Clifford Chance

The National Crime Agency ("NCA") has set out the priorities on which it thinks firms should be focusing. Sanctions evasion and professional enabler activity feature prominently in the list of areas to which it has indicated firms should be devoting compliance resources.

The NCA’s 2025 System Priorities

In 2023, the previous Conservative Government published the Economic Crime Plan 2 ("The Plan"). The Plan set out a renewed strategy to combatting economic crime in the UK. The Plan recognised the power of public-private collaboration on economic crime threats and identified that more could be done to direct public-private resources towards priority areas.

In response to that commitment, the NCA, in partnership with the FCA, Home Office and HM Treasury, has now published the UK’s 2025 system priorities. For the first time, these priorities are being communicated directly to the regulated sector. The aim is to help firms focus resources on the most significant threats, marking an important development in public-private sector collaboration.

There are nine priorities in total, each considered of equal significance and developed to address key risks identified in the National Risk Assessment and the NCA’s 2025 National Strategic Assessment. Among them is sanctions evasion facilitated by UK-based or UK-registered professional enablers, particularly in relation to the evasion of the UK's Russia sanctions regime.

Professional enablers are defined as individuals or organisations that provide professional services which enable criminality. It includes those whose conduct is negligent through a failure to meet professional and regulatory obligations.

The NCA highlights that designated persons are using a range of techniques to circumvent sanctions affecting their personal and commercial holdings, and considers that professional enablers play a fundamental role in the ability of criminals to disguise their assets and launder the proceeds of crime.

This focus on professional enablers in the context of sanctions evasion is not new. Earlier this year, OFSI published a Financial Services Threat Assessment which highlighted the use of enablers by designated persons as one of the main risk areas for financial services firms.

Professional enabler activity in the financial services sector has traditionally been associated with wealth management and other kinds of financial advisory services, particularly those based in intermediary jurisdictions offering greater secrecy through their financial and legal systems. However, OFSI noted in its Threat Assessment that there has been an increase in activity by non-professional enablers linked to designated persons. These include individuals with close personal ties to designated persons, such as family members, associates, or other proxies.

Given the increased focus by enforcement bodies on the use of enablers in the circumvention of sanctions, firms should be alert to red flags which could indicate activity by an enabler aimed at circumventing sanctions.

UK Introduces Irregular Migration Sanctions Regime

In a related development, the UK government has brought into force its irregular migration sanctions regime, effective 23 July 2025.

As the first of its kind globally, the regime targets individuals and entities - including their enablers - who are complicit in people smuggling to the UK. Sanctions under the regime include asset freezes and travel bans.

The Regime is designed to disrupt the financial and logistical networks that facilitate irregular migration and complements new law enforcement powers being introduced in the Border, Security, Asylum and Immigration Bill to address organised immigration crime. It reflects the UK government's broader and increasingly assertive approach to deploying sanctions as a tool against organised crime and related threats.