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The Scale of Money Laundering in the UK: Too Big to Measure?

Anton Moiseienko and Tom Keatinge
Briefing Papers, 11 February 2019
Centre for Financial Crime and Security Studies, AML/CTF, Intelligence
By measuring the measurable – rather than lamenting the immeasurability of the immeasurable – the lower bounds of the scale of money laundering in the UK can be established.

Money laundering in the UK is often acknowledged as a serious threat to the country’s reputation, the integrity of its financial sector and, ultimately, its security. Despite the near-universal recognition that concerted action is necessary to tackle money laundering in the UK, the basic question of how much money is laundered in the UK remains unanswered.

This Briefing Paper reports how policymakers and researchers can gain a better understanding of the scale of money laundering in the UK than is currently available. 

  • Measurements of money laundering should distinguish between: (1) laundering of the proceeds of UK crime; (2) laundering of the proceeds of overseas crime that are invested in the UK, and (3) laundering of the proceeds of overseas crime via the use of UK business infrastructure.
  • Measuring the overall proceeds of UK crime can be based on aggregating the assessments of the volume of proceeds generated by various types of crime. Even if imprecise, the more reliable of those assessments are helpful for establishing the lower bounds of money laundering in the UK.
  • To improve the availability and reliability of data on criminal proceeds generated or laundered in the UK, law enforcement agencies should ensure that the information on criminal proceeds generated during investigations and trials is recorded and analysed, subject to necessary legal safeguards.
  • Measuring the proceeds of overseas crime that are either invested in the UK or laundered via the use of UK business infrastructure is especially challenging because the underlying crimes (known as ‘predicate crimes’) take place outside the UK. Analysis of case studies and suspicious activity reports (SARs) can provide a partial picture of the scale of money laundering that, although not comprehensive, can be used in the absence of better data. 

The paper is based on an expert roundtable workshop held at the Royal United Services Institute (RUSI) on 10 December 2018, which brought together 31 participants from the UK government, law enforcement agencies, academia, and the private sector. The discussion was held under the Chatham House rule.

Anton Moiseienko is a Research Analyst at RUSI’s Centre for Financial Crime and Security Studies. His research covers a range of financial crime issues, including corruption and financial integrity in developing countries, global responses to terrorist financing, and the intersection between cybercrime and money laundering. Anton holds a PhD in law from Queen Mary University of London.

Tom Keatinge is the Director of the Centre for Financial Crime and Security Studies at RUSI.

The views expressed in this publication are those of the authors, and do not reflect the views of RUSI or any other institution. The Strategic Hub for Organised Crime Research (SHOC) expert roundtable workshop on which this paper is based was generously funded by the ESRC.

Anton Moiseienko
Research Fellow, Centre for Financial Crime and Security Studies

Anton is a Research Fellow at RUSI’s Centre for Financial Crime and Security Studies. His current and recent research covers a range of... read more

Tom Keatinge
Director, Centre for Financial Crime and Security Studies, RUSI

Tom Keatinge is the Director of the Centre for Financial Crime and Security Studies at RUSI, where his research focuses on matters at... read more

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