Enablers of Illicit Finance: a Conceptual Framework

Enablers of corruption and financial crime more broadly have been increasingly gaining attention in public, policy-making, and scholarly discourse. Major exposes such as the Panama Papers, Pandora Papers and the FinCEN Files have made headlines in mainstream media and highlighted the role that individuals and firms play in facilitating the movement of funds and formation of companies used to hide and benefit from illicit funds (Arshinoff, Humphreys et al. 2022). Policy-makers and regulators in governments, multilateral organizations, and industry standard-setting bodies have hastened to devise programmes to rein in the enablers of illicit finance and a body of academic research to study enabling has emerged (see, for example, Heathershaw et al., 2025). Yet there is little consensus among policy-makers and scholars as to the conceptual scope of the terms ‘enabler’ and ‘enabling’ Often, the term is used to refer to certain professions that are gatekeepers to the financial system–primarily lawyers and accountants. However, recent cases demonstrate the importance of other types of professional individuals and firms such as consultancies, private wealth managers, rental and travel agents (see, for example, Canaya, 2023; News Agencies, 2020). All of these actors have the potential to enable criminals to enjoy the proceeds of their crimes, but not all are regulated for money laundering or have global-level industry standard setting bodies that oversee illicit finance. Better understanding of the types of stakeholders that enable illicit finance is necessary to “disable” the enablers of illicit finance. The article provides three significant contributions to the existing literature on enablers of illicit finance. First, it unpacks the concept of enablers, and its relation to cognate concepts such as gatekeepers, intermediaries and facilitators. It bridges the gap between siloed discussions on the topic in legal, economic, political, development, sociological and behavioural literature as well as policy discussions and interventions. Second, the paper offers a conceptually robust definition of an enabler and enabling in the context of illicit finance. The new definition identifies those actors that willingly or negligently allow individuals and corporations to hide, move, protect, launder, invest or enjoy the benefits of illicitly obtained or transferred funds, resulting in economic, social or political harm. Third, the article provides a theoretical framework to understand and respond to enablers of illicit finance based on their functional role, motivational drivers and the harms caused. The framework is aimed to guide regulators as to the appropriateness of varying regulatory responses in different scenarios. It specifically considers regulatory approaches at the international level, including international external regulation–such as the FATF Standards and their application to different industries at the national level–as well as industry supervision and oversight structures at the international level. The article draws on a survey of the academic and grey literature on enabling, including governments’ and law enforcement agencies’ policies; non-governmental organisations’ and think tanks’ publications as well as statements and reports produced by professional industry standard setters.