POLICY PAPER

Due Diligence Deficiencies, Conflict of Interest Vulnerabilities,

and the Imperative of Adequate Resourcing and Remuneration

With Reference to the Russian Federation, the People’s Republic of China,

the Islamic Republic of Iran, the Republic of Türkiye, and the Republic of Azerbaijan

May 2026

To be considered by both HM Government and Parliamentary Select Committees

Executive Summary

This policy paper seeks to undertake a forensic analysis of the structural weaknesses of the public services architecture of the UK, including the inter-relationship between chronic under-resourcing, absence of due diligence frameworks, and risks of emergence of conflict of interest due to staffing with personnel with previous links with governments in high-corruption jurisdictions. The paper will demonstrate that national security, institutional integrity, and democratic governance of the UK are critically dependent upon a thorough resource provisioning, staffing and remuneration policy framework underpinning public services. Simply committing to “protecting the UK” is structurally incoherent from a forensic analytical perspective, if there is no articulated commitment to the protection and strengthening of its public services architecture.

This paper uses a range of sources which includes Transparency International Corruption Perceptions Index (CPI), the Organised Crime and Corruption Reporting Project (OCCRP), the Institute for Government’s Performance Tracker, the Institute for Fiscal Studies, the UK Bribery Act 2010 legislation and guide to prosecution, records from the UK Parliament and UK intelligence assessment reports. By looking at five governments with known high corruption and human rights abuses the Russian Federation, the People’s Republic of China, the Islamic Republic of Iran, the Republic of Türkiye, and the Republic of Azerbaijan – it demonstrates how employees and contractors of corrupt governments are a potential conflict of interest which has not been considered by vetting and due diligence within the UK.

The conclusion of the paper was that competitive public service funding, with substantial salary increases for public servant police, intelligence, regulatory and front-line service personnel is a national security priority. Targeting increased pay at all levels is expected to draw higher quality candidates, reduce bribery and blackmail, improve employee loyalty and job satisfaction and produce more thorough due diligence and investigative procedures for identifying conflicts of interest with foreign transnational criminals.

1. Introduction: The Foundational Imperative

Over the past decades, discourse from politicians about the prospect of protecting the UK has consistently emphasised external threats, from counter-terrorism to cyber warfare, hostile activity from foreign states to the enforcement of immigration boundaries. While this is certainly a necessary discussion, the following submission will posit that the most dangerous and systemic threat facing the security and integrity of governance in the UK comes from the slow but steady deterioration of the public services framework supporting the very foundations of any defence.

The Institute for Government highlighted that all public services in 2024, excluding schools, suffered worse conditions than in 2010, some of them demanded immediate reforms to avoid their collapse, prisons for example (Institute for Government, 2024a). The Institute for Government remarked that from 2010 to the pandemic, the day to day public spending augmented only in two per cent in real terms, meanwhile, for capital spending, the cuts were “even sharper” (Institute for Government, 2024a). With this continuous austerity, the British police forces, regulatory bodies, border control and anti-corruption services operate in reduced capacities for a long time and in this scenario, undermined due diligence and penetration of conflict of interests conditions thrive.

The MI5 Director General said in a speech in October 2025 that “the state threats we face are escalating”, and that in the past year there had been a 35 per cent increase in the number of individuals MI5 was investigating in relation to state threat activity, including “espionage, including against our Parliament, our universities, our critical infrastructure” (House of Commons Library, 2025). The Director of GCHQ said in a speech in May 2024 that it now devotes more of its resources to the China threat than to any other mission (House of Commons Library, 2025). In light of assessments of these escalation in threats made by the UK intelligence agencies themselves, it is even more important to support and stress the resourcing argument made in this paper. All intelligence agencies whose duty it is to detect and counter the threats require not just incremental but transformational investment in their capacity, capabilities, and people.

This paper argues a very clear and straightforward point. If the political leaders in the United Kingdom feel so passionately about protecting this country, the first and foremost step they should take is to protect and provide resources to the public services which are responsible for protecting the country. Specifically, they should ensure that public services pay is at the level where they can attract and retain the best people to work for them instead of going to the private sector or even worse, receiving financial and economic incentives from foreign countries.

2. The Critical Condition of UK Public Services: A Forensic Assessment

2.1 Fiscal Deterioration and Systemic Underfunding

The overall record of UK public services between 2010 and 2025 is, by any objective measure, one of sustained damage. The Institute for Government’s Performance Tracker 2025 reported that by the summer of 2024, spending on most services had returned to and indeed exceeded 2010 levels, but many were still recovering from deep cuts in the first half of the decade, the most severe having been in local government, criminal courts, and prisons, where spending in real terms had been reduced by between a fifth and a quarter (Institute for Government, 2025). The Institute for Government concluded that this had “severely damaged the long-term productivity of public services” (Institute for Government, 2025).

The Office for Budget Responsibility (OBR) predicted the total public expenditure in 2025–2026 to be GBP 1,368 billion, or approximately GBP 48,000 per household, or 44.8 per cent of national income (OBR, 2026). The net interest payable on national debt would account for GBP 110 billion. The Institute for Government reported that acute services had become the priority for government expenditure as numerous administrations made deep cuts to preventative services and programmes, thus creating a “negative spending spiral in which cuts to preventative services fed increased acute demand and political pressure to fund acute services, leaving governments to contemplate still more cuts to preventative services” (Institute for Government, 2025).

The funding gap faced by local authorities was £4 billion in 2024–25 and £6.2 billion in 2026–27, as estimated by the Local Government Association (Bennett School, 2024). The University of Cambridge’s Bennett School of Public Policy labelled the local authority funding system to be at a “tipping point” (Bennett School, 2024). The Conservative government, now resigned, said the system was “all but broken;” while the Labour government pledged to “repair the foundations” of local authorities (Bennett School, 2024). The above paints a picture of systematic under-supply of resourcing to a public services infrastructure that has direct consequences for the due diligence, vetting and investigative processes covered in this paper.

2.2 Criminal Justice System: A System Under Forensic Stress

For the issues of due diligence and corruption, the most serious example of systemic failure in this country is the criminal justice system. Prisons are at crisis point, with the Institute for Government projecting a 12,000 person increase in the prison population and only 4,400 new prison places to be delivered by end of 2025 (Institute for Government, 2024a). In the fourth quarter of 2023, the probation service, which is a key element of the criminal justice system and the enforcement of regulatory penalties, had a 25 per cent vacancy rate against 10 per cent in 2020 (Institute for Government, 2024a). Policing is characterised by short-term and inconsistent policy and funding, poor retention of staff and persistent gaps in key skills (Institute for Government, 2024a).

The harm done to the criminal justice system weakens the ability of the UK to investigate, prosecute, and generally deter the types of financial crime, corruption, and foreign state interference discussed in this paper, which is a threat to national security. A weakened police and court system will be simply less able to carry out the complex and demanding investigations required of the often opaque corrupt networks, money laundering operations, and conflicts of interest at the highest levels. An example of this is the failed prosecution of two men accused of spying for China, in September 2025. The Crown Prosecution Service discontinued prosecuting the two men, as the government was unable to provide evidence substantive enough to support a prosecution (House of Commons Library, 2025).

2.3 The Remuneration Imperative: Higher Income as a National Security Investment

This paper argues that paying public servants competitive salaries is an investment in national security. The argument rests on four interdependent grounds.

First, the recruitment and capability argument. A report by the Institute for Fiscal Studies revealed that between 2007 and the end of 2023, average real pay in the public sector had decreased by one per cent, contrasted by a gain of four per cent in the private sector (IFS, 2025). For specific professional categories, such as doctors and teachers, the decline in real pay was even sharper after years of pay freezes (IFS, 2025). The IFS report indicated that more than one-fifth of government spending is allocated to pay, making public servants’ remuneration one of the critical factors affecting service quality and institutional capability (IFS, 2024). Among the priorities needing to be addressed, the 2024 Labour Party manifesto identified the public services “recruitment and retention crises” as requiring urgent attention (IFS, 2024). Based on the House of Commons Library report, average public sector pay in April 2025 increased by 5.8 per cent, reflecting recommendations from the Pay Review Bodies accepted by the government (House of Commons Library, 2026). However, the Cabinet Office guidance for 2026–27 directed that Senior Civil Servants should receive a maximum pay increase of 2.5 per cent, with no additional Treasury funding available (LiveBusinessBlog, 2026). The Spending Review 2025 increased day-to-day spending by 3.5 per cent and 4.3 per cent in 2024/25 and 2025/26 respectively to respond to the public services crisis, but departments were advised there would be no additional funding if recommended awards exceeded allocated budgets for 2026/27 (HM Treasury, 2025), and the Institute for Government noted all decisions must be taken in light of a decade of continual underinvestment (Institute for Government, 2025).

Unfortunately, this differential in pay has direct implications for the ability of public services to recruit and retain the calibre of personnel needed to perform the complex due diligence, vetting, financial investigation, and intelligence analysis activities that characterise forensic work. When the best graduates and professionals are drawn to the private sector by significant pay differentials, the ability of the state to conduct investigations and provide protection is fatally compromised.

Second, the anti-corruption resilience argument. A large body of criminological literature demonstrates that public servants who are poorly paid relative to the cost of living and to their counterparts in the private sector are more susceptible to corruption and influence from outside actors (Rose-Ackerman and Palifka, 2016; Transparency International, 2025). Specifically, poorly paid public servants are more likely to be targeted by hostile states, criminal organisations, and corrupt foreign actors who offer financial incentives in exchange for access, information, or discretion on behalf of foreign interests. Higher remuneration materially strengthens the integrity of the public service workforce by increasing the opportunity cost of corrupt conduct.

Third, the institutional morale and retention argument. If experienced public servants depart and take their knowledge, institutional networks, and investigative expertise with them, the ability of the institutions to identify threats and respond appropriately is negatively affected. The cost of allowing this to happen, both from a financial perspective and in terms of operational capacity, will always exceed the cost of ensuring the public servants are paid competitively. The IFS notes that pressure on public sector pay is set to increase, and that “recruiting and retaining more public sector workers, and improving their living standards, will in part require additional expenditure on public sector pay over the course of this parliament” (IFS, 2024).

Fourth, the public service attractiveness argument. If the United Kingdom is to attract the highest calibre individuals to positions of immense responsibility for national security, public safety, and institutional integrity, it must pay at a level that reflects the gravity and complexity of those responsibilities. The current pay structure, which in real terms has been declining relative to the private sector for over a decade, sends the opposite signal: that the state does not value the apparatus that protects it, and does not wish to invest in the people who operate it. This is not merely a question of fairness; it is a question of strategic national capability. A well-remunerated public service is a public service that people aspire to join and remain within, and one that can therefore select from a deep pool of talented, motivated, and incorruptible candidates.

3. Due Diligence Deficiencies: Structural Vulnerabilities in the UK Framework

3.1 The UK Bribery Act 2010 and Enhanced Due Diligence Requirements

The UK Bribery Act (2010) is the most robust anti-bribery legislation in the world. Its six principles of anti-corruption compliance – proportionate anti-bribery procedures; top-level commitment; risk assessment; due diligence; communication and training; monitoring and review – form a model for accompanying legislation and policy (Ministry of Justice, 2011; National Crime Agency, n.d.). Unlimited financial penalties and a term of up to ten years’ imprisonment are applicable to individuals under this legislation (Diligent, 2026). It is contended in this paper that the Act’s due diligence requirements and the procedural vetting and recruitment processes of the UK government are reliant on resources that have been negatively impacted by the service underfunding presented in Section 2.

In the UK, enhanced due diligence is known to apply to politically exposed persons, to high-risk clients or transactions, and to relationships or transactions that involve jurisdictions rated high-risk for corruption or other crime (LexisNexis, n.d.). Compliance literature defines high-risk clients as those whose agents deal with governmental agencies in countries with high corruption perception indexes, requiring enhanced due diligence procedures, such as beneficial ownership, financial, and field inquiries, with continuing diligence procedures (Diligent, 2026). These principles do not seem to translate into current practice when it comes to effective due diligence on individuals who have been employed or contracted by the governments of high-risk jurisdictions and are seeking employment within the UK government or police forces.

3.2 Security Vetting Failures: The Mandelson Precedent

The case of Lord Mandelson’s appointment to a senior diplomatic role highlighted the failures in UK security vetting. On 20 April 2026, the Prime Minister informed the House of Commons that the UK Security Vetting (UKSV) had prepared a report in which it recommended not to grant developed vetting (DV) to Lord Mandelson. The Prime Minister emphasised that it was an operational decision made by officials from the Foreign Office. They had made the decision to grant DV to Mandelson without any political discussion (Hansard, 20 April 2026). The Prime Minister informed the House that if he had known that UKSV recommended not granting the clearance before the appointment of Mandelson, he would not have proceeded with the appointment. The Prime Minister had changed the process of direct ministerial appointments so now “full due diligence is now required as standard” and in case of risks, “an interview must be taken pre-appointment to discuss any risks and conflicts of interest” (Hansard, 20 April 2026).

Three critical failures were highlighted by the case. These were: the ability of departments to override the security vetting authority (UKSV); a lack of political oversight on vetting decisions concerning key appointments; and failure of institutional communications, resulting in the required information not being communicated by the relevant parties to the decision-maker. The Institute for Government found that the errors were “causing serious damage to ministerial-civil service relations” and the allowance for the Foreign Office to grant DV contrary to UKSV advice was a “failure of process” (Institute for Government, 2026). While changes to government protocol resulting from the case, such as the requirement to gain security vetting prior to announcement of an appointment and removal of the Foreign Office’s ability to override the UKSV’s decision, are positive steps, they do not address the systemic vulnerability of the security vetting process arising from lack of resources.

3.3 The Greensill Precedent: Conflicts of Interest and the Revolving Door

The Greensill Capital scandal revealed further shortcomings in the management of conflicts of interest in the UK. Bill Crothers, a senior civil servant, was employed by Greensill Capital as an adviser to its board in September 2015 while still employed by the Civil Service, with the Cabinet Office’s approval, in accordance with its conflicts of interest policy (BBC News, 2021). In the wake of the scandal, the Cabinet Secretary instructed all departments to establish whether any of their senior officials had any undisclosed second jobs or outside interests that could conflict with their duties under the Civil Service Code (BBC News, 2021). The Greensill affair revealed that existing mechanisms, including the Advisory Committee on Business Appointments (ACoBA), were inadequate to prevent conflicts of interest arising from the blurring of boundaries between the public and private sectors.

The Public Administration and Constitutional Affairs Committee (PACAC) stated that the existing framework for conflict of interest management, which includes the Ministerial Code, the Civil Service Code, and ACoBA, is not effective for the scale and complexity of modern conflict of interest circumstances (PACAC, 2017). If the existing framework cannot effectively detect and manage conflicts of interest arising from relationships with private companies, it is unlikely that it can manage foreign state conflicts of interest, especially with high-corruption countries, which are likely to present more complex and more difficult issues to identify.

3.4 Underfunding as a Due Diligence Multiplier

The underfunding of public services directly affects the ability to perform due diligence. When the agencies responsible for vetting, investigation, and enforcement are understaffed, under-resourced, and overworked, the quality of due diligence suffers. Background checks are less thorough, cross-referencing against international databases is cursory, and the capacity to conduct extended investigations into complex financial histories or foreign government affiliations is diminished. This is how individuals with material conflicts of interest—such as prior service to corrupt governments—can slip through the vetting process.

The solution is the resource argument. To ensure that people with past links are not a risk to UK national security and our institutions, the best approach is to ensure that their vetting and investigations are properly funded, properly resourced, and properly staffed. Every pound committed to improving the vetting capability of the UKSV, the National Crime Agency, the Serious Fraud Office, and the intelligence services to carry out proper, forensic due diligence is a gain not measured financially but in terms of the integrity of institutions.

4. Conflict of Interest: Foreign Government Affiliations and Corruption Contamination

4.1 The Analytical Framework: Corruption as Institutional Contamination

This paper argues that a history of employment in a corrupt government or state is a risk factor for conflicts of interest which should result in enhanced due diligence, and in certain cases disqualification from employment in UK government, law enforcement, and sensitive security positions, regardless of citizenship or possession of a passport. This assessment is based on criminological and forensic intelligence research. Those whose careers have spanned corrupt governments or states have necessarily been accomplices to, enablers of, or at a minimum complicit with corrupt practices in order to advance their own careers (Johnston, 2005; Mungiu-Pippidi, 2015). This is not to say that individuals engaged in such conduct are necessarily morally culpable, but this risk factor warrants a thorough assessment in the vetting processes used by the UK. Beyond participation in corrupt practices, foreign government and state employees may have active connections to, or obligations to previous corrupt governments they have served, or be subject to compromise, blackmail or influence operations from corrupt and hostile foreign governments. As a result, their employment poses a direct threat to the integrity of the UK.

The factors that could cause corruption are not eliminated by the acquisition of British citizenship, but are instead transported across jurisdictional borders. The multiple dimensions of conflict of interest contamination are: knowledge (the individual understands corrupt practices and vulnerabilities in the system); relationship (there are existing connections that foreign actors could exploit); allegiance (there may be competing loyalties); and coercion (there could be blackmail or leverage arising from the individual’s prior involvement with corrupt elements in the state apparatus).

4.2 Case Study: The Russian Federation

The UK faces one of its most serious threats to national security from both corruption and hostile intelligence from the Russian Federation. The Corruption Perceptions Index 2025 saw Russia score 22 out of 100, placing it 157th out of 182 countries in the global ranking. This was an all-time low score for Russia, sharing the same rank with Honduras, Zimbabwe, and Chad (Transparency International Russia, 2026). Transparency International stated that “corruption continues to be widespread in Russia due to the lack of independent institutions, government secrecy, and a lack of accountability” and that “the public sector now serves the narrow elite rather than the people” (Transparency International Russia, 2026).

Beginning with its full-scale invasion of Ukraine in 2022, the Russian Federation has been steadily closing all forms of civil society, independent media, and other institutions of accountability. State procurement and spending became increasingly opaque, creating “fertile ground for widespread corruption” according to Transparency International (Transparency International Russia, 2026). Russia remains identified as a direct threat to UK national security as articulated in the National Security Strategy in June 2025, and the UK’s intelligence agencies have been increasingly allocating efforts to countering Russian espionage, influence, and cyber attacks targeting UK infrastructure.

The risks posed by conflict of interest for anyone who has been an employee or contractor of the Russian state are manifest. The Russian state possesses a substantial intelligence community – comprised of the FSB, SVR, GRU and other agencies – which are routinely involved in recruiting, co-opting and if necessary exploiting those with access to Western government departments. As such, anyone who has been an employee or contractor of the Russian state presents a risk to the UK comprising potential current obligations, susceptibility to blackmail, and experience of Russian intelligence techniques. Their presence in UK government or law enforcement agencies constitutes, in the absence of the most rigorous enhanced due diligence, an unacceptable risk to UK national security.

4.3 Case Study: The People’s Republic of China

The corruption and espionage threat from the People’s Republic of China is distinctly difficult. China received a score of 45 on the CPI in 2024, better than the other countries set out in this paper, though this score may completely underestimate the pervasive corruption endemic to the Chinese Communist Party (CCP) due to the closed nature of CCP state institutions and lack of independent reporting in China.

The threat from Chinese state activity is unequivocal in the UK intelligence community. MI5 Director General Ken McCallum stated in October 2025 that threats from other states “are escalating” and cited a 35 per cent rise in the number of state threat investigations by MI5, which includes “espionage, including against our Parliament, our universities, our critical infrastructure” (House of Commons Library, 2025). GCHQ Director Anne Keast-Butler said in May 2024 that the agency was now putting “more resource to China than any other single mission” and China “poses a genuine and increasing cyber risk to the UK” (House of Commons Library, 2025). The UK’s National Security Strategy states in June 2025 that “the instances of China’s espionage, interference in our democracy and the undermining of our economic security have increased in recent years” (House of Commons Library, 2025).

According to a report by AP News (2025), MI5 warned British parliamentarians of espionage by Chinese agents “using LinkedIn profiles to conduct outreach at scale on behalf of Chinese Ministry of State Security.” MI5 had earlier issued a warning in January 2022 of the involvement of a London-based lawyer, Christine Lee, in supplying covert funding from the CCP’s United Front Work Department to British parties and legislators (House of Commons Library, 2025). By 2023, the Bloomsbury Intelligence and Security Institute indicated that more than 20,000 individuals in different high-technology industries had been targeted over LinkedIn for potential industrial espionage (Bloomsbury Intelligence and Security Institute, 2026).

Due to the nature of the ownership and influence model within the Chinese Communist Party, state-owned enterprises, quasi-government research and development institutes, and United Front Work Department organisations, there are especially complex issues pertaining to the conflict of interest assessment for current and former Chinese state officials and affiliated personnel. In many instances, the interests of the Chinese state, Chinese state-owned enterprises, Chinese universities, and other entities connected with the CCP are inseparable. Therefore, all current and former officials and state representatives or persons who have worked within these organisations carry a range of conflict of interest risks, including blackmail risks arising from Chinese intelligence service coercion and compromise, financial ties to CCP-affiliated businesses and interests, and involvement in efforts to obtain and transfer sensitive dual-use technologies and intellectual property on behalf of the state. At a minimum, all identified persons who have served in or with the Chinese government and Chinese state institutions must be required to meet the same enhanced due diligence standards as would be applied for any of the other jurisdictions examined in this paper.

4.4 Case Study: The Islamic Republic of Iran

The unique corruption-threat nexus of the Islamic Republic of Iran is due to the Islamic Revolutionary Guard Corps (IRGC) and its transnational financial networks. In May 2026, the US Financial Crimes Enforcement Network (FinCEN) released an alert on prevalent IRGC sanctions-evasion typologies, covering the use of front companies, financial facilitators and digital assets to launder and evade sanctions (FinCEN, 2026). The US Office of Foreign Assets Control (OFAC) has designated almost 1,000 persons, vessels and aircraft associated with Iran since February 2025 as part of its maximum economic pressure strategy (US Department of the Treasury, 2026).

In May 2026, the UK government imposed sanctions on four members of the Zaringhalam family for their involvement in activities that threatened the UK’s national peace and stability. At least three of the four designated individuals were believed to be based in London. One of the four members, Farhad Zaringhalam, was a UK national with a PhD from King’s College London, was a board member of an oil trading firm in Iran, and had conducted business in Singapore (Iran International, 2026). The US Treasury Department had previously sanctioned the family’s exchange houses for providing funds for laundering activities relating to the IRGC, while one UK-registered digital asset exchange allegedly affiliated with the Zaringhalam family’s network reported over $94 billion worth of transactions (US Department of the Treasury, 2026).

The Iranian case study significantly supports the main thesis of this paper. A British citizen educated at a high-ranking British university and using UK-registered companies had links concurrently to an IRGC-affiliated financial network that had been designated for the financing of terrorism and money laundering. Being a British citizen, having a British education, and having British-registered companies could not prevent the conflict of interests that emerged from that citizen’s connection with a foreign government that has been declared as systematically corrupt and hostile to the interests of the UK. It is also telling that the mechanisms put in place in the UK for due diligence and vetting did not identify such links prior to US enforcement action – this points to the fact that the existing mechanism is simply not adequate.

4.5 Case Study: The Republic of Türkiye

The conflict of interest framework described in this paper is highly correlated with the Republic of Türkiye. The Corruption Perceptions Index (CPI) published in 2025 allocates a score of 31 out of 100 and a rank of 124th out of 182 worldwide. This value defines the weakest CPI score in the history of the Republic, and the trend in the last ten years has been consistently decreasing (Transparency International, 2026a). This CPI score is also inferior to the CPI average values for the region (34) (Eastern Europe and Central Asia) and global (42) values. The Rule of Law Index report published in 2024 by the World Justice Project allocates a rank of 117th out of 142 countries (Turkish Minute, 2025). Transparency International considers that key factors for deterioration of the CPI scores are the weakening of democratic checks and balances, judicial interference by government, diminishing effectiveness of oversight institutions and closing of civic space (Transparency International, 2026a).

Perhaps the most high-profile case of corruption at the state level that implicates Türkiye abroad is the case of Reza Zarrab. Zarrab is a dual citizen of Türkiye and Iran, and was arrested in 2016 in the United States for bank fraud, money laundering, and other charges (OCCRP, 2021). In 2017, Zarrab testified in the case at the US District Court for the Southern District of New York that President Recep Tayyip Erdoğan was aware of and approved bank transactions involved in a sanctions-evasion scheme that prosecutors described as “a fraud of global proportions” (Courthouse News Service, 2020). Zarrab allegedly paid approximately $70 million in bribes to the Turkish economy minister, and the scheme involved the Turkish state-run Halkbank in channelling Iran’s oil profits into international markets (OCCRP, 2021; Bipartisan Policy Center, n.d.).

There are three forensic aspects with respect to the Zarrab case. First, it establishes that there exists high-level corruption of the Turkish state apparatus implicating ministers, state banks, and the president himself as claimed in sworn testimony. Second, there are implications of direct obstruction of justice: when Turkish prosecutors launched investigations into the corruption scandal in December 2013, they were removed from the judiciary (Bipartisan Policy Center, n.d.). Third, it illustrates the global reach of the criminal conspiracy of Turkish state corruption, involving the UAE, UK (Standard Chartered), and Germany (Deutsche Bank) (Duvar English, 2020). Based on leaked US documents available from FinCEN, Deutsche Bank lodged a Suspicious Activity Report regarding a company with direct links to Zarrab. The SAR noted that “the transactions originated from a high-risk country [Turkey]” and that there was “no commercial justification” (Duvar English, 2020). Anyone who has served in the Turkish state apparatus is therefore rendered a high-risk factor for corruption, bribery, and evidence tampering, making the prospect of employment in UK government or positions of trust a non-starter pending a high level of specific enhanced due diligence.

4.6 Case Study: The Republic of Azerbaijan

The case of Azerbaijan is similar and arguably more flagrant. The “Azerbaijani Laundromat” was revealed in September 2017 by the OCCRP and Transparency International. The “Laundromat” was a $2.9 billion slush fund that was created and operated by the elite of Azerbaijan from 2012 to 2014, through four shell companies based in the United Kingdom (Transparency International EU, 2017). Transparency International stated that Azerbaijan is “a country where human rights are routinely threatened and opposition to the government is crushed yet the elites flourish.” The country scored 30 on the Corruption Perceptions Index and ranked 160th on the Press Freedom Index (Transparency International, 2017).

Among other purposes, the laundered money was used for bribing Parliamentary Assembly of the Council of Europe (PACE) members, an institution charged with promoting and ensuring human rights and the rule of law (Transparency International, 2018). Journalists identified several PACE members from Germany, Belgium, Italy, and Spain as the ultimate beneficiaries of the laundered money (Transparency International, 2018). In July 2025, a German court sentenced one former assembly member in connection with the PACE bribery scandal linked to the Azerbaijani Laundromat (Transparency International, 2025c). Transparency International Germany filed criminal complaints against assembly members in March 2019 – according to the indictment, one former assembly member received 3.4 million euros from shell companies between 2008 and 2014 without actually providing any services or doing any work (Transparency International, 2025c).

This is especially pertinent to UK due diligence policy as the shell companies used to launder the $2.9 billion were incorporated in the United Kingdom. This highlights that not only is the Azerbaijani state corrupt at an industrial scale, but it has specifically used the United Kingdom as a jurisdictional vehicle for its corrupt activities. Any individual who has worked with or has been contracted by the Azerbaijani government is at enhanced risk of being or having been complicit with, facilitating, or turning a blind eye to the corrupt activities of the state of Azerbaijan. Such a profile necessitates the highest level of enhanced due diligence.

4.7 Synthesis: The Common Thread Across High-Corruption Jurisdictions

The five case studies discussed above – Russia, China, Iran, Türkiye, and Azerbaijan – share one feature despite their particularities regarding corruption and state threat: corruption is not an exception in a healthy state system for these five countries but a structural reality of their states. They use networks of corruption, coercion, and transnational influence through their intelligence services, financial institutions, and ruling elites, which all target the United Kingdom directly.

Therefore, UK due diligence policy must provide a strong precedent: it is unacceptable to assume that anyone who has previously been a civil servant, adviser to government, or contractor for these governments, or others identified as systemically corrupt, is entitled automatically to be regarded as “clean” by virtue of possessing a British passport. The Civil Service Code requires all civil servants to act with honesty, integrity, objectivity, and impartiality (Cabinet Office, 2015). It is impossible to reconcile these values with the employment of individuals who clearly or presumably have been aligned with states characterised by systemic corruption. The possession of a passport does not make the passage through due diligence any more compatible with these principles than straightforward vetting.

5. The Income and Resourcing Nexus: Why Higher Public Service Pay Protects the Nation

The advanced due diligence investigations that this paper advocates – forensic financial analysis, open-source intelligence assessment, and multi-jurisdictional cooperation required to detect conflicts of interest arising from foreign government affiliations – require personnel with advanced analytical capabilities, linguistic skills, and specialist technical expertise. These are precisely the individuals who are most readily attracted to the private sector, where they can command significantly higher salaries.

When the National Crime Agency, the Serious Fraud Office, UK Security Vetting, GCHQ, and MI5 lose out to consulting firms, law firms, banks, and other commercial entities competing for the same talent at higher salary levels, the state loses the opportunity to employ individuals who could have spent their careers dismantling IRGC-affiliated money laundering operations through UK-registered shell companies, or highlighting instances where applicants for sensitive civil service roles failed to declare connections to the Russian state or other foreign government entities. Instead, those people are employed elsewhere, and the state is left with a diminished, less experienced, and less capable workforce for some of the most consequential national security functions.

Higher salaries for public servants are not a cost but a capital investment in the human capital that is the basis of every function of national protection. The price of fully engaging and paying the workforce of investigators, intelligence analysts, vetters, and front-line service personnel is a trifle compared to the cost of what happens when an under-resourced workforce fails to see the signs: the unreported conflict of interest that compromises a sensitive procurement decision; the foreign intelligence penetration of a government department; the money laundering syndicate that operates through UK banking infrastructure because the agencies empowered to investigate these crimes are understaffed.

Both in the criminological literature focused on corruption prevention and in practice, adequate compensation is a significant buffer against corruption in public officials. In their benchmark work Corruption and Government: Causes, Consequences, and Reform (2016), Rose-Ackerman and Palifka argue that under-compensated public officials tend to be more vulnerable to external financial inducements. Competitive compensation lowers the opportunity cost of corruption (the value of the lawful income sacrificed by engaging in corrupt activities) and diminishes the attractiveness of corrupt offers in comparison with a secure and adequate legitimate salary.

In the threat environment outlined in this paper, in which state-sponsored adversaries of the UK, including Russia, China, Iran, Türkiye, Azerbaijan, and others, seek to influence, recruit, and corrupt those with access to UK government and law enforcement agencies, the pay of public servants is a first-order national security variable. A public servant who is well-paid, able to support a family, and adequately rewarded for the seriousness of their function is materially less likely to be vulnerable to the financial overture of a foreign intelligence officer or corrupt intermediary than one who is increasingly challenged by the cost of living, unable to afford accommodation near their place of work, and considering leaving for a better-paid position in the private sector.

Higher public service remuneration creates a virtuous cycle. Higher salaries attract a larger pool of applicants, enabling more selective hiring. Increased selectivity produces a more capable and more rigorously vetted workforce. A more capable workforce delivers more effective due diligence, investigation, and enforcement. More effective enforcement deters future threats and reduces the burden on the system. A reduced burden permits more thorough investigation of each case. The entire system becomes progressively more capable, more resilient, and less susceptible to the infiltration and corruption risks that are the primary concern of this paper.

In contrast, the existing model – where real pay compression drives attrition, attrition drives loss of capability, loss of capability leads to processing shortcuts, processing shortcuts generate security vulnerabilities, and security vulnerabilities are exploited by adversarial actors – is a vicious cycle that will only compound and undermine the country’s security posture until corrective policy initiatives are employed to reverse it.

6. Policy Recommendations

On the basis of the forensic analysis presented in this paper, the following policy recommendations are advanced for consideration by HM Government and the relevant parliamentary select committees.

6.1 Resourcing and Remuneration

Recommendation 1. HM Government should commit to sustained, above-inflation increases in funding for UK public services, with particular urgency in the criminal justice system, the police, intelligence agencies, and regulatory and anti-corruption bodies, recognising that these serve as the first line of national security.

Recommendation 2. A comprehensive, independent, and transparent review of public service remuneration should be conducted, benchmarking public sector pay against private sector comparators for equivalent skill levels, with the objective of achieving parity or near-parity for positions critical to national security, investigative capacity, and due diligence.

Recommendation 3. A “National Security Workforce Premium” should be introduced for personnel in roles directly involved in counter-espionage, counter-corruption, financial investigation, security vetting, and intelligence analysis, recognising that these functions carry unique responsibilities warranting commensurate remuneration.

Recommendation 4. The decade-long reduction in preventative services must be reversed, with sustained investment in institutional capacity across all public services, recognising that the costs of preventative services foregone are manifested as increases in acute demand and institutional atrophy.

Recommendation 5. Expenditure on training, professional development, and career progression within public services should be increased to ensure that highly skilled personnel have clear incentives to remain in the public sector.

Recommendation 6. Funding for the National Crime Agency, the Serious Fraud Office, and UK Security Vetting should be ring-fenced, ensuring that their investigative and vetting capacity is insulated from annual budgetary pressures and is commensurate with the escalating threat environment documented in this paper.

6.2 Due Diligence and Vetting Reform

Recommendation 7. Mandatory enhanced due diligence (EDD) should be required for all applicants to UK government, law enforcement, or security-sensitive positions who have prior professional affiliations with governments or state entities of jurisdictions scoring below 40 on the Transparency International Corruption Perceptions Index, or designated as posing state threat risks by UK intelligence assessments.

Recommendation 8. Building on the reforms introduced following the Mandelson vetting failure, UK Security Vetting (UKSV) recommendations should not be capable of being overridden by departmental officials without mandatory referral to the relevant Secretary of State.

Recommendation 9. UKSV should be resourced with the personnel, technical infrastructure, and investigative expertise to undertake detailed assessment of foreign government affiliations, including access to international law enforcement databases, liaison with partner country anti-corruption agencies, and the capacity to carry out in-depth forensic financial investigations where complex cross-jurisdictional histories are identified.

Recommendation 10. For individuals in security-sensitive positions who have declared or been found to have prior affiliations with foreign governments, mandatory ongoing monitoring and periodic re-vetting should be required, recognising that conflict of interest risks are not static but may evolve over time.

6.3 Conflict of Interest Framework

Recommendation 11. A statutory presumption of conflict of interest should be introduced for applicants to UK government and law enforcement positions who have served in an official, advisory, or contractual capacity with governments designated as high-corruption risk or state threat risk, with the burden of rebuttal placed upon the applicant to demonstrate, through comprehensive disclosure and investigation, that no material conflict exists.

Recommendation 12. The Civil Service Code and the Ministerial Code should be amended to include explicit provisions addressing conflict of interest risks arising from prior foreign government affiliations, including mandatory disclosure requirements and enhanced scrutiny, with specific reference to the jurisdictions identified in this paper and others posing comparable risks.

Recommendation 13. A Foreign Affiliations Review Panel should be established within the Cabinet Office, with responsibility for assessing conflict of interest risks arising from prior foreign government service, drawing on expertise from UKSV, the National Crime Agency, the Serious Fraud Office, MI5, MI6, GCHQ, and relevant academic and civil society organisations.

Recommendation 14. Legislation should be enacted to ensure that British citizenship does not exempt any individual from enhanced due diligence scrutiny where prior affiliations with high-corruption or state-threat jurisdictions have been identified, and that dual nationals of such jurisdictions are subject to the highest level of vetting for any government or security-sensitive role.

Recommendation 15. An independent review should be commissioned of the adequacy of existing legislation—including the UK Bribery Act 2010, the National Security Act 2023, and the Proceeds of Crime Act 2002—in addressing the specific conflict of interest and corruption contamination risks posed by employing individuals with prior foreign government affiliations in UK public service roles.

7. Conclusion

Protecting the UK is not an abstract goal to be pursued by political rhetoric; it is a forensic operational requirement that depends on the capacity of the institutions that provide protection. The UK’s public services constitute that institutional capacity in its entirety. The analysis in this paper demonstrates that these services have been subjected to a sustained pattern of fiscal attrition that has materially compromised their operational capacity, with particularly severe consequences for the criminal justice system, law enforcement, the intelligence services, and the regulatory and anti-corruption apparatus upon which institutional integrity depends.

The relationship between income and resources discussed in this paper is not tangential to the analysis of conflicts of interest; it is foundational. Higher salaries for public servants attract more capable personnel, strengthen resistance to corruption, improve morale and retention, and ultimately enhance the due diligence and investigative capacities upon which the detection of foreign-linked conflicts of interest depends. The cost of this investment is measurable; the cost of failing to make it—in terms of compromised investigations, undetected conflicts of interest, exploited vulnerabilities, and degraded institutional integrity—is incalculable.

The due diligence and conflict of interest vulnerabilities illustrated by the case studies of the Russian Federation, the People’s Republic of China, the Islamic Republic of Iran, the Republic of Türkiye, and the Republic of Azerbaijan—and the domestic precedents of the Mandelson vetting failure and the Greensill conflict of interest scandal—are not outliers in an otherwise effective system. They are the inevitable outcomes of a system that has been chronically under-resourced. The remedy is not a series of ad hoc procedural reforms but a fundamental reorientation of priorities: recognising that protecting public services, and those who work within them, is the necessary first step in protecting the country.

British citizenship confers many rights and privileges, but it does not and cannot immunise against the risk of institutional contamination posed by previous professional immersion in systemically corrupt state apparatus. The policy recommendations outlined in this paper—spanning resourcing and remuneration, due diligence and vetting reform, and conflict of interest management—provide a comprehensive framework for addressing these risks with the forensic rigour that the protection of UK national security and institutional integrity demands. The question for policymakers is not whether these recommendations are affordable, but whether the nation can afford the consequences of continued inaction.

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