Witting and unwitting: The hidden role of trusted professions in organised crime

By Hol Thomas-Wrightson, 6 July 2026

In March 2026, ICA Course Director Ben Jones held an inCONVERSATION discussion with Andy Clarke, a former police officer and anti money laundering (AML) & anti-bribery expert. Clarke’s previous work saw him convict professional enablers who abused their positions in order to hide beneficial ownership behind offshore structures. 

Clarke’s experience in this space, plus his work in recovering vast sums of criminal assets and helping to re-shape English law to close loopholes and prevent future reoccurrences, provided key insights for this discussion about organised crime’s manipulation of people in professional positions – whether they realise it or not. 

What is a professional enabler?

On the surface, Clarke explains, the phrase ‘gatekeeper’ seems to cover the same list of people: lawyers, accountants, financial advisors, corporate service providers. These professionals, as guardians of routes into the financial system, make an excellent target for criminals looking to launder money. The key differentiator is that while ‘gatekeeper’ is a neutral description of their role, ‘professional enabler’ refers to those professionals that – whether through deliberate, reckless, or negligent action – help criminals to access and abuse these systems. 

It is worth noting that there is some dispute over whether the term professional enabler should be reserved only for those that take proactive steps to help criminals, as opposed to those that do so by accident, through negligence or poor compliance. 

The question of culpability

In light of this distinction, Jones poses the natural next question: how do you tell the difference between a professional that is deliberately complicit, one who has been deliberately misled by a criminal, or one who just isn’t asking the right questions?

Clarke directed learners to Dr Katie Benson, – a previous contributor on in CONVERSATION – and her book Lawyers and the Proceeds of Crime for a more in-depth analysis. He refers to her description of the ‘degree of knowingness’ when trying to distinguish where someone sits on the scale of criminal culpability. 

He reminds us that even with ever-increasing awareness, investigation, and concerted efforts to implement policies, procedures and training, we still only know a fraction of the money laundering that takes place. A lot of organised criminals employ professional money launderers that have developed effective schemes for adapting to and overcoming every control that we put in place. Even regulators know and recognise this fact, with many acknowledging that a zero-failure regime is not realistic to expect.

Therefore, you cannot make the assumption that if it has happened, someone must be an (active) professional enabler. However, we do need to consider the level of involvement. For instance, when the professional relationship gets stretched to the point where calls are happening way outside of working hours, there are suspicious levels of possessiveness over a client, or indicators of bribery hidden behind gifts and hospitality. 

Criminal coercion and seduction

Jones considers how the majority of professionals likely never intend to commit or allow anything criminal to happen on their watch, and yet find themselves compromised. He asked for Clarke’s perspective of how they may end up being corrupted. 

Clarke explains that it often starts small. Little persuasions through gifts, taking them out for meals or to expensive sports events to say thank you for a small indiscretion, or to lead them towards doing something that benefits the criminal. This slowly ascends until the professional becomes reliant on the benefits the criminal can offer. 

On the other side of the coin, it can also be a slippery slope where the professional is persuaded to commit a minor transgression, a slight bending of the rules, but which gives the criminal something that works as blackmail, or as a way for them to call in favours to replay complicit actions. 

Barriers against manipulation

Many countries have legislation against the risks of bribery, giving guidance and limitations on what can be accepted as 'reasonable' in terms of gifts and hospitality. This also empowers managers and colleagues to recognise cases of failure to report and disclose. 

These professionals are also regulated, and as such regulators have put pressure on organisations to make sure their compliance culture, controls, policies and procedures focus on these risks and on stamping them out. This all adds up to make it harder for criminal behaviours to slip under the radar, and easier for evidence to be uncovered when individuals fail to comply. 

Spotting deception

Clarke emphasises the importance of recognising when a client is being suspiciously evasive of providing important documentation. ‘There can be remarkable stories… for why you haven’t got it’, he says, with incredibly inventive reasoning for why someone can’t supply, say, evidence of their source of funds. ‘But professionals need to be robust, and not afraid to say, “I need you to provide [this] documentation… and if you can’t, we can’t continue this relationship.”’ 

Culture shift

With the UK Financial Conduct Authority (FCA) recently taking over AML regulation for solicitors and accountants, Clarke warns that there is likely to be a culture clash. The challenge comes from the fundamental differences in how supervision manifests for financial services verses law firms and accountants, and in how their relationships with clients look. It is not as simple as mirroring the same rules and approaches that would work within banks.

Ignorance is bliss

Jones asks a final question: how often, in recovering criminal assets, were professionals found to be truly ignorant of the crimes they have been used to commit?

In Clarke’s experience, he saw a lot of cases where there was blatant negligence, such as in real estate purchases (a known favourite area for criminals to use for money laundering) that had none of the necessary documentation, and the proper procedures just were not followed. 

In contrast, he has seen cases where on the surface, the documents are apparently all present and accounted for, but are fraudulently manufactured and hide potentially huge sums of criminally-derived funds. This illustrates clearly that sliding scale of culpability, how negligence can be a mask for responsibility, and the importance of due diligence.