ABSTRACT
The robust investigative tools appearing in the Criminal Finances Act 2017 have been complemented by measures introduced by the Sanctions and Anti-Money Laundering Act 2018 which was passed on 23 May 2018. Parliament’s Treasury Committee has since launched an inquiry into economic crime. Changes to the suspicious activity report framework are afoot, but it is unlikely that they will disturb any of the new powers and frameworks introduced by the Criminal Finances Act 2017. As policy and law directed at illicit wealth develops in the United Kingdom and test cases emerge, striking a tolerable balance between tough and effective measures and fairness to the individual or company–who may not be the subject of any actual criminal investigation–will continue to be a challenge. Whilst the concealed nature of illicit wealth calls for innovative law, the need for procedural fairness to be extended to even the most suspicious of persons lies at the heart of any mature legal system.
