International Fraud and Asset Tracing 2025

UK Trends and Developments Contributed by: Sarah Keeling, Piers de Wilde, Dmitry Sachkov and Alexander Greenall, StoneTurn

vanishing offshore. The updated WFO standard has already been cited in other cases heard in English courts to reinforce this simplified test, suggesting we are likely to see an uptick in WFO applications. In the longer run, the ability to lock down assets swiftly before judgment is likely to impact the dynamic of fraud disputes and par - ties’ negotiating strategies. Crypto-Assets and Fraud, Upcoming Sector Regulation According to research by the FCA from Novem - ber 2024, 12% of UK adults owned crypto- assets (cryptocurrencies), with 93% of adults being aware of them. With increasing crypto ownership comes growing exposure to fraud involving crypto-assets. The number of crypto-asset scam reports received by the FCA jumped from 1,527 in the 2019-20 financial year, to 8,588 in 2022-23; the regulator did not publish such statistics in later periods. According to a January 2025 report by the specialised blockchain analysis firm Chain - alysis, crypto scam revenues worldwide have consistently been in the range of USD10-12.5 billion every year since 2021. The same report indicates that in 2024, fraudsters generated most revenue through high-yield investment scams (50.2% of all crypto scams) and romance or investment (also known as “pig butchering” ) scams (33.2%). According to Chainalysis, the latter type of scams saw a particularly sharp increase in 2024 – by 40% year on year. Not least in response to the growing fraud involv - ing crypto, the UK government is advocating to regulate crypto-assets in a similar manner to traditional finance. In November 2024, the Eco - nomic Secretary to the Treasury announced that the government would proceed with establish - ing a new regulatory framework that would bring

certain operations with crypto-assets (including trading, intermediation, lending and custody) under the remit of the FCA. The FCA soon released “Crypto Roadmap” , which stipulates multiple consultations on the future regime to take place before 31 March 2026, with the final rules to be released later that year. In parallel, the government is also looking to introduce new regulated activities for stable - coins (crypto tied to fiat currency), but without bringing them into the perimeter of the existing payments regulations. Minimising risks of fraud is one of the new regime’s objectives declared in the FCA’s dis - cussion paper DP24/4 in December 2024. The regulator emphasised the following desired outcome of the new regulation among others: “Crypto is not attractive for money laundering, fraud, terrorism or any other criminal activity” . If implemented properly, the new regime should make it more difficult to deploy crypto fraud schemes. The FCA is also likely to receive more power to intervene, such as when requiring reim - bursement for fraud victims or freezing crypto accounts of fraud perpetrators. While the new regime parameters are yet to be shaped, the FCA already demonstrated a tough - ening stance on crypto-asset firms when, in July 2024, it took its very first enforcement action against a crypto trading platform. The context here is that such trading platforms (but not oth - er types of organisations working with crypto- assets) which provide services to UK customers are already obliged to register with the FCA and comply with money laundering obligations. The regulator fined Coinbase Payments Ltd (CBPL, part of Coinbase Group) over GBP3.5

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