Insolvency Service – the new sheriff in town

In our recent post we looked at some of the recent achievements of Companies House and the Insolvency Service. Hot on the heels of this update, on 17 July 2025, the Insolvency Service published its investigations and enforcement strategy for 2026-2031.

Its vision, as set out in the paper, is to be “recognised as a leading enforcement agency”, having a “more prominent role in tackling economic crime facilitated through companies” by “leading on more cases featuring fraud and money laundering” and delivering “richer and joined-up intelligence on potential abuse of corporate structures”.

Investigations and Enforcement Strategy 2026-31[1]

The Insolvency Service’s Strategy Paper sets out the following key areas of focus. It will, among other things:

• Work hand-in-hand with Companies House and establish deeper partnerships with the National Economic Crime Centre and other enforcement agencies (such as HMRC, the FCA, City of London Police and the Serious Fraud Office).
• Focus on pursuing fraudulent government support schemes, such as COVID support loans; pursue company directors who fail in their duties in relation to the Register of Overseas Entities, and act against those who use companies as vehicles to facilitate economic crime.
• Expand the use of their powers of asset seizure and forfeiture under the Proceeds of Crime Act 2002.
• Embrace the use of emerging technology (including AI and enhanced data analytics) and recruit and retain a motivated, skilled and professional workforce to make it an agile and effective prosecutor.

As set out in our prior update, funding from the Economic Crime Levy and Companies House fees has already enabled the Insolvency Service to investigate and prosecute cases. This has included:

• Intelligence work on 43,000 suspicious entities on the Companies House register with strong links to South East Asia criminal activity including money laundering, fraud and illegal gambling. The Strategy Paper reports that this intelligence led to a complex operation involving over 100,000 shell companies and asset recovery investigations into £70 million by the National Crime Agency (NCA).
• 11,500 companies being struck off[2], following a coordinated action by the NCA, Companies House, the Insolvency Service and others. The operation included raids of 11 addresses as well as debarment, referrals for criminal action to the Insolvency Service, high risk trust and company service providers being closed or facing action, and the identification of significant criminal property for civil recovery action.

The Insolvency Service has already put itself on the map as an enforcer. We will follow its next steps to become a leader in the fight against economic crime with interest.

HOW GHERSON CAN ASSIST

Gherson’s regulatory, white-collar and investigations team are highly experienced in providing assistance with corporate governance and defence matters. If you require assistance with filing or correcting information at Companies House or find yourself the subject of an investigation by the Insolvency Service, NCA or other enforcement body, our experts can help.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025

[1] https://www.gov.uk/government/publications/insolvency-service-launches-5-year-investigation-and-enforcement-strategy#:~:text=The%20enforcement%20strategy%20has%20three,economic%20crime%20facilitated%20through%20companies

[2] https://www.nationalcrimeagency.gov.uk/news/11-500-uk-companies-struck-off-companies-house-register-after-crackdown