Skip to main content

Chris on illicit finance

Why we need to come together to fight back

Illicit finance is the money that underpins and enables nearly all crime. By tackling illicit financial flows, we can tackle all kinds of crime – human trafficking, bribery, corruption - you name it.

Tackling illicit finance is a job for all of us, explains Chris Bostock, director in our Financial Crime team.

After time as the money-laundering threat lead for the UK’s National Crime Agency (NCA), Chris is now busy helping global networks forge new crime-cutting connections.

Here, he takes us into a world of high-calibre criminals who undermine the societies and economies we live and work in. And he explains why the key to fighting back is coming together.

“Illicit financial flows underpin and enable nearly all global organised crime. Fraud, bribery and corruption, money laundering: they’re all aspects of illicit finance, and they all rub up against each other,” explains Chris.

“In tackling illicit finance, we want to make it harder for criminals to go about their criminal business. The only way to do that effectively is for the whole system to come together and to work collaboratively in the fight against illicit finance. That means having key stakeholders in both the public and private sectors working to achieve shared outcomes; it means cooperating nationally and globally, across all elements of the economy, to forge new relationships, develop new collaborative approaches and fight a common enemy.”

We often think illicit finance is victimless. But behind each illicit financial flow, there’s a huge societal and human cost. “People want to live in safe and stable economies and societies. But illicit finance undermines and damages both,” Chris says.

Each year, in their own silos, agencies and governments spend up to a combined $1.28 trillion trying to combat illicit finance – that’s 5 per cent of global GDP. And despite tremendous efforts, less than 1 per cent of the billions of pounds laundered every year is ever recovered, and only 3 per cent of fraud cases result in a conviction.

“When money moves into shadowy underworlds, it undermines good governance and means there’s less available for investment in communities - hospitals, schools, ambulances and roads. In countries where people are already living hard lives, that can be devastating.

“We need to do better. We’re never going to be as fast as the criminals, but we need to be less slow. We can use tech and data far more effectively if we share information, collaboratively deploy our public and private resources and tackle the threat together.”

“Criminals move between countries and institutions deliberately – they know we don’t talk to each other in the way we should. If we’re not working together, the criminals will slide between the cracks.”

Pace is also an issue. Criminals move money through the banking system in minutes; it can take law enforcement years to follow. There are good reasons that following the money is slower than sending it… sharing personal data – especially across borders – is hard. We need to think about the balance between the right to privacy and the right to be protected from crime and ensure we have that balance right.

We also need to ensure the capacity that exists in the whole system – public and private – is used effectively. The financial sector will always have more people fighting financial crime than government: “Many banks in the UK have more financial crime people than the National Crime Agency has officers. This capacity is often locked in low-value activities, like triaging false-positive transaction monitoring alerts. We need to ask why. Who has the levers to enable that capacity to do more? The nature of supervision is key, here – as is information sharing.

“Think of the regulated system as the defensive perimeter. We hope for example that banks can identify criminal activity through systems and controls… but if they can’t then the defensive perimeter is breached. Sharing insight and information about what bad looks like is critical as it will help all those mechanisms in the regulated systems be more effective at detecting and preventing crime. And we can’t just stop at the regulated sector.

Everyone has a role to play – take fraud. Once money is moving through the banking system it is too late… we need to ensure, for example that social media and telecoms companies are also part of the response as they can play a key role in helping protect people from being targeted by fraudsters in the first place,” explains Chris.

“Right now, all the stakeholders are fulfilling their own mandate – regulators are regulating, law enforcement is arresting people, banks are following the money-laundering regulations, but no-one is really monitoring whether everyone is working towards an effective outcome and a society that we all want to live in.

So how do we get to a point that everyone is moving towards our shared intended outcome?

“The UK’s Economic Crime Plan published in April 2023 is a good start. The first of its kind globally; it’s an acknowledgement that the system doesn’t work, and we need to do something about it.”

It explores how we work collaboratively with all the important stakeholders and agree on the national priorities. It examines what we should be doing about information sharing and how we can get the right legislation in place.

“The way forward is contingent on both public and private sectors being able to bring the whole of their capabilities to bear effectively in ways that will have a greater impact on crime. There’s a huge role, for example, for private business to rethink how it works and take advantage of changing legislation.

Criminals are always hunting ways to move value around as easily as possible. They’re going to avoid the heavily regulated sectors and find more innovative ways to get funds to where they need them. By thinking laterally and exploring how criminals could abuse your business, you become part of the defensive perimeter. Fighting crime takes all of us.”

Keep reading


Enjoyed learning more about illicit finance? Follow Chris, director of our Global Forum for Tackling Illicit Finance, for more updates. And stay tuned for new releases in this series exploring big themes and how we can tackle them — responsibly.