Particularly since the late 2010s, governments, regulators and NGOs have honed in on a previously under-theorised threat: the “professional enabler.” Unlike the money launderer hiding in the shadows, these gatekeepers—lawyers, accountants, trust service providers and corporate formation agents—actively design and execute schemes that channel illicit funds into legitimate channels. Their conduct ranges from deliberate complicity to negligence, but the impact is the same: corruption, drug trafficking, people-smuggling, proliferation finance and terrorist funding all find sanctuary within their corporate structures.

A Rising Tide of Reports and Warnings

In March 2022, the ICAEW joined the Economic Crime Strategic Board in declaring professional enablers “a key issue in the fight against money laundering and related economic crimes”. The definition they agreed with the National Economic Crime Centre characterises an enabler as one whose “behaviour is deliberate, reckless, improper, dishonest and/or negligent through a failure to meet their professional and regulatory obligations.”

Shortly before, the OECD’s “Ending the Shell Game” report warned that lawyers, accountants and advisers are “undermine their own profession” by marketing and facilitating sophisticated offshore schemes tied to cross-border financial crime. In December 2024, Europol went further, revealing that more than 85% of organised-crime networks deploy shell-company–only vehicles with no real economic substance—offered by professional facilitators—as part of their crime-as-a-service model.

High-Profile Cases Expose the Threat

Panama Papers (2016) and Paradise Papers (2017) investigations by the International Consortium of Investigative Journalists showcased how global law firms and accounting practices set up opaque offshore structures to conceal the wealth of politicians and oligarchs. In the Luanda Leaks probe, consulting firms and trust companies helped funnel hundreds of millions of dollars out of Angola for Isabel dos Santos, Angola’s former president’s daughter, using a web of shell companies and nominee directors before funds landed in real assets overseas.

Closer to home, UK enforcement bodies are spotlighting complicit professionals. The Office of Professional Body AML Supervision (OPBAS) and the National Crime Agency’s Cross-System Professional Enablers Strategy (2023) highlight cases where solicitors used client accounts to launder proceeds of crime and accountants attested to false financial statements—actions that triggered regulatory sanctions and criminal prosecutions.

Fueling a Wall of Regulation

The exposure of professional enablers has directly driven a cascade of new rules:

  • 2002: Proceeds of Crime Act extends confiscation powers and requires Suspicious Activity Reports (SARs).
  • 2007: Money Laundering Regulations implement the EU Third Directive, bringing solicitor firms and accountants under AML obligations.
  • 2010: Bribery Act imposes strict liability on organisations for failing to prevent bribery by anyone associated with them.
  • 2017: Fourth EU AML Directive deepens KYC requirements for gatekeepers and expands scope to include trusts and corporate service providers.
  • 2023: Economic Crime and Corporate Transparency Act (ECCTA) mandates identity verification for company directors and PSCs, introduces failure-to-prevent-fraud offences, and strengthens Companies House powers.

By the mid-2020s, law and accountancy practices that once needed nothing more than basic credit checks to take on clients now face exhaustive client due-diligence rules, ESG checks, beneficial-ownership registries, and continuous transaction monitoring. This regulatory wall is only set to grow higher, with upcoming EU AML Package proposals and the UK’s post-ECCTA refinements.

Why Your Firm Can No Longer Afford Laxity

Professional enablers wield specialist skills—company formation, trust drafting, audit and conveyancing—that map perfectly onto the needs of criminal networks. When firms neglect red flags such as:

  • Rapid incorporation of shell companies in secrecy jurisdictions
  • Nominee directors with no verifiable background
  • Complex multi-tier ownership with no economic rationale
  • Large transactions inconsistent with client profile

they risk not just regulatory fines, but criminal prosecution, reputational ruin and client claims. As Baroness Hodge, the UK’s anti-corruption champion, observed, even unwitting facilitation carries severe consequences under ECCTA’s failure-to-prevent offences.