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At the Annual Compliance conference recently held in London, we were honoured to hear from Baroness Hodge at our Annual Compliance Conference. Baroness Hodge offered a candid and comprehensive overview of the UK’s ongoing challenges and opportunities in tackling economic crime, tax avoidance, and illicit finance. Drawing on decades of parliamentary experience and her current role as the UK Prime Minister’s anti-corruption champion, Baroness Hodge outlined a wide-ranging agenda for reform, grounded in transparency, accountability, and the strategic use of legislative tools to reshape behaviour across the financial and political sectors.

Baroness Hodge began by framing economic crime as a continuum – from tax avoidance to tax evasion to outright corruption – with the UK’s financial services sector playing a central role. Despite the sector’s economic importance, its entanglement with secrecy jurisdictions and shell companies has facilitated large-scale illicit finance. The scale is staggering: an estimated £350 billion in illicit flows annually, with disproportionate harm to developing countries and UK public services. The UK’s corporate registry remains vulnerable, with thousands of shell companies registered under implausible details, including minors listed as persons of significant control and mass registrations at single addresses. These systemic weaknesses, she argued, are not merely technical failings but moral failures that undermine trust and enable broader criminality.

The session also highlighted the UK’s patchy enforcement record. While landmark leaks such as the Panama and Paradise Papers exposed global networks of corruption, the UK’s response has often lagged behind international counterparts. Baroness Hodge pointed to the US’s aggressive pursuit of financial institutions (such as the $2 billion fine in the Danske Bank case) as a contrast to the UK’s inaction. She advocated for stronger enforcement mechanisms, including recycling fines into investigative capacity and leveraging legal talent from the private sector. The introduction of a new corporate offence, the “Failure to Prevent Fraud” was proposed as a behavioural lever, akin to the Bribery Act’s impact on corporate culture.

Transparency and smart regulation were recurring themes. Baroness Hodge called for public registers of beneficial ownership across all UK-linked jurisdictions, including crown dependencies and overseas territories. She warned of the growing use of trust structures to obscure ownership and argued that legitimate financial arrangements should not require secrecy. The need for integrated, comprehensive legislation was also emphasised, replacing the current patchwork of underutilised laws. Reform of professional supervision, director liability, and political integrity (spanning lobbying, appointments, and party funding) were identified as critical to restoring the UK’s reputation as a trusted jurisdiction.

Finally, the discussion turned to the intersection of anti-corruption and national security. Baroness Hodge cited the infiltration of UK politics and property markets by Russian and Central Asian wealth as a direct threat to democratic institutions. She noted the use of political donations to influence policy and the failure to enforce existing sanctions regimes. While recent progress has been made in sanctions policy, enforcement remains under-resourced. The broader challenge, she concluded, is to convince policymakers that anti-corruption is not a constraint on growth but a prerequisite for attracting legitimate global capital. In a world increasingly shaped by geopolitical risk and reputational scrutiny, the UK must lead with integrity and transparency.

Conclusion

Baroness Hodge’s underscored the urgent need for systemic reform in the UK’s approach to economic crime and corruption. From corporate transparency to political accountability, the agenda she outlined is, in her view, both ambitious and necessary. The UK’s financial infrastructure, while a pillar of its economy, must not be allowed to serve as a conduit for illicit finance. Legislative reform, robust enforcement, and cultural change within both the public and private sectors are essential to restoring trust and safeguarding national security.

You can access all materials from the Annual Compliance Conference 2025 here.

Additional Guest Speaker:
David Knott (Case Controller, Serious Fraud Office, UK)

Author

Henry is a partner in the Baker McKenzie Dispute Resolution team and Co-Chair of the Investigations, Compliance & Ethics practice in London. Henry's practice focuses on investigations and business crime related issues with particular expertise in advising companies and individuals in relation to multijurisdictional fraud, bribery, corruption, and whistleblowing investigations and criminal and civil litigation. Henry is also well versed in supporting companies with their compliance processes and procedures. Henry worked in our San Francisco office for an extended period with our US white collar crime team and has been seconded to the investigations team of a well-known bank in London. During his secondment, Henry played a leading role in the internal legal team on a number of high-profile investigations. Henry has also been seconded to the UK Serious Fraud Office, during which time he was the Case Lawyer on a high profile and significant multi-million-pound investigation. Henry is recognised as a “Next Generation Partner” in Legal 500, which notes he is “intelligent and a good team player” and “extremely good in putting together both enforcement agency perspectives and the practical real life requirements and incidents”. He is also listed as a Future Leader in the Lexology Index for Investigations and was awarded Lexology’s Client Choice Award for Investigations in 2024.

Author

Eleanor is a senior associate in the Dispute Resolution team based in London and a member of the Global Investigations, Compliance & Ethics practice group. Eleanor's practice includes a broad spectrum of disputes and investigations, with a particular focus on white collar-crime, including anti-bribery and corruption, fraud and anti-money laundering. Eleanor’s work involves conducting internal investigations on behalf of clients, as well as external investigations engaging with regulators and enforcement agencies, advising on compliance matters, and criminal defence.

Author

Carolina Pardo joined Baker McKenzie in 1994 and is a Partner of the Firm since 2008. She is currently a member of the Global Steering Committee for the Firm’s Cybersecurity and Privacy group and of the Global Steering Committee for the Firm’s Investigation, Compliance and Ethics Group. She was a member of the Global Steering Committee for the Firm’s Global Antitrust and Competition from 2016 and until 2020 and is currently a member of the Latam's Antitrust Steering Committee.
She graduated as a lawyer and a specialist in International Contracts Law from Universidad de Los Andes in Bogotá. She obtained a LL.M. with emphasis in International Private Law and Competition Law from the London School of Economics and Political Science.
In 2016 and 2025 Global Competition Review selected her as one of the 100 most influential women in antitrust. The last two Superintendents of Industry and Commerce have selected Carolina as a Non-Governmental Advisor to the Colombian Antitrust Regulator. Legal 500 also awarded her a recognition in 2025 as lawyer of the year in compliance and investigations in Colombia.

Author

Cyrus Vance Jr. has earned a well-deserved international reputation as a trial attorney with a proven track record in high-stake litigation and global investigations. As the Co-Chair of Baker McKenzie's North America Litigation and Government Enforcement Practice, Cyrus is well-known for his expertise in white collar criminal investigations, complex civil and criminal litigation, sanctions enforcement, compliance and cybersecurity. With over three decades of experience in both public and private sector, Cyrus provides invaluable guidance to clients navigating cross-border investigations, enforcement matters, and cybersecurity incidents.
Prior to joining the Firm, Cyrus served three consecutive four-year terms as Manhattan District Attorney, overseeing a team of over 600 prosecutors. He handled landmark criminal prosecutions, including the successful litigation before the U.S. Supreme Court in Trump v. Vance and the conviction of Harvey Weinstein on two felony sex crimes. He also managed more than 100,000 cases annually, including complex white collar and business crimes both domestically and internationally. Cyrus regularly collaborated with regulatory and crime-fighting partners such as the City of London Police, Paris Prosecutors' Office, Singapore Attorney General, Europol and Interpol, and is known for his ability to build and manage teams collaboratively across borders and agencies.