Looking Beyond the Headlines – Unexplained Wealth Orders

  • When: 25th June 2020
  • Time: 12PM – 2PM BST
  • Level: All

In recent years the use of UWOs and AFOs by UK authorities has received much publicity. Overall, using UWOs to seek evidence and explanation of large sums of wealth has been received positively both by the public and the media, who generally applaud the deterrent effect of such tools. However, there is a school of thought in the legal profession that the basis of UWOs which involves a partial reversal of the burden of proof goes against the tenet of English law of “innocent until proven guilty”. Should investigative tools place the burden of proof on individuals? What does this mean to large financial institutions who do business with those served with UWOs? From a more practical perspective, what should an financial institution do when a client has been served with an UWO? Are there longer term implications for financial institutions? How are these instruments used in the rest of the world? The webinar discusses answers to all these pertinent questions.

Learning Objectives

  • Understand the power of Unexplained Wealth Orders and Asset Freezing Orders
  • Review recent cases where UWOs are used
  • Explore short term and longer term implications for financial institutions
  • Learn about how financial institutions are cooperating with law enforcement and steps that could advance this cooperation
  • Examine the use of such instruments around the world
  • Hear the presenters’ concluding views on UWOs and AFOs, and their applicability in fighting financial crime

Who Should Attend

  • Wealth managers
  • Firms providing mortgage services
  • Firms providing high value goods
  • Legal firms supporting financial services
  • Legal and second line of defence teams within financial institutions
  • World wide appeal with a focus on UWO implementation in the UK
  • Real Estate Agents


  • UK, Europe, Australia
  • Banking
  • Large financial institutions
  • Private Banks
  • Global banks
  • Legal practitioners
  • Real Estate


ACAMS Members Non-Members
$245 $445
Register Now Join ACAMS


Rajeev Ahya
  • Rajeev Ahya

  • Financial Crime Subject Matter Expert, EMEA


Rajeev has worked in London’s financial markets for over a decade having started his career in the front office with Lloyds Banking Group and subsequently at Barclays Wealth International. In the aftermath of the financial crisis, he worked on various Financial Crime change programs driven by regulatory demand delivering target operating models at Santander and Lloyds. Most recently, he worked in the Commercial Banking Control Function at Lloyds in a Financial Crime advisory capacity with a focus on Correspondent Banking & Financial Institutions.

Since joining ACAMS as a Financial Crime Subject Matter Expert, Rajeev has been extensively involved in research and development of new ACAMS certifications, direction of programming for ACAMS conferences and facilitation & moderation of training; as well as network outreach and thought leadership in the Anti-Financial Crime space.


Shilpa Arora
  • Shilpa Arora

  • Anti-Money Laundering Director, Europe, Middle East and Africa


Shilpa is the AML Director, Europe Middle East and Africa for ACAMS, where she is responsible for the development of regional anti-financial crime content strategy and implementation across all channels. Shilpa also builds and manages the expanding multilingual faculty of leading subject matter experts and instructors who work with ACAMS on curriculum development, instruction, event programming and task forces.  Shilpa represents ACAMS by speaking at select major industry events and conferences, participating in think tanks and engaging proactively with policy makers, regulators and industry practitioners across the region.

Shilpa is an industry expert in financial crime prevention in the financial services sector. She has a strong understanding of risk frameworks and control environments. She is highly regarded for her ability to deliver large scale culture change and transformation in technology and financial crime prevention.

Previously Shilpa was the Head of Financial Crime Prevention for the Retail and Business Bank in Santander UK. She was accountable for all areas of financial crime prevention including KYC/ CDD, customer screening, payment screening, transaction monitoring, customer risk assessment and assurance. She led the bank through the implementation of AML/ CTF and ABC policies, advisory on high risk onboarding, training and communication and risk assessments. She also held leadership roles in Barclays in financial crime prevention, governance and controls and led large transformation programmes.

Shilpa has a background in technology and holds a degree in computer science where she was the top student. She also holds an MBA from Cass Business School which she completed with distinction.

Ben Cowdock
  • Ben Cowdock

  • Investigations Lead
  • Transparency International UK


Ben has been with Transparency International UK for nearly five years and leads their research and investigations into the UK’s role as transit and destination for the proceeds of global corruption. This encompasses working to expand beneficial ownership transparency to give criminals nowhere to hide, strengthening the UK’s defences against dirty money and improving the UK’s asset recovery system to deny the corrupt of their ill-gotten gains.

During his time at Transparency International UK, Ben has researched and written seven reports including “At Your Service” which analysed the role played by UK businesses and institutions in laundering the money and reputations of corrupt individuals and regimes. Ben also conducts investigations into instances of corrupt and suspicious wealth in the UK which are disseminated to law enforcement and regulators as well as published in national media.

Steve Smith


Steve is a partner in the Financial Services Disputes & Investigations group at Eversheds Sutherland (International). He is an experienced criminal litigator and advises individuals and corporate clients in respect of financial crime matters often with cross-jurisdictional impact. He joined Eversheds-Sutherland in December 2018.

He draws on his unusual experience as a defence lawyer, former prosecutor for the Financial Conduct Authority and, most recently, as the Deputy MLRO for a major global financial institution, to defend individuals and corporate clients in financial crime, fraud and regulatory investigations and prosecutions; and advise on financial crime compliance with a particular emphasis on anti-money laundering and anti-bribery systems and controls.

Joe Smith
  • Joe Smith

  • Director, Global Financial Crime Counsel
  • Barclays Bank PLC


Joe Smith is Global Financial Crime Counsel at Barclays.  Based in London, he leads a team of lawyers who provide specialist counsel to Barclays businesses and functions globally on a wide range of complex Anti-Money Laundering, Sanctions and Anti-Bribery & Corruption investigations and advisory matters. 

Joe plays a leading role in the bank’s engagement with UK Government and law enforcement partners on significant AML policy and legislative initiatives, including the Joint Money Laundering Intelligence Task Force, SARS reform and the Criminal Finances Act.

Joe trained as a solicitor at Freshfields Bruckhaus Deringer, qualifying in 2005.