UK Trends and Developments Contributed by: Neil Swift, Jasvinder Nakhwal, Charlotte Tregunna and Rachel Cook, Peters & Peters
Access to Trust Information and the Register of Overseas Entities Since 1 September 2025, any individual can apply to access trust information held on the UK’s Register of Overseas Entities. From August 2022, overseas entities owning UK property have been required to disclose their beneficial owners, but trust data was previously restricted to regulators. Under the 2025 amendments, individuals can now request this information by application, with limited grounds for refusal such as ongoing investigations, national security or the involvement of minors. Appli - cants may need to demonstrate a legitimate interest in certain cases. Individuals listed within the register can apply for protection from public disclosure in specific circumstances. Protection is granted if the disclosure of information would put the individual or their house - hold at serious risk of violence or intimidation, or if the individual is a minor or lacks capacity. This change increases transparency but also risk. Trusts can no longer be relied upon to conceal ben - eficial ownership. Companies and individuals with trust-based structures must ensure compliance and prepare for greater public scrutiny. Investigators and journalists, meanwhile, gain a powerful new tool for UWOs continue to grow in importance as a means of asset recovery, following a reduction in the risk of adverse costs being ordered. In January 2025, the SFO obtained its first UWO, relating to a property in the Lake District owned by the ex-wife of a convicted fraudster. By September 2025, the SFO had recovered GBP1.1 million from the sale of that property. tracing ownership and financial flows. Unexplained Wealth Orders (UWOs) Director Nick Ephgrave emphasised that the agency will use “all the tools at our disposal” to recover illicit assets, including from associates or family members of convicted individuals. The success of this case confirms that UWOs can be an effective instrument in tracing and recovering proceeds of crime. Companies and individuals holding high-value UK assets through opaque structures should reassess their exposure. With the SFO’s increased focus on
asset recovery, the risk of scrutiny under the UWO regime is higher than ever. Sanctions for Corruption Breaches: UK Anti- Corruption Sanctions Regime The UK’s sanctions toolkit now plays an increasingly prominent role in tackling corruption. Under the Global Anti-Corruption Sanctions Regulations 2021, the gov - ernment can designate individuals or entities involved in “serious corruption”, including bribery and misap - propriation of property, and impose a suite of sanc - tions such as asset freezes, director disqualification and travel bans. These sanctions apply within the UK and extend to all UK persons (ie, British nationals and bodies incor - porated in the UK), wherever they are in the world. Once designated, a person’s funds and economic resources (including property) must be frozen, and no funds may be made available to or for their benefit unless licensed by the Office of Financial Sanctions Implementation (OFSI). In practice, OFSI now serves as a robust enforcement arm in the UK’s broader economic crime and anti- corruption architecture. It is shifting from a primarily reactive model to a more proactive one, leveraging intelligence, monitoring and outreach to detect non- compliance. In April 2025, the Foreign, Commonwealth & Develop - ment Office updated the UK sanctions list, adding 13 new entries under its global anti-corruption sanctions regime. This demonstrates that the regime is actively maintained and expanded. OFSI has also begun enforcing information-related offences. In May 2025, it imposed a GBP5,000 fine on a UK company (Svarog Shipping & Trading) for fail - ing to respond to a statutory Request for Information. Although the case related to Russia sanctions, it sig - nals that OFSI expects prompt and full co-operation in its inquiries, a principle that transfers into the cor - ruption sanctions space. From a client perspective, these developments carry important implications:
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