Published: January 2026
Authors: Maria Nizzero, John Heathershaw, Tom Mayne

Highlighting a disconnect between the UK’s ambition to be a global leader in the fight against corruption and illicit finance and its weak track record in confiscating assets derived from kleptocracy, a new research paper by Maria Nizzero, John Heathershaw and Tom Mayne argues that the UK must move away from seeing kleptocracy as a source of wealth problem and reframe it as a transnational enterprise. The authors propose a new legal conceptualisation of ‘kleptocratic enterprise’ as operating as networks structured in a similar way to those observed in organised criminal groups (OCGs). 

The authors use case studies to examine elements of the UK’s current asset recovery system which present persistent challenges in confiscating proceeds of corruption, in particular the focus on targeting individuals rather than the broader enterprise they operate within. They point to the potential underuse of existing tools within the UK’s legal framework which could be used to target conspiracy and systemic networks, as well as the lack of any examples of successful prosecution in kleptocracy cases without a provable predicate crime. 

Drawing on lessons from anti-racketeering laws around the world used to target OCGs, they argue that this new conceptualisation could enable development of legal tools which would better equip law enforcement agencies to target the proceeds of corruption. The authors propose a series of options which could be used to reframe the UK’s approach, unlocking asset recovery, strengthening sanctions and restoring UK credibility in the fight against corruption and illicit finance.