Professional Enablers of Financial System Abuses
Professional enablers allow kleptocrats and illicit actors to abuse the financial system. Our work seeks to understand their role in the criminal ecosystem and the required policy response.
Professional enablers, also known as gatekeepers, are defined in the UK’s Economic Crime Plan as ‘an individual or organisation that is providing professional services that enable criminality’.
The definition of professional enablers is broad, but the role of lawyers and accountants in facilitating criminality – from laundering the proceeds of organised crime to ensuring that oligarchs and kleptocrats circumvent sanctions – has drawn global attention, particularly since Russia’s full-scale invasion of Ukraine in 2022. A professional enabler’s behaviour can range from the complicit to the negligent to the unwitting. It is essential that the policy and regulatory response to enabling activity recognises this if it is to drive improvement in compliance standards across the sectors and act as an effective deterrent.
Aims and objectives
We explore the way in which professional enablers facilitate criminal activity, including money laundering and sanctions evasion, and the challenges to effective regulation and supervision of the sectors.
Our research aims to assess:
- The effective anti-money laundering supervision of professional enablers in the UK and the EU, including the challenges that both supervisors and the sectors face, the nature and impact of enforcement activity and the role of the FATF.
 - Typologies of enabling activity and the required policy response.
