NCA lists nine “system priorities” aimed at combatting the financing of organized crime

On July 21, 2025, the UK National Crime Agency published a paper identifying nine “system priorities” aimed at combatting the financing of organized crime in the United Kingdom.  The system priorities were established by the NCA, in partnership with the Financial Conduct Authority and Home Office and HM Treasury, that align with the objectives in the National Risk Assessment (NRA) and NCA National Strategic Assessment (NSA).  According to the NCA, these priorities are intended to “support the regulated sector in allocating resources where they can have the most impact on the threat, on a cost-neutral basis while maintaining their regulatory responsibilities.”  They mainly focus on money laundering typologies that apply to all possible predicate offenses that fall under the definition of economic crime, including fraud, sanctions evasion, terrorist financing.  The NCA also indicated that the priorities will be governed by “a newly created public-private System Prioritisation Governance Group (SPGG).”

The system priorities identified by the NCA are as follows:

1. 1. Professional enablers of economic crime and sanctions evasion in the UK and, in particular, those involved in the evasion of sanctions linked to Russia’s invasion of Ukraine;
   2. Transaction flows and corporate structures with ties to abuse of power by overseas Politically Exposed Persons (PEPs);
   3. The creation of a crypoasset ecosystem that is increasingly resilient to criminal abuse;
   4. The consolidation, cross-border movement and deposit of criminal cash into the UK banking system, including transactions that utilize the Post Office;
   5. Money laundering linked to Organized Crime Groups (“OCGs”) associated with priority Jurisdictions, including Albania, China, Russia, and the United Arab Emirates (UAE).  This includes activities by International Controller Networks and Underground Banking;
   6. Fraud against UK-based victims perpetrated by international offenders, including OCGs linked to criminality in priority Jurisdictions, including Ghana, Nigeria, Southeast Asia;
   7. Money mule networks used by mule herders to obfuscate the origin, movement and cashing out of crime proceeds;
   8. Tackling fraudulent schemes that originate from telecommunications services or online platforms; and
   9. The financing of terrorist attacks in the UK, individuals and entities involved in attack planning, or those who propagate terrorist ideologies.