by INT/2025/6160920 on 29 April 2025 (expires 28 October 2025).
*The general licence allows law firms to get paid for specific activities to a person designated under either the Russian or Belarus regime, including funds needed to meet basic needs of the individuals and entities and payment of fees for any legal representation that they might seek.
Financial Sanctions – find out more
Updated LSAG Guidance
The Legal Sector Affinity Group (LSAG) has reviewed and updated the UK legal sector AML Guidance, which has also been approved by HM Treasury within the meaning of regulation 76(6) MLRs.
Demonstrating that you have followed LSAG Guidance provides a defence in any investigation regarding breach of MLRs – guidance and Sectoral Risk Assessments.
Failure to prevent fraud – new offence
The new ‘failure to prevent fraud offence comes into force in September 2025. It is being introduced under the Economic Crime and Corporate Transparency Act 2023 (Act) and targets large organisations to encourage a `proactive corporate-cultural shift around fraud prevention’.
The offence applies to all organisations that meet two of the following: Have more than 250 employees; have more than £36 million turnover; have more than £18 million in total assets. The criteria apply to each organisation, including its subsidiaries.
Economic Crime Quarterly – new Home Office update
The latest edition of the Economic Crime Quarterly from the Home Office – April 2025 includes Fraud Prevention and Protection case studies, plus an update on the fraud strategy expansion (as part of the government’s Plan for Change).
For further details please access the CRL Economic Crime webpage.
