Conclusion

At the time of writing, the robust investigative tools appearing in the Criminal Finances Act 2017 have been complemented by measures introduced by the Sanctions and Anti-Money Laundering Act 2018 which was passed on 23 May 2018. Notably, an unsuccessful amendment to the Criminal Finances Bill 2016 which would have seen that Act introduce a public register of beneficial owners of companies registered in British Overseas Territories has had a reversal of fortune. A publicly accessible offshore company register, pursuant to Part 2 of the Sanctions and Anti-Money Laundering Act 2018, shall be developed by 2020.