Unexplained Wealth Orders: Powerful Tools to Investigate Financial Crime in the UK

What are UWOs?

Unexplained Wealth Orders (UWOs) were introduced pursuant to the Criminal Finances Act 2017 in the UK to strengthen UK proceeds of crime regimes. UWOs allow for the confiscation of property without proving criminality by reversing the burden of proof, i.e. the respondent of a UWO have to prove that the property was obtained through legitimate means. UWOs are issued when there is reasonable ground to suspect that either:

• The person or organisation’s known sources of income would not be sufficient to obtain the property, or
• The property was obtained through unlawful conduct.

UWO powers, which serve as an investigatory tool and not a final recovery remedy, are available to five enforcement agencies in England and Wales: Crown Prosecution Service (CPS), Financial Conduct Authority (FCA), His Majesty’s Revenue and Customs (HMRC), National Crime Agency (NCA) and Serious Fraud Office (SFO).

Why is there an increase in UWO cases?

Recently, we have seen an increase in headlines-grabbing UWOs. This is likely to be a result of the expansion of the UWOs’ scope of the powers under the UK Economic Crime (Transparency and Enforcement) Act (ECTE), effective 15 March 2022, making it easier to target assets held by Politically Exposed Persons (PEPs) or criminals using complex structures.

UWOs will continue to be powerful tools to investigate those who look to use, move or hide their proceeds of crime in the UK and enforcement is expected to remain on an upward trajectory.

Recent UWO cases

• London Property Portfolio (CPS, 2026)^[1]: The CPS secured its first UWO and Interim Freezing Order (IFO) over a London property portfolio valued at more than £81 million. The High Court granted the orders based on suspicion regarding the source of funds used to acquire 85 properties across central and South London. ‍
• Lake District Case (SFO, 2025)^[2]: The first SFO-issued UWO which saw the freezing of a Lake District property allegedly acquired with the proceeds of a £100 million fraud. The property, whose estimated value was approximately £1.5 million, is owned by Claire Schools, the ex-wife of Timothy Schools, who was imprisoned in 2022 following his conviction for fraud. ‍
• NCA v GKC (No. 1) (NCA, 2025 – 2026)^[3]: In 2025, the NCA obtained a UWO and IFO in respect of assets belonging to a graduate student worth approximately £6 million, including two UK properties and multiple UK bank accounts. The basis of the UWO and IFO in this case was that the graduate student is believed to be connected to a $2 billion money laundering investigation in Singapore. An application to challenge the orders was rejected by the High Court in 2026. ‍
• Zamira Hajiyeva Forfeiture (2024 – 2025)^[4]: The NCA’s first UWO in 2018 resulted in the forfeiture of two luxury properties; a house in Knightsbridge worth £14 million and a golf club in Ascot worth £10.5 million, both owned by the wife of jailed Azerbaijani banker, Jahangir Hajiyev.

Lessons learned

1. Strengthen Customer Due Diligence: Conduct enhanced due diligence on individuals or organisations where anomalies and red flags appear, including performing additional checks on the ultimate beneficial owner (UBO), sources of wealth and funds, exposure to sanctions, etc.
2. Adopt a risk-based approach: Firms, especially those in the regulated sector, must adopt a risk-based approach to Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT), involving the identification, assessment and mitigation of risks associated with different customer types and transactions. Management and compliance officers should conduct regular risk assessments to review their exposure to AML/CFT risks.
3. Ongoing monitoring: A robust AML and CFT compliance programme should include the ongoing monitoring of customer activities and transactions for unusual activities or risks. Risks are not static, and as such, AML/CFT procedures should evolve based on changing risk exposure.
4. Identifying the legitimate origin of money: Source of Funds (SOF) and Source of Wealth (SOW) are critical AML concepts; however, they are not the same. SOF seeks to identify the origin of money for a specific transaction, noting that there is no fixed number of “hops” or transfers when tracing the funds back to its origin, but instead aims to trace the money back to a legitimate verifiable origin; whilst SOW seeks the explanation of how a person accumulated their total net worth.

Conclusion

As enforcement efforts continue, individuals and organisations are reminded of the importance of AML/CFT controls as the burden of proof is on those who are served a UWO.