The Economic Crime Levy Report 2024–25: what it tells us about the UK’s expanding enforcement arsenal

Introduction

In July 2026, HM Treasury published the second annual Economic Crime Levy Report, covering the financial year 2024–25. The report details how £96.9 million collected from entities subject to the Money Laundering Regulations was spent across six core deliverables  and what that spending has produced.

For those who have followed Gherson’s work in this area, the report confirms themes we have been highlighting for some time: the accelerating sophistication of crypto enforcement, the expansion of asset recovery capabilities, the growth of cross-border cooperation mechanisms and the increasing pressure on firms and individuals who find themselves within the authorities’ sights. This article examines the report’s key findings through the lens of those themes.

The numbers: where the money went

In 2024–25, funding was deployed across six deliverables, the largest allocations being:

• £31.5 million on hiring and training financial crime investigators, including approximately 200 new specialists at the NCA, City of London Police and Regional Organised Crime Units, plus 44 new legal, operational and investigative personnel at the Crown Prosecution Service dedicated to criminal and civil asset recovery;
• £22.5 million on state-of-the-art technology, including £15.3 million on Suspicious Activity Reports (SARs) reform, £4.8 million on data exploitation capability at the NCA, and £0.8 million on the successor platform to the legacy Joint Asset Recovery Database; and
• £17.2 million on specialist intelligence teams and the Combatting Kleptocracy Cell, including the Data Fusion pilot programme and expanded crypto and digital assets capabilities.

The levy is set to increase substantially. Following changes at Budget 2025, it is expected to raise approximately £225 million per year from April 2027 onwards — more than double its original £100 million target.

Crypto enforcement: the powers are being used

As we have highlighted across our series of blogs on UK crypto regulation and enforcement, the UK’s legislative framework for seizing and recovering cryptoassets has moved from the theoretical to the operational.

The ECL Report confirms this trajectory. It notes that levy-funded innovation in the NCA’s crypto and digital assets capabilities delivered:

• The first Crypto Wallet Freezing Order – a power we examined in detail in our blog “What is a Crypto Wallet Freezing Order?” and subsequently tracked through our article on the £6 million in frozen assets and our Freedom of Information requests to the SFO and HMRC;
• The training of over 600 officers in cryptoasset enforcement; and
• The use of AI and data tools to identify over 6,000 suspicious crypto addresses.

For individuals and firms operating in the crypto space, the message is unambiguous: these are no longer dormant powers. As we noted in our recent article on the OFSI Cryptoassets Threat Assessment, the UK enforcement community — now coordinated through the Crypto Cash Fusion Cell bringing together the NCA, Metropolitan Police, HMRC, the FCA, City of London Police and OFSI – is actively targeting the criminal abuse of cryptoassets.

Asset recovery: a system gaining confidence

The report documents significant operational results from Anti-Money Laundering Asset Recovery activity in 2024–25:

• £17.5 million recovered in a single civil case following a Defence Against Money Laundering request;
• £1 million+ in frozen assets, £40,000 seized, and 35 arrests in Operation Machinize targeting high street money laundering;
• £2.9 million in frozen assets, £10 million in confiscation orders, and 21 ongoing money laundering investigations from PLUME — a cross-agency initiative led by the Environment Agency, which saw the first-ever cash seizure using POCA legislation by that agency;
• 60 convictions for money laundering supported by the Expert Laundering Cadre, covering £150 million in combined laundering, 245 sentencing years, and forfeitures/confiscations of £35.5 million; and
• 7 properties and 3 high-value vehicles worth over £32 million seized as part of the UK’s participation in European Money Mule Action 10.

As we have consistently emphasised, including in our articles on Unexplained Wealth Orders, POCA asset seizure powers, and the expanding reach of the Combatting Kleptocracy Cell, the UK’s enforcement agencies are developing both the legal tools and the institutional confidence to pursue asset recovery at scale.

The Combatting Kleptocracy Cell: outperforming targets

The Combatting Kleptocracy Cell significantly outperformed its disruption target in 2024–25, delivering 27 disruptions, of which 17 were classified as “high-end interventions”. The report highlights a case study in which cross-team collaboration between the Civil Recovery Team and the Jurisdictions of Risk pillar enabled the recovery of £12 million in a settlement with suspected Chinese money launderers and fraudsters – a case that focused solely on asset recovery rather than criminal prosecution.

This is precisely the model we have discussed in our blogs on civil recovery and unexplained wealth orders: the UK increasingly uses non-conviction-based recovery as a primary tool, allowing authorities to deprive individuals of assets without the burden of proving a criminal case beyond reasonable doubt. For high-net-worth individuals with assets in the UK, this represents a fundamentally different risk profile from the one that existed even five years ago.

SARs reform: the intelligence foundation

The levy has invested heavily in reforming the Suspicious Activity Reports system — the mechanism by which financial institutions, law enforcement and the regulated sector report suspected money laundering. Over 1.1 million SARs have now been submitted via the new digital service, with more than 15,211 organisations onboarded.

The UK Financial Intelligence Unit (UKFIU) receives over 850,000 SARs per year. The report includes a case study illustrating the system in action: a reporter flagged concerns about a client from a high-risk jurisdiction laundering funds through cash deposits, leading to fast-tracked intelligence referrals, multiple asset freezing orders and nearly £150,000 restrained.

For firms subject to the Money Laundering Regulations, including cryptoasset businesses, the effectiveness of the SAR system has direct implications. As we have noted in our work on AML compliance, the obligations to identify, report and act on suspicion are not merely regulatory box-ticking exercises – they are feeding an intelligence machine that is demonstrably leading to arrests, freezing orders and forfeitures.

Public-private data-sharing: the data fusion pilot

Perhaps the most significant operational development for the private sector is the Data Fusion pilot programme – a public-private data-sharing initiative bringing together the NCA and seven UK banks. In 2024–25, the programme generated 338 tactical reports and identified £66 million in restrained assets. Two participating banks used Data Fusion data to inform their own transaction monitoring rules.

This represents a qualitative shift in the relationship between law enforcement and the financial sector. The traditional SAR model, in which firms report and then wait, is being supplemented by active, real-time collaboration. For firms, this means that the information they share (whether through SARs, Data Fusion or other mechanisms) is being operationalised far more quickly and effectively than in previous years.

AML supervision reform: the FCA as single supervisor

The report confirms that work on AML supervision reform continued in 2024–25, with the publication of a consultation response and the announcement that the FCA will assume AML supervisory responsibilities for certain professional services sectors. This is part of the broader consolidation of what has historically been a fragmented supervisory landscape – a development that is expected to bring more dissuasive enforcement and greater sharing of intelligence.

What this means for individuals and firms

The ECL Report 2024–25 is not merely a spending summary – it is a capability statement. It tells us:

1. The authorities have more people — almost 300 new FTEs onboarded in a single year, with a commitment to 475 by 2026;
2. They have better technology — modernised SARs, AI-driven crypto address identification, data exploitation platforms and real-time data sharing with banks;
3. They are recovering more — £66 million identified through Data Fusion alone, tens of millions in individual operations and the first crypto wallet freezing orders executed in practice;
4. They are getting bolder — the CKC outperforming targets, civil recovery being used aggressively without criminal prosecution and cross-border cooperation delivering settlements;
5. The funding is increasing — from £100 million to £225 million per year. The next Economic Crime Plan (2026–29) will be backed by substantially more resources.

For anyone with exposure to the UK’s anti-money laundering framework — whether as a regulated firm, a crypto business, a professional enabler or a High-Net-Worth individual with assets in the jurisdiction — the direction of travel is clear.

How we can help

Gherson’s White-Collar Crime and Regulatory team provides advice and assistance across the full spectrum of economic crime risk, including:

• AML and sanctions compliance, including for cryptoasset businesses;
• Responding to disclosure orders, SARs-related enquiries and regulatory investigations;
• Advising individuals subject to Unexplained Wealth Orders and interim freezing orders;
• Challenging enforcement actions and asset freezes involving digital currencies; and
• Advising on the interplay between compulsory disclosure mechanisms and Article 6 rights.

If you would like to discuss any of the issues raised in this article, 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 2026