As you know, one of the most disappointing aspects of the UK's AML regime has been the widely acknowledged under performance of the asset recovery systems put in place by POCA.
The following information is from SOCA's 2010/2011 Report (I've removed the footnotes for ease of reading).
Category Value at 31 March 2011
Cash seizures £5.7m
Restraint orders £45.8m
Assets frozen (civil and tax powers) £13.7m
Confiscation orders obtained £33.8m
Civil recovery orders £2.0m
Consent orders £7.5m
Value of assets denied by partners in £44.8m
the UK as a result of SOCA referrals
Value of assets denied by partners £174.3m
overseas supported by SOCA
Total assets denied to criminals £327.6m
Now I tend to use estimates of Money Laundering occurring in the UK: £20-£40bn per annum.
That asset recovery is so miserable is bad enough, however, IMHO the UK Government should resist any siren calls to relax procedures because we could end up with an American style system. Check out paragraphs 7 and 8 of this story in The Daily Mail: Cynical but true?
So, as SOCA evolves, my advice would be to keep an eye on changes to the Asset Recovery system.
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