The More than the sum of its parts blog series presents learnings on key, cross-cutting themes from across the GI ACE research programme.
‘Professional enablers’ play a key role in facilitating, disguising, and protecting kleptocracy, grand corruption, and state capture, and laundering the proceeds of corruption. Over the last ten years, several GI ACE research projects have explored how enablers operate, the impact of policy and regulatory responses on enabling, and new approaches to tackling this complex problem. In this blog post, GI ACE researcher Devi Pillay looks at that remarkable body of evidence and draws out critical findings.
Enablers are central to illicit financial flows (IFFs)
Kleptocrats, criminals, and corrupt elites need professional service providers to move, disguise, and legitimise their funds. These intermediaries – including finance professionals like bankers, as well as non-financial professionals, such as lawyers, accountants, and realtors – facilitate IFFs by setting up shell companies and structuring corporate vehicles, providing tax advice, purchasing real estate and property, hiding beneficial ownership, and providing a wide variety of other professional services (Arshinoff et al., 2022). Banks are high-risk vectors of illicit finance, especially where they are politically connected or controlled (Dell’Osso et al., 2025). Lawyers can be considered ‘keystone’ enablers, as they are central to many transactions, structures, and activities involved in IFFs, and most enabling activities will require a lawyer at some point in the process (Prelec et al., 2025; Taylor and Beizsley, 2022). Real estate agents are key to the acquisition of property in destination jurisdictions (Angélico et al., 2025).
The key role played by these professions is widely acknowledged, though not uncontested. The risk-based approach central to the international anti-money laundering (AML) regime – especially as encapsulated by the Financial Action Task Force (FATF) standards and recommendations – is underpinned by the assumption that professional service providers are strategically positioned to discover, interrupt, and prevent IFFs, and therefore imposes a number of regulatory obligations on these firms to identify and mitigate the risks related to money laundering.
The current anti-IFF approach is unable to effectively tackle professional enabling
In practice, professional enabling has proved to be a complex problem that the narrow AML approach has been unable to untangle. Research has revealed critical gaps in the regulatory framework, but there is a dearth of evidence on the actual impact of current policy, and on effective strategies to curb the involvement of enablers (Arshinoff et al., 2022). The FATF-based approach has not delivered the intended results. In the UK, for example, the evidence shows that the system is effectively risk-insensitive, with poor identification of risk, inconsistent reporting, and weak enforcement (Heathershaw et al., 2021), and there is significant non-compliance with the AML regime (Taylor and Beizsley, 2022).
One critical gap is that the AML approach is designed to identify funds that are criminal in origin. It is often very difficult to establish a predicate crime for corruptly acquired funds, especially in countries characterised by kleptocracy or state capture (Nizzero et al., 2026). In these contexts, corrupt elites can protect themselves from investigation and prosecution, making it difficult to prove criminality. In captured states, where corrupt elites may control legislation and policy, funds that are the proceeds of corrupt are often (technically) legally acquired. Without a clear predicate offense, professional service providers are left to use their own judgement (Prelec et al., 2025), and it is impossible to hold them accountable for ‘enabling’.
Despite growing convergence in global anti-IFF regulation, both the nature of professional enabling and the implementation of AML standards varies widely across different contexts. Real estate money laundering in the Global South, for example, differs substantially from patterns observed in the Global North, including greater involvement of unregulated professionals like construction companies and property developers, informal and cash-based financial systems, and systemic corruption rather than implementation gaps (Angélico et al., 2025; Kundai and Oldfield, 2025). In some contexts, the very institutions that are meant to be the gatekeepers of the financial system can be captured by corrupt elites – as in the case of BGFI Bank in the DRC (Dell’Osso et al., 2025). International AML standards do not account for these context specific characteristics, a significant regulatory gap that creates opportunities for new types of enabling and money laundering.
Dominant anti-IFF approaches also tend to assume that money flows from the Global South to the Global North, but IFFs and the related professional enabling also exist within the Global South, where local institutions may be less capacitated to deal with being a ‘destination’ of illicit funds (Angélico et al., 2025).
Professional enabling is international
Professional enablers (much like kleptocratic networks) operate in sophisticated, transnational networks across multiple jurisdictions, coordinating a range of activities both lawful and unlawful (Heathershaw et al., 2025; Nizzero et al., 2026). Global firms have offices in many jurisdictions, often structured as franchises, and often escape meaningful consequences for misconduct committed by regional offices with relative ease. And while Western financial centres like London remain hubs for professional enabling, intermediaries are increasingly decentralised and other global financial centres are rising in prominence (Haberly et al., 2023). Corrupt actors and enablers adapt quickly to regulatory changes and take advantage of the asymmetrical regulatory landscape, shifting their activities to jurisdictions with weaker regulations and enforcement. We can see this in the substantial shift in IFF activity from Western financial centres to Dubai and Hong Kong, for example (Haberly et al., 2024).
Professional firms within this global ecosystem often work together in a complex series of interactions and transactions that can obscure illegality and misconduct. One way of conceptualising this is to look at how ‘upstream’ and ‘downstream’ enablers work together (Prelec and Oliveira, 2023). Upstream enablers enter into deals with kleptocrats in full knowledge of both the political status of their clients and the sources of their wealth and broker the initial steps of the laundering process. They are more likely to be involved with the acquisition and outflows of illicit funds and are more likely to operate in high-corruption contexts where AML enforcement is weak. Downstream enablers come later into the value chain of money-laundering activities and proceed with the part of the process that is not obviously illegal. Large, respectable firms, which are instrumental for the legitimation of illicit wealth and reputations, can therefore maintain plausible deniability within financial centres subject to stronger regulation and enforcement.
In the DRC, international correspondent banks and external auditors processed or overlooked clearly corrupt activities by a politically controlled local bank, one of many similar cases highlighting major weaknesses in global anti-money laundering enforcement in politically sensitive contexts (Dell’Osso et al., 2025). In South Africa, local politically-connected consulting firms worked with reputable multinationals to acquire corrupt contracts and facilitate state capture in state-owned entities (Pillay, 2025).
Investigating and prosecuting single individuals operating in this transnational, networked manner – especially professional enablers – is profoundly difficult. A more flexible and strategic approach, informed by anti-racketeering laws in many jurisdictions, may be to target the ‘kleptocratic enterprise’ itself, rather than individuals, and focus on systemic patterns of conduct (Nizzero et al., 2026).
Professional enablers do more than enable money laundering
Most policy responses to this problem have focused on AML rules and regulations, but hiding money and buying property are only one part of the picture. Professional enablers play a key role in protecting elites from accountability, laundering their reputations, attacking their enemies, and maintaining political power (Heathershaw et al., 2025; Cooley et al.,2021). They are also often involved in designing, facilitating, and even executing the corrupt activities that generate IFFs, especially in cases of state capture (Pillay, 2025). AML regulations are not designed to combat these activities, and many types of professional enablers – like wealth managers, family offices, and management consultants – aren’t covered at all.
Professions navigate complex ethical decisions and contest ideas of ‘enabling’
Professionals frequently operate in the grey area where corrupt activities are often technically legal or any criminality is very well obscured. This means that the narrow regulations offered by the AML regime have little concrete guidance to offer when professionals must decide whether to take on a client or provide a service in this grey area. Therefore it is critical for anti-corruption advocates to understand how these professions understand their ethical obligations in these circumstances and how they navigate the complex decisions involved in enabling, reporting, or refusing clients. Recent research on the legal profession in the UK shows deep seated differences in opinion about the role and responsibility of lawyers when acting for the beneficiaries of kleptocracy, state capture, and grand corruption (Prelec et al., 2025). These competing narratives reveal the key faultlines within the profession and explain both the prevalent norms and attitudes within the profession that legitimise enabling and opportunities for changing incentives and firm culture.
These professions are neither homogenous, nor are they passive. The very concept of professional enabling is highly (and vociferously!) contested (Prelec et al., 2025). They also do not merely take advantage of opportunities created by gaps in regulation and corrupt elites, but are actively involved in creating demand for their services and an enabling environment for these activities (Heathershaw et al., 2025). Professional service firms are largely self-regulated and highly influential in both the private and public sectors; they have substantial power to set the rules of the game by shaping regulatory standards as well as how they are implemented and enforced. Building consensus for profession-led reforms will be an important avenue for change.
Works cited
Angélico, F., Mugellini, G., Zinnbauer, D., Villeneuve, J.-P., Cunha, M.A., Silitonga, M.S., Irwinda, V., Oldfield, J., 2025. Real estate anti-money laundering in the Global South – are the laws and policies covering the actors they should cover? Trends Organ Crim 28, 524–551. https://doi.org/10.1007/s12117-025-09578-0
Arshinoff, N., Humphreys, J., Tassé, M., 2022. Global Finance and the Enablers of Corruption. GI ACE.
Cooley, A., Prelec, T., Heathershaw, J., Mayne, T., 2021. Reputation Laundering in the University Sector of Open Societies (Working Paper). National Endowment for Democracy.
Dell’Osso, J., Hollenbach, F., Hornsby, M., Szakonyi, D., 2025. Inside the Congo Hold-Up: How a Captured Bank Enabled Grand Corruption, GI ACE Research Paper. Anti-Corruption Data Collective.
Haberly, D., Garrod, G., Barrington, R., 2024. From Secrecy to Scrutiny: A New Map of Illicit Global Financial Networks and Regulation (CSC Working Paper No. 18). GI ACE.
Haberly, D., Shipley, T., Barrington, R., 2023. Corruption, Shell Companies, and Financial Secrecy: Providing an Evidence Base for Anti-Corruption Policy (CSC Working Paper No. 16). GI ACE.
Heathershaw, J., Cooley, A., Mayne, T., Michel, C., Prelec, T., Sharman, J., Soares de Oliveira, R., 2021. The UK’s kleptocracy problem: How servicing post-Soviet elites weakens the rule of law. Chatham House.
Heathershaw, J., Prelec, T., Mayne, and T., 2025. Indulging Kleptocracy: British Service Providers, Postcommunist Elites, and the Enabling of Corruption. Oxford University Press, Oxford, New York.
Kundai, L., Oldfield, J., 2025. Challenges in addressing illicit finance in the Kenyan real estate sector. CIFAR.
Nizzero, M., Heathershaw, J., Mayne, T., 2026. The Kleptocratic Enterprise: Lessons from organised crime to target transnational corruption and strengthen asset recovery in the UK. GI ACE.
Pillay, D., 2025. Consulting firms, corruption and state capture: A case study from South Africa. GI ACE.
Prelec, T., Oliveira, R.S. de, 2023. Enabling African loots: tracking the laundering of Nigerian kleptocrats’ ill-gotten gains in western financial centres. Journal of International Relations and Development 26. https://doi.org/10.1057/s41268-023-00292-4
Prelec, T., Barrington, R., Garrod, G., Tonin, P., 2025. Gatekeepers, enablers or technicians? The contested role of lawyers as facilitators of kleptocracy and grand corruption. GI ACE and Spotlight on Corruption.
Taylor, H., Beizsley, D., 2022. A Privileged Profession: How the UK’s Legal Sector Escapes Effective Supervision for Money Laundering. GI ACE.