Yesterday the English Court of Appeal rejected an attempt by Mrs Zamira Hajiyeva to overturn the unexplained wealth order (UWO) obtained by the National Crime Agency against her property in Knightsbridge.

Mrs Hajiyeva was the first person to be made subject to such an order. The wealthy lady's husband, Jahangir Hajiyeva, 58, was the chairman of the International Bank of Azerbaijan (on a salary of £54,000) between 2001 and the time he resigned his post in March 2015, claiming to be in bad health. In December of that year he was arrested in his country and subsequently charged with various offences including misappropriation, abuse of office, large-scale fraud and embezzlement in connection with the bank. He was sentenced to 15 years' imprisonment in 2016.

Ed Smyth, Senior Associate in the Criminal Litigation team at Kingsley Napley LLP, told Compliance Matters: “This decision provides a real boost to the NCA and other agencies in their fight against suspected illicit assets and will likely whet their appetite for more UWOs.

"Since their introduction in 2018, UWOs have not been widely used and this appeal was a test case for whether they could withstand a concerted challenge. We can undoubtedly now expect to see more UWO applications in the coming months and years against HNW individuals with connections to funds of questionable origin.”

Compliance officers and money-laundering reporting officers therefore ought to ready themselves for a fresh round of UWOs.