Who are the enablers of secrecy?

Global financial secrecy requires a large infrastructure of lawyers, accountants, bankers, trust and company formation agents and other professionals, the intermediaries who make the whole system function. In many small secrecy jurisdictions expatriate professionals constitute a significant share of the population.  

While the market has thousands of players, the room at the top is surprisingly limited. Global accounting is still dominated by the "Big Four" firms of accountants, while a small number of "capital city" and haven‐based law firms in the so-called "Offshore Magic Circle" dominate the lawyering. As our report The Price of Offshore, Revisited makes clear, global private banking is dominated by fewer than 50 multinational banks.

These stem from household names such as HSBC and UBS, to lesser known companies.  

International rules seeking to tackle the problem of secrecy rarely target these private intermediaries, even in the rare cases where prosecutions can be brought against their clients, however this is starting to change.  

The United States has launched a number of criminal investigations against major banks for their role in tax evasion and money laundering. The most high profile of these was the case against  BNP Paribas for its facilitation of money laundering on behalf of countries subject to US sanctions, Iran, Cuba and Sudan. After entering into a plea bargain, BNP Paribas was subject to a $8.9bn fine.  

In 2015 the UK government announced a new criminal office of failing to prevent tax evasion, or the facilitation of tax evasion, the law implementing this new offence was passed in 2017, and it is still too early to assess its effectiveness.  

Following the Panama Papers leak of information in 2016, several authorities around the world are investigating Mossack Fonseca, the law firm at the centre of the controversy.   

Read more on our dedicated page about the intermediaries, here, and in our summary of recent developments, here.