Blog
Permission to Visit - Goldilocks and the Three Bank Statements
Robert Houchill
On 16 July 2025, the Insolvency Service released its new five-year strategy towards tackling economic crime facilitated by companies to be implemented between 2026-2031.
Despite an enthusiastic introduction to its plans as ‘ambitious’ and ‘transformational’, the four strategic pillars laid out in the strategy brief – to target more cases involving corporate structures and serious criminality; exploit emerging technology; collaborate closely with public and private sector partners; and recruit, retain and invest in its workforce – echo the agency’s existing commitments, as well as the aims of recently released strategies by adjacent organisations like the FCA, NECC and CPS.
Nevertheless, the Insolvency Service’s continued commitment to existing enforcement measures should still be acknowledged positively, given recent successes. The economic benefits of the agency’s work in disqualifying company directors and shutting down their companies was calculated to be in excess of £50 million between 2024-25.
During this period, the Insolvency Service also secured 77 criminal convictions, more than 1,000 director disqualifications and over £4 million in compensation. The average director disqualification tariff amounted to 8.5 years, with 20% lasting for longer than 10 years, and an estimated net benefit of £36 million to the economy. While these amounts are a tiny fraction of the yearly £10 billion that can be traced from illicit financial activity in the UK, according to the NCA’s 2025 report, the increase in director disqualifications and convictions – from 4 in Summer 2022 to more than 1,000 in 2025 – is a mark of significantly increased activity.
The strategy also mentions the agency’s successes in COVID-19 Bounce Back loan abuse investigations, following on from its inheritance of all remaining viable casework from the National Investigation Service (NATIS) earlier this year.
A director who fraudulently secured a £50,000 Bounce Back loan was convicted and sentenced at Isleworth Crown Court in June 2025. Jagoda Rubaszko, who applied for and received £50,000 for her fake business in 2021, is now disqualified from managing a limited company until 2033. She has been ordered to complete 300 hours of unpaid and made to pay a £2,000 contribution to the Insolvency Service’s prosecution costs.
Perhaps most notably, the Insolvency Service was also able to claw back the £50,000 Bounce Back loan in full by forcing Rubaszko to sell their residential property and motor vehicle in subsequent confiscation proceedings. This particular victory, though small in scale, is indicative of what the Insolvency Service is capable of achieving through swift and focused enforcement action.
The Economic Crime and Corporate Transparency Act 2023 (‘ECCTA’) has introduced the most significant reforms to Companies House since its creation. While the Insolvency Service’s strategy brief is unclear on how its enforcement responsibilities are expanded under the ECCTA, it demonstrates that, through its developing partnership with Companies House, its work will soon be multiplied as a result of the increased powers of Companies House. For instance, from March 2025, Companies House has been able to take swift and decisive enforcement action by:
- Commencing strike off measures if companies do not provide an appropriate address within the specified period (companies are not able to use a Royal Mail PO Box and equivalent services going forward)
- Rejecting appointments of new directors to existing companies where the individual was previously a disqualified director.
- Issuing financial penalties for any relevant offences under the new Act.
- Expediting the strike-off of companies concluded to be formed on a false basis
- Carrying out checks on Authorised Corporate Service Providers (ACSPs) to allow them to carry out verification services on other companies.
Through alerts from Companies House, the Insolvency Service has already initiated investigations into around 2,000 companies relating to the abuse of dormant company status involving directors based overseas with links to tax avoidance, tax evasion schemes and money laundering.
An increased workload, combined with a strategy to recruit and invest in a skilled and effective workforce, may well bring the ‘transformational’ change hoped for in this early stage.
With thank you to Angela Tsui for her assistance in preparing this blog.
About the author
Alun is a partner in the Criminal Litigation team and specialises in serious or complex financial crime, proceeds of crime litigation and corporate investigations. He has particular knowledge and experience of issues surrounding cross-border criminal investigations, corporate crime and deferred prosecution agreements.
Latest blogs & news
From Certificates to Belief Statements: The CPS and the Limits of Forum Bar Intervention
The CPS’s June 2025 guidance on the forum bar marks a decisive narrowing of the circumstances in which prosecutor’s belief statements may be issued. Such statements (by which a domestic prosecutor expresses the view that the UK is not the most appropriate jurisdiction for prosecution) have often featured in litigation under sections 19B and 83A of the Extradition Act 2003.
Focusing on Prosecuting Corporates: joint SFO – CPS Guidance released
On 18 August 2025, the Serious Fraud Office (SFO) and Crown Prosecution Service (CPS) published their Joint SFO-CPS Corporate Prosecution Guidance, intended for prosecutors who will make decisions about whether or not to prosecute a corporation.
Preparing for changes to non-disclosure agreements from 1 October 2025
In June the Ministry of Justice announced new legislation under the Victims and Prisoners Act 2024 which affects NDAs and confidentiality clauses.* Related guidance, published at the beginning of June, sets out the impact of this legislation on the enforceability of such agreements.
Why the Leveson Review Is Significant For UK Court System
The Leveson review has been billed as a once-in-a-lifetime opportunity to reform the court system, with 45 recommendations being presented to Lord Chancellor Shabana Mahmood.
OfS Condition E6: a first step towards a unified approach to harassment and sexual misconduct, but does it go far enough?
In July 2024 the Office for Students (OfS) published guidance on a new condition of registration dealing specifically with harassment and sexual misconduct. That condition, ‘E6’, comes into force on 1 August 2025. As such, universities and colleges have had a year to ensure they comply.
The Insolvency Service: Repackaging Old Strategies for New Successes with Major Partner
On 16 July 2025, the Insolvency Service released its new five-year strategy towards tackling economic crime facilitated by companies to be implemented between 2026-2031. Despite an enthusiastic introduction to its plans as ‘ambitious’ and ‘transformational’, the four strategic pillars laid out in the strategy brief – to target more cases involving corporate structures and serious criminality; exploit emerging technology; collaborate closely with public and private sector partners; and recruit, retain and invest in its workforce – echo the agency’s existing commitments, as well as the aims of recently released strategies by adjacent organisations like the FCA, NECC and CPS.
New Child Safety Duties Under the Online Safety Act: What Online Platforms Must Know
As of 25 July 2025, new child safety duties under the Online Safety Act have come into force, requiring online platforms to implement robust safety measures to prevent children from accessing illegal or harmful content. The consequences for non-compliance are significant, making it essential for online providers to understand their new obligations.
A System Under Strain: Why It's Time to Rethink the UK’s Approach to Extradition and International Cooperation
As global crime evolves and political landscapes shift, the UK’s legal frameworks for international cooperation and extradition are showing their age. In a new blog, Rebecca Niblock explores the Criminal Law Reform Now Network (CLRNN) Scoping Review (June 2025) which makes a compelling case: the time for reform is now.
Modernising Cartel Enforcement: CMA launches consultation on updated leniency guidance
On 29 April 2025, the UK’s Competition and Markets Authority (CMA) published a consultation on proposed revisions to its leniency guidance for cartel cases. The changes are intended to reflect legislative changes, align with current enforcement practices, and enhance the clarity, accessibility, and effectiveness of the CMA’s leniency regime.
New UK crypto regime takes a step closer
HM Treasury has published a draft statutory instrument which, when brought into force, will introduce a new regulatory regime for cryptoassets in the UK.
Five things to know about criminal risk in M&A transactions
Criminal risk isn’t the first thing that comes to mind when considering the commercial drivers behind a merger or acquisition. But our recent roundtable discussion at our offices made clear that criminal liability—however peripheral it might seem—can have very real consequences for deal viability and post-completion exposure. Here are five key takeaways from a discussion that brought together legal and business perspectives on how economic crime intersects with transactional work.
A tizzy over fizzy: how the Coca-Cola Company, and others, became recent targets of corporate “greenwashing” allegations
Whilst historically, climate-related litigation has been focused on governments, a report published last year by the Grantham Research Institute on Climate Change and the Environment showcased how, in recent years, climate litigation is being initiated more frequently against corporations for alleged Environment, Social and Governance (“ESG”) failings
Adolescence is brilliant TV but Jamie should have sacked his brief
The new Netflix drama Adolescence has propelled many themes to the forefront of our national conversations in the last week. With the corrosive effect of social media on our children being the most important, it is hardly surprising that the realism of the portrayal of the criminal justice system in the series has been somewhat overlooked.
Adolescence: The ordinary family’s worst nightmare
As we await the release of the Netflix series Adolescence this evening by award winning writer Jack Thorne, I am interested to see how the series will deal with very real, yet often publicly unheard problems of how our criminal justice system, in particular the police, manage children who are alleged to have committed serious offences.
Is the FCA’s name and shame policy now dead in the water?
On 6 February the House of Lords Financial Services Regulation Committee published its response to the latest iteration of the FCA’s proposals to “name and shame” firms under investigation by the regulator.
The implementation of the Online Safety Act: understanding Ofcom’s new requirements
Following the enactment of the Online Safety Act (“OSA”) in October 2023, Ofcom has prepared a multi-stage plan for its implementation. Under this legislation, online service providers are subject to a number of new obligations, and Ofcom has a duty to ensure compliance with these requirements.
SFO Unexplained Wealth Orders – new focus for illicit finance?
On 17 January, the Serious Fraud Office (SFO) secured its first Unexplained Wealth Order, in respect of a property believed to have been purchased with the proceeds of a £100 million fraud.
Sir Brian Leveson’s review of the courts
Whatever its cause, a backlog of over 73,000 Crown court cases is not acceptable. Delays for complainants, defendants and witnesses all impede justice. In the third quarter of 2024, the Crown court received over 31,683 new cases and disposed of 29,502. The passage of time will not solve the problem. Change is inevitable.
Increased Funding for INTERPOL’s CCF: Will it Solve the Delay Crisis?
A recent update on INTERPOL’s website is unlikely to raise eyebrows. The Commission for the Control of INTERPOL’s Files (CCF) has acknowledged that it has been experiencing delays in meeting its deadlines due to an increased workload, both within the Commission and among other INTERPOL stakeholders. This will be all too familiar to those targeted by red notices and their representatives. Resourcing issues and delays have long plagued the CCF, despite operational rules requiring decisions on disclosure requests within four months and deletion requests within nine months.
The continued rise of sextortion and blackmail
In this article, Sandra Paul, a Partner at Kingsley Napley, looks at the rise of sextortion and blackmail, the legal landscape in regard to such offences and the need for the current protections to be reviewed and consolidated
We welcome views and opinions about the issues raised in this blog. Should you require specific advice in relation to personal circumstances, please use the form on the contact page.
Contact us today
Or call +44 (0)20 7814 1200
You may also be interested in:
Blog
The rise of the cryptoassets in financial remedies
Connie Atkinson
Blog
Supreme Court clarifies VAT group rules in Prudential v HMRC
Waqar Shah
Share insightLinkedIn X Facebook Email to a friend Print