On 16 July 2025, the Insolvency Service released its new five-year strategy towards tackling economic crime facilitated by companies to be implemented between 2026-2031.
Despite an enthusiastic introduction to its plans as ‘ambitious’ and ‘transformational’, the four strategic pillars laid out in the strategy brief – to target more cases involving corporate structures and serious criminality; exploit emerging technology; collaborate closely with public and private sector partners; and recruit, retain and invest in its workforce – echo the agency’s existing commitments, as well as the aims of recently released strategies by adjacent organisations like the FCA, NECC and CPS.
Nevertheless, the Insolvency Service’s continued commitment to existing enforcement measures should still be acknowledged positively, given recent successes. The economic benefits of the agency’s work in disqualifying company directors and shutting down their companies was calculated to be in excess of £50 million between 2024-25.
During this period, the Insolvency Service also secured 77 criminal convictions, more than 1,000 director disqualifications and over £4 million in compensation. The average director disqualification tariff amounted to 8.5 years, with 20% lasting for longer than 10 years, and an estimated net benefit of £36 million to the economy. While these amounts are a tiny fraction of the yearly £10 billion that can be traced from illicit financial activity in the UK, according to the NCA’s 2025 report, the increase in director disqualifications and convictions – from 4 in Summer 2022 to more than 1,000 in 2025 – is a mark of significantly increased activity.
The strategy also mentions the agency’s successes in COVID-19 Bounce Back loan abuse investigations, following on from its inheritance of all remaining viable casework from the National Investigation Service (NATIS) earlier this year.
A director who fraudulently secured a £50,000 Bounce Back loan was convicted and sentenced at Isleworth Crown Court in June 2025. Jagoda Rubaszko, who applied for and received £50,000 for her fake business in 2021, is now disqualified from managing a limited company until 2033. She has been ordered to complete 300 hours of unpaid and made to pay a £2,000 contribution to the Insolvency Service’s prosecution costs.
Perhaps most notably, the Insolvency Service was also able to claw back the £50,000 Bounce Back loan in full by forcing Rubaszko to sell their residential property and motor vehicle in subsequent confiscation proceedings. This particular victory, though small in scale, is indicative of what the Insolvency Service is capable of achieving through swift and focused enforcement action.
The Economic Crime and Corporate Transparency Act 2023 (‘ECCTA’) has introduced the most significant reforms to Companies House since its creation. While the Insolvency Service’s strategy brief is unclear on how its enforcement responsibilities are expanded under the ECCTA, it demonstrates that, through its developing partnership with Companies House, its work will soon be multiplied as a result of the increased powers of Companies House. For instance, from March 2025, Companies House has been able to take swift and decisive enforcement action by:
- Commencing strike off measures if companies do not provide an appropriate address within the specified period (companies are not able to use a Royal Mail PO Box and equivalent services going forward)
- Rejecting appointments of new directors to existing companies where the individual was previously a disqualified director.
- Issuing financial penalties for any relevant offences under the new Act.
- Expediting the strike-off of companies concluded to be formed on a false basis
- Carrying out checks on Authorised Corporate Service Providers (ACSPs) to allow them to carry out verification services on other companies.
Through alerts from Companies House, the Insolvency Service has already initiated investigations into around 2,000 companies relating to the abuse of dormant company status involving directors based overseas with links to tax avoidance, tax evasion schemes and money laundering.
An increased workload, combined with a strategy to recruit and invest in a skilled and effective workforce, may well bring the ‘transformational’ change hoped for in this early stage.
With thank you to Angela Tsui for her assistance in preparing this blog.
About the author
Alun is a partner in the Criminal Litigation team and specialises in serious or complex financial crime, proceeds of crime litigation and corporate investigations. He has particular knowledge and experience of issues surrounding cross-border criminal investigations, corporate crime and deferred prosecution agreements.
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