From watchdog to enforcer: the Insolvency Service targets financial crime
22 July 2025On 16 July 2025, the Insolvency Service unveiled a new five-year strategy, heralding a significant expansion of its role in the fight against economic crime. The Insolvency Service, underpinned by the new powers and funding granted to it in the Economic Crime and Corporate Transparency Act 2023 (ECCTA), is seeking to take a more proactive, interventionist role in insolvency-related wrongdoing and in doing so is anticipated to become a central actor within the UK’s enforcement framework for economic crime.
A new enforcement mandate
Historically, the Insolvency Service’s focus has been on core insolvency offences:
- bankruptcy restrictions;
- director disqualification; and
- prosecutions directly linked to insolvency proceedings.
The newly announced strategy suggests that ECCTA has fundamentally altered this landscape, providing the Insolvency Service with a sustainable funding model primarily through fees levied by Companies House. This increased funding should facilitate significant growth in both headcount and investigative capability. The Insolvency Service is now explicitly targeting a broader range of financial crime, including fraud, money laundering, and the misuse of cryptoassets.
The five-year strategy sets out three core objectives:
- enforcement of the UK’s insolvency framework;
- enforcement of the Companies Acts and associated legislation; and
- tackling economic crime facilitated through companies.
Towards achieving these aims, the Insolvency Service notes that it now has responsibility for enforcing 78 new criminal offences under the Companies Act, and a further 8 shared with Companies House. The strategy also notes that the Insolvency Service is reviewing its disqualification framework and live company investigation powers to ensure they remain fit for purpose in a rapidly evolving threat landscape.
Actions already underway
The Insolvency Service has immediately demonstrated its intent by spearheading a Companies House “clean-up” operation (announced the same day as the strategy), which has purportedly resulted in over 11,500 companies being struck off the register and the identification of 43,000 suspicious entities linked to international criminal activity, including money laundering and fraud. Such abuse of Companies House has been a longstanding issue within UK enforcement, and was a key motivation behind the passage of ECCTA. The Insolvency Service will be hoping that this recent inter-agency operation, involving close collaboration with Companies House, the National Crime Agency, and other partners, can serve as a model for future enforcement activity in this space. It is stated to have already led to asset recovery investigations worth approximately £70m and the winding up of multiple trust and company service providers.
The Insolvency Service is also expanding its use of the Proceeds of Crime Act (POCA) to freeze and forfeit criminal proceeds, and is investing in new forensic accountancy and digital forensic capabilities. Notably, the Insolvency Service has appointed its first “cryptocurrency specialist”, reflecting the growing importance of cryptoassets in both legitimate business and criminal activity. The Insolvency Service states that its enhanced digital and intelligence infrastructure, including a new intelligence database and the adoption of AI and data analytics, will enable it to identify, target, and disrupt misconduct upstream of actual insolvency.
Implications for insolvency market participants
For market participants, the message from the strategy is clear: the Insolvency Service wants to become an active prosecutor across a range of offences. It will target and directly address wrongdoing in cases involving complex fraud, cryptoassets, and cross-border money laundering. Directors, officeholders, and professional advisers should expect greater scrutiny, more robust enforcement, and a willingness by the Service to pursue claims and recoveries that may previously have been left to other agencies - or possibly dropped entirely due to a lack of resourcing. The Companies House operation is intended to herald a new era of insolvency enforcement in the UK – the coming months and years will prove whether the enforcement outcomes continue to match the rhetoric.
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