Aziz Rahman of business crime solicitors Rahman Ravelli wonders if the authorities are unsure of the effectiveness of UWOs.

Three unexplained wealth orders (UWOs) have been secured as a result of a National Crime Agency investigation into London property connected to a politically exposed person believed to have links to serious crime.

The UWOs are for three residential properties bought for a total of more than £80M and held by offshore companies. It is the second time that the NCA has obtained a UWO since they became a feature of the UK legal system 18 months ago, under the Criminal Finances Act.

The first UWO was issued last year against two London properties believed to be owned by Jahangir Hajiyev, the jailed former chairman of the International Bank of Azerbaijan, and his wife Zamira Hajiyeva; whose lavish spending in Harrods has been the subject of recent headlines.

The UWOs issued so far have certainly been the subject of mass media coverage. It remains to be seen if this latest one will signal an opening of the floodgates for the NCA, as this time a year ago it was saying it had identified 120 to 140 potential targets for UWOs. If this latest UWO is followed by another long wait until the next one, it may be a sign that the authorities do not believe the orders are a game changer when it comes to targeting the proceeds of crime.

The Serious Fraud Office, HM Revenue and Customs, Financial Conduct Authority and Crown Prosecution Service are yet to use UWOs, even though they can do.

It is also worth considering that the securing of a UWO is only the start of the process. The subject of one can challenge it and while UWOs are a new development, the seizing of the assets that they target relies on civil recovery proceedings, which are nothing new.

You can read more about Unexplained Wealth Orders at our website here:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.