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The Criminal Finances Act 2017 introduces the most important changes to the anti-money laundering and anti-terrorist-financing regimes in the UK in over a decade. The passage of the legislation further expresses a clear intent on the part of the government to put the civil powers to freeze and forfeit cash and property derived from ‘unlawful conduct’ to greater use. Building on the government’s 2016 Action Plan for Anti-Money Laundering and Counter-Terrorist Finance which earmarked the creation of ‘aggressive new legal powers’ and ‘new capabilities’ for law enforcement to enable the ‘relentless disruption of criminals and terrorists’ as a major priority, 1 the Act was passed on 27 April 2017 with overwhelming bipartisan support. Although the opacity of money laundering means it is notoriously difficult to quantify, the Home Office estimated in 2017 that the scale of money laundering in the UK exceeds £90 billion a year. The eye-watering figure has meant that both sides of politics have been quick to support new corporate offences, forfeiture powers as well as changes to the money laundering and counter-terrorist-financing framework. The new measures have been regarded as proportionate to the objective of protecting the UK’s status as a global financial centre 2 and cleansing it – or attempting to cleanse it – from so-called ‘dirty money’.
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