The UK Government has published its much anticipated Anti-Corruption Strategy. You may be asking yourself, is it any good?

On the whole, yes. This is a Strategy that sets out the Government’s plans to tackle domestic and international corruption, and lays out a vision for where it wants the UK to be on this issue.

Of course, there are places where Transparency International and the Bond Anti-Corruption Group, of which I am co-chair, feel that the Strategy is off the mark, or could have gone much further.

Here’s TI’s summary of how the Strategy fares:

THE GOOD

• Scope: The breadth and remit of the Strategy covers both domestic and international corruption, and shows how the two elements meet.

• Focus on domestic corruption: Many people think corruption is something that only happens ‘elsewhere’. If only that were true. UK citizens may not have to pay a bribe every time they visit the doctor or report a crime – as is often the case in some countries – but our research has unearthed problems in many areas such as prisons, property, and local government. These manifestations can be subtle and are often hidden from public view, but the consequences can be severe. The Strategy is forthcoming about the domestic risks, and highlights four UK sectors where the Government believes the risk of ‘insider threat’ is particularly problematic: defence, borders, prisons & probation, and the police. The narrative here is strongly linked to national security – which is an obvious Home Office lens. The Home Office will need to ensure that sectors which don’t have a direct impact on national security should still be prioritised if information comes to light that implicates them as corruption hotspots.

• It knows what it doesn’t know: The Strategy displays a good understanding of the gaps in knowledge when it comes to mapping the corruption risks across UK sectors, and sets out a plan to build a concrete evidence base, including reiterating the 2014 Anti-Corruption Plancommitment to launch a corruption reporting mechanism in the UK.

• Rhetoric on Trade: There is evidence that including anti-corruption and transparency provisions in trade deals works – to lower costs, alleviate information asymmetries, and improve market confidence and activity – and the UK must ensure that it doesn’t bow to any pressure to forgo these provisions to secure new deals post Brexit. The Strategy contains welcome assurances that the UK will prioritise anti-corruption provisions in any future trade agreements and ensure that the UK’s place in the world after Brexit is founded on integrity and rule of law.

• Leadership: The Strategy announces the appointment of a new Anti-Corruption Champion after a six month vacancy, and creates a new Ministerial position in the Home Office to lead the charge in tackling economic crime.

• The Strategy also has good things to say on open contracting and strengthening government procurement.

THE BAD

• UK Politics: The Strategy is dishearteningly off the mark when it comes to the corruption risks in, and the government record on, UK politics. There’s no mention of the multiple scandals, or the glaring holes in the rules that govern parliamentary behaviour. The Lobbing Act is dressed up as a success, rather than legislation that took the status quo back a step. This will do nothing to alleviate the public perception of political complacency on this issue.

• Overseas Territories: While the Strategy stated that it was the Government’s ‘ambition to ensure all countries adopt public registers’, there was no indication that moves would be made to ensure that territories such as the BVI and Cayman Island do so. Given the UK’s leadership in creating the Persons of Significant Control Register, the Government can and should further cement the global norm by requiring the Overseas Territories to publish a similar public register.

• Corporate Liability: Following the Strategy’s launch, TI and many of our colleagues in the Bond Anti-Corruption Group expressed serious disappointment that the Government has once again kicked the SFO’s plea for a stronger criminal corporate liability offence for economic crime into the long grass. The new Minister for Economic Crime should make it a priority to ensure that the results of the Call for Evidence on the need for law reform are published as soon as possible.

• Golden Visas: The Strategy makes no provision for addressing the corruption risks associated with the UK’s Tier 1 investor visa system. The Government should use the forthcoming Immigration Bill to ensure that those buying residency in the UK pass the strictest due diligence checks.

THE FENCE

There are a few areas that show promise but where only time will tell whether the Strategy commitments will secure necessary change:

• Property register: At the 2016 Anti-Corruption Summit, the Government committed to introduce legislation on the true owners of overseas companies owning UK companies or bidding for government contracts, by April 2018. The good news is that the Strategy recommits to implementing the register. However, the next move announced is a draft bill – rather than the promised legislation – a curious decision, as cross party support for the register has already been demonstrated in parliament. The draft bill should be laid before parliament without delay.

• Business: The retention of the Serious Fraud Office as a key enforcement agency and recognition of its important role in fighting bribery, and the rhetoric on trade agreements are welcome. However, while a step forward, the changes to the AML system of supervision don’t go far enough to ensure that professional enablers will be held to account for facilitating corrupt transactions. The Strategy reaffirms some good commitments on extractives transparency. Hopefully the Government will act on recent proposals from mainstream civil society to address difficulties affecting the UK EITI process.

• New set up: The Joint Anti-Corruption Unit has moved to the Home Office, but retained its cross-government remit. This could turn out to be a very positive move, but the Home Office will have to ensure that JACU’s international remit isn’t side-lined by departmental priorities.

• Annual reporting to Parliament: This is a positive step forward, and my hope is that this report will consist of more than just a written statement that invites no parliamentary scrutiny, such as questions from the floor. Only time will tell.

Overall, this Strategy is an encouraging signal that the Government recognises the threat that corruption poses to UK society, and the world. Of course, as with all strategies, the proof of this will be in the action that is taken in the following months and years. Transparency International will be watching closely.