‘Professional enablers’ pose a significant risk to the integrity of the UK’s economy and reputation as a global financial centre. We’ve worked with the government to agree a definition for anti-money laundering purposes. This guide sets out how to interpret the definition and what steps AIA members can take in the fight against economic crime.
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The National Crime Agency (NCA) and partners have highlighted the role of professional enablers at the heart of serious and organised crime impacting the UK.
Criminals exploit the specialist skills, knowledge and expertise of professionals to launder the proceeds of crime. They can also be used to enable crime, including:
The UK accountancy profession plays a key role in protecting the economy by tackling illicit finance and money laundering.
However, past rhetoric conflating accountants with ‘professional enablers’ undermines confidence in the UK’s financial system and the reputation of accountants providing legitimate services for clients.
This clear definition should help ensure law enforcement targets the appropriate bad players, distinct from the wider accountancy profession.
We worked with the National Economic Crime Centre (NECC), which consulted widely with the public and private sectors, to agree a definition for professional enablers.
This definition, published in the economic crime plan 2023/26, sets the foundation for the system response to tackle the threat:
“A professional enabler is an individual or organisation that is providing professional services that enable criminality.
Their behaviour is deliberate, reckless, improper, dishonest and/or negligent through a failure to meet their professional and regulatory obligations.”
‘Professional services’ includes but is not limited to:
The term ‘professional enabler’ does not include other types of enablers of crime, such as:
The involvement of the legal profession is more critical than ever in the fight against professional enablers.
We hope this definition will ensure the profession’s role as a gatekeeper is better understood and supported across law enforcement and government.
The definition should help government and law enforcement better understand the ways money laundering risks crystalise in different parts of the legal sector and where to focus supervisory activity.
Critical to this is government’s engagement with the legal sector, supervisors and law enforcement to obtain this firmer understanding to feed into legislative and other reforms.
The professional enabler is a part of a criminal network and has knowledge that they are facilitating criminal activity by providing their services.
The professional enabler fails to implement or adhere to proper controls and procedures to detect criminal activity, such as money laundering.
They are wilfully blind and take a ‘no questions asked’ policy. Their behaviour does not meet the standard expected of someone in a position of trust.
The professional enabler fails to meet their obligations under the Money Laundering Regulations 2017 and/or falls short of the standards set by their regulator/supervisor.
This could include:
Any individual or firm falling within the definition is vulnerable to criminal prosecution and regulatory/supervisory enforcement action which will significantly hinder, and in some cases stop, their ability to operate in the UK.
A professional will not fall outside the definition if they lack knowledge around the exact criminal activity being enabled.
It is vital that all professional service providers:
The definition does not include legitimate professional service providers who:
In May 2024, the Royal United Services Institute (RUSI) published analysis of the common services that professional enablers provide to sanctioned individuals. This included:
RUSI identified 12 recommendations to help sanctions achieve their desired results.
Read RUSI's recommendationsSuspicious activity reports (SARs) are a vital intelligence source.
The XXPRFXX glossary code identifies SARs related to professional enablers.
A UK Financial Intelligence Unit (UKFIU) review of all XXPRFXX SARs submitted in 2022 found that 66% had the incorrect glossary code.
Given how many SARs are made, it is important the correct glossary code is applied to enable efficient use of resource to assess and highlight relevant SARs.
Accurate use of the glossary code helps equip law enforcement and regulators to identify and respond to enabling activity by highlighting how the threat of professional enablers is impacting the UK.
As a basic guide when making a SAR, it should include, wherever possible:
Indicators of professional enabler activity can include:
The NECC and UKFIU are working with SARs reporters to improve the quality of intelligence reported in SARs.
The NCA has committed under the NCA strategy 2023/28 to tackle professional enablers of serious and organised crime.
The NCA looks to tackle those enabling the activities of the highest harm organised crime groups (OCGs), whilst local policing looks to take a robust approach to professional enablers.
There are a range of disruption opportunities available to law enforcement as well as regulators and supervisors which can bolster the UK’s response.
The NECC has implemented a refreshed professional enablers strategy to drive the law enforcement response to the threat.
The NECC is working with UK government, regulators, supervisors, and the private sectors to establish and implement a cross-system strategy to tackle the threat.
Its focus is on increasing the effective flow of intelligence between law enforcement, supervisors and the private sector, to prevent professional services from being exploited in serious and organised crime.
In this article, HMRC discusses actions taken to tackle the threat to the accountancy sector from professional enablers…
When we talk about crime, and the harm it causes to communities and individuals, money laundering is rarely more than an afterthought. It shouldn’t be; money laundering is key to organised crime. Without the ability to wash dirty money, criminals would struggle to further their operations and hide their assets. Money laundering underpins and enables organised crime.
Professional Money Launderers – or PMLs – are people who, for a fee, provide services to organised crime groups (OCGs) by laundering the proceeds of their crimes. They launder for multiple OCGs and don’t concern themselves with how the proceeds were generated. In other words, they’ll just as happily launder for drug traffickers or human traffickers as they will for tax fraudsters.
PMLs operate globally. They facilitate the movement of dirty money through multiple jurisdictions and are often based in countries where they (wrongly) think they are out of reach of UK Law Enforcement. We also know they use multiple methods and schemes to hide the true source of funds. This includes using the expertise, skills, influence or access of others.
People working in regulated sectors, such as accountants, are of great interest to PMLs. By exploiting regulated and professional businesses or individuals, PMLs can increase the veneer of legitimacy for their laundering techniques. They try to hide in plain sight and hope the system isn’t dynamic enough to catch them.
Through HMRC’s criminal investigations, we have identified several ways in which accountancy professionals can be used in money laundering schemes. For example, PMLs might utilise trust and company formation services to conceal the ownership of criminal assets and/or facilitate the movement of illicit funds through secrecy jurisdictions.
They may use criminally complicit professionals to falsify accounting through false bookkeeping or to create false documents in order to facilitate trade-based money laundering. For those individuals, in addition to using all the tools HMRC has to disrupt their activities, we are working with supervisors to share insight, intelligence and leverage other capabilities to make professional life for these complicit individuals extremely difficult.
However, we suspect that many accountancy professionals used by PMLs will likely be unaware of their role in facilitating multimillion pound money laundering schemes. In such circumstances, we don’t try to make life difficult for them. Instead, we want to focus on education, building understanding and helping professionals spot PML exploitation and take the necessary next steps.
The more we know about PMLs, the better we can respond. The submission of Suspicious Activity Reports (SARs) is key to this. These reports are of significant value to HMRC, including in ways that are not immediately apparent. For example, we use all non-sensitive – that is, TF focused – SARs as part of our routine risking processes, including our ongoing intelligence development against identified PMLs. We are reaching out right across the regulated sector to reinforce the value of SAR reporting to help us build our understanding of PML networks. If you’d like more information about SARs and how to submit a high-quality SAR, visit the NCA’s SAR webpage.
But we also want to listen to the experiences of the accountancy sector more generally and hear the thoughts and views of accountancy professionals themselves. Apart from SARs, are there other opportunities for the public and private sector to work together to tackle Professional Money Launderers? Is there an opportunity to better use technology? Where should we focus our educational efforts, and can we do so jointly? We’d be really interested to hear your thoughts. If you want to learn more about PMLs, sign up for our webinar.
