GI ACE Phase 1Heathershaw

February 2025 saw the publication by Oxford University Press of Indulging Kleptocracy, a groundbreaking new book by John Heathershaw, Tena Prelec and Tom Mayne. The book examines how lawyers, real estate agents, bank managers and others in similar professions play a key role in not only transferring illicit financial flows from kleptocracies, but in laundering the reputations of kleptocratic political elites. The book – based on years of research completed under the auspices of the ACE project – was recently launched with an event in parliament, hosted by the APPG on Anti-Corruption & Responsible Tax and chaired by Joe Powell MP, which saw a packed house listen to the authors’ arguments. Further comments were provided by Susan Hawley, Executive Director at Spotlight on Corruption. In this blog post, author Tom Mayne sets out the key arguments of Indulging Kleptocracy, and some steps the authors propose to better target the ‘professional enablers’ who protect and legitimise kleptocratic wealth. 

Indulging Kleptocracy explains the relatively new phenomenon of how modern-day kleptocrats are able to utilise a transnational network of professional enablers located in the Global North to extract money and maintain power. Crucial to our understanding of this is the fact that professional enablers do not simply supply their services, but create the structures that sustain kleptocracy, embedding it into our political and economic fabric. In the book, we analyse many cases where it is professionals based in London who identify creative ways to find loopholes in the rules, and invent new products which benefit the corrupt, such as citizenship-by-investment schemes. In doing so, we argue that these professionals have indulged kleptocrats much like the Catholic church once sold indulgences – offering absolution for a price.  

The effect on the kleptocrats’ countries of origin is clear – money gets stolen, poverty increases, and autocratic rule is entrenched. What is less well understood are the wide-ranging effects that transnational kleptocracy has had at home in the West.. For example, over half of UK Tier 1 investment visas – so-called ‘golden visas’ where individuals from abroad could gain residency by paying £1 million – issued between 2008 and 2015 were later reviewed by the UK government for potential security concerns. Once resident in the UK, kleptocrats and oligarchs will hire corporate intelligence firms to track journalists and researchers, and will instruct lawyers to issue  libel claims, a tactic often referred to as a ‘SLAPP’, a Strategic Lawsuit Against Public Participation. Even the threat of legal action will have a chilling effect on free speech and public interest research, as journalists cannot often afford to defend the potential multi-million cost of a High Court case and will instead self-censure their findings. Meanwhile, the kleptocrat will curry favour by making charitable and political donations, and such donations, along with opaquely funded ‘think tanks’ and societies, can start to undermine democracy. Without restrictions such corrosive capital can begin to challenge the efficiency and effectiveness of the rule of law. 

With Russia’s full-scale invasion of Ukraine, there was a realisation – at least in certain political and business circles – that the open-door policy to oligarchic cash may not have been a good idea. Along with wide-ranging sanctions, the UK Parliament passed two acts in 2022 and 2023 to counter economic crime, with an eye on illicit financial activity from Russia. However, if it was just a legal question, the solution would be easy: investigate and prosecute those enablers who are breaking the law. Yet the overall picture from the nine indulgences we analyse in the book, from “hiding money” (banking) to “silencing critics” (defamation law), is one of regulators being outgunned by the private sector. Enablers aren’t usually accessories to crimes. They may not be interacting directly with the acts of grand corruption that produce the wealth and are typically compliant with the law. In most cases, they appear to be either aware of who they are acting for or at least wilfully unwitting. This phenomenon cannot easily be legislated out of existence – think of a company owned by the son or daughter of a corrupt president receiving a lucrative oil contract, for example. Such an act might not be illegal under the law of the country in question, but even if it is, the fact that the judiciary in a kleptocracy is not independent from the country’s leadership, means there will be no cooperation with international investigators, and as a result little chance of the case ever reaching a UK court of law. 

We suggest introducing legislation which allows law enforcement to designate “kleptocratic enterprises” as organised crime, allowing assets belonging to anyone who is part of such a network to be seized1. This would also allow law enforcement to more easily target the enablers as they would then also be considered part of a criminal network. But new legislation is only as strong as its enforcement, and for that there needs to be greater resourcing of the National Crime Agency to tackle economic crime from overseas where the proceeds make their way to the UK.  

During the parliamentary launch event, I also suggested that legislation governing company formation should be tightened, requiring a nominated officer to be resident in the UK who would be liable for prosecution should the company be shown to be involved in criminal activity. This would deter company service providers from simply signing off on hundreds of companies with overseas owners. Across the world, there needs to be transparency from charities, universities and political parties over who they receive donations from, and there should be increased protection for investigators, journalists and whistleblowers seeking to expose kleptocracy and grand corruption.  

Without such actions, the transformation to a world where kleptocratic and oligarchic wealth and influence sit easily within democracies – witness Trump’s America, as an emerging example – will continue apace.  

Find out more about the ACE work that fed into the development of Indulging Kleptocracy here. 

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