In an article published in the Fall 2025 issue of the Bulletin of the International Academy of Financial Crime Litigators, Andrew Dornbierer explores the revival of unexplained wealth orders (UWOs) in the United Kingdom.

Introduced in 2017 as a tool to combat the abuse of UK's markets to launder criminal proceeds, the UWO mechanism suffered a severe setback in 2020. After only a handful of attempts to use it, a decision by the High Court effectively left it sprawled on the canvas.

Criminals exploit legal loopholes, borders and other avenues to conceal the proceeds of their illegal activities and evade prosecution. Meanwhile, they use their illicit proceeds to buy luxury villas or increase their power and influence. Victims of crime – including communities affected by corruption – suffer the losses.

Only a handful of states have been actively pursuing the enforcement of foreign bribery. Switzerland is one of them and its efforts to crack down on this offence is commendable.

Between 2011 and 2024, Switzerland issued 14 final judicial orders at a federal level against Swiss-linked companies that engaged in foreign bribery. In these proceedings, the companies were ordered to hand over approximately CHF 730 million (combined) in illicit profits that they had obtained through their foreign bribery schemes, and an additional CHF 30 million in fines.