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Why UK investigations increasingly cross borders
Money moves freely across borders. People and companies exploit jurisdictional complexity to conceal assets, evade tax, hide beneficial ownership, and escape accountability. The major financial scandals affecting UK actors over the past decade — offshore tax avoidance, beneficial ownership concealment, sanctions evasion — have all had cross-border dimensions that required journalists to work outside the UK to investigate them.
The UK is both a victim and a beneficiary of offshore complexity. The City of London and the UK financial system are major channels for international capital, including capital of questionable provenance. The British Overseas Territories and Crown Dependencies — including the British Virgin Islands, Jersey, and the Isle of Man — are among the world’s most significant offshore centres and are frequently used by UK actors. Investigating these connections requires UK journalists to work with partner organisations in other jurisdictions, access international company registries, and understand how UK regulators interact with their overseas counterparts.
The global investigative journalism networks — ICIJ, OCCRP, EIC.network, and Forbidden Stories — exist precisely because cross-border accountability requires cross-border journalism. UK journalists can both contribute to and benefit from these networks.
International investigative journalism networks
ICIJ
www.icij.orgInternational Consortium of Investigative Journalists
Invitation-only global network behind the Panama Papers, Paradise Papers, and Pandora Papers. UK outlets including the Guardian and FT have participated. Public access: Offshore Leaks database.
OCCRP
www.occrp.orgOrganised Crime and Corruption Reporting Project
Open to credentialed journalists. Operates the Aleph data platform — a searchable archive of leaked and public documents. Strong in Eastern Europe, former Soviet states, and MENA.
EIC.network
eic.networkEuropean Investigative Collaborations
Network of European investigative newsrooms including Der Spiegel, Le Monde, Der Standard, and others. Has included UK partners in cross-border EU investigations.
Forbidden Stories
forbiddenstories.orgForbidden Stories
Continues investigations by journalists who have been silenced, killed, or imprisoned. Also coordinates collaborative investigations such as the Pegasus Project (NSO Group spyware). Paris-based.
UK-linked offshore jurisdictions
British Virgin Islands (BVI)
UK Overseas Territory. One of the world's largest offshore company registration centres. No public beneficial ownership register (as of 2024, despite UK pressure). OpenCorporates holds some historical data. Central to the Panama Papers.
Jersey
Crown Dependency. Financial services centre with a public company registry. Has a beneficial ownership register accessible to law enforcement but not the public. The Jersey Financial Services Commission (JFSC) is the regulator.
Isle of Man (IoM)
Crown Dependency. Has a public company registry. The Isle of Man Financial Services Authority (IoMFSA) is the regulator. Used for both legitimate tax planning and concealment structures.
Cayman Islands
UK Overseas Territory. Major hedge fund and private equity domicile. Beneficial ownership register accessible to law enforcement but not public. Cayman Islands Monetary Authority (CIMA) is the regulator.
Gibraltar
UK Overseas Territory. Has a public company registry. Used for online gambling, crypto, and financial services structures. Financial Services Commission Gibraltar regulates.
When cross-jurisdictional research is essential
- 1A UK company's corporate structure leads you to an offshore subsidiary that cannot be researched through Companies House alone.
- 2A UK individual has assets, companies, or litigation in another jurisdiction that is central to the story.
- 3The story involves sanctions evasion — tracing assets moved through multiple jurisdictions to circumvent UK/EU sanctions.
- 4A source tells you money was moved offshore through a specific jurisdiction — you need to verify through that jurisdiction's registry.
- 5The investigation concerns a pattern of behaviour across multiple countries — requiring parallel reporting partners.
- 6You have a document from a jurisdiction you do not have expertise in — a partner organisation in that country can verify and contextualise it.
Red flags in cross-border corporate structures
- Nominee directors — individuals who appear on company registers as directors but are actually proxies for the real beneficial owner.
- Circular ownership structures — Company A owns Company B which owns Company A — designed to obscure who ultimately controls assets.
- Rapid jurisdictional changes — a company structure that has moved through several offshore jurisdictions in a short period.
- Registered agent addresses shared by hundreds or thousands of companies — a formation agent address rather than a genuine place of business.
- Beneficial ownership information withheld in a jurisdiction that provides limited public access — seek alternative verification routes.
- UK-linked structures involving sanctioned individuals or politically exposed persons (PEPs) from high-risk jurisdictions.
Cross-jurisdictional investigation checklist
- I have mapped the full corporate structure from the UK entity outwards, identifying all subsidiaries, parent companies, and associated entities in each jurisdiction.
- I have searched OpenCorporates for entities in relevant jurisdictions.
- I have searched ICIJ's Offshore Leaks database for any of the entities or individuals involved.
- I have searched OCCRP's Aleph platform for relevant documents.
- I have identified a partner organisation in the key foreign jurisdiction with local knowledge and language capability.
- I have assessed whether collaboration under embargo is appropriate and discussed this with my editor.
- I have checked whether any individuals involved appear on UK, EU, or US sanctions lists.
- I have considered whether to make a referral to the FCA, HMRC, or National Crime Agency alongside publication.
- I have sought legal advice on defamation risk in each jurisdiction where the story will be published or accessed.
Tools for cross-border investigations
Use our FOI Request Builder for domestic document requests that complement your cross-border research, and the Investigation Risk Register to track multi-jurisdiction legal risks.
Common mistakes
- Stopping at the first layer of a corporate structure — beneficial ownership may be three or four layers deep.
- Not checking whether nominee directors are being used — the named directors may not be the real controllers.
- Assuming that because a jurisdiction is a UK Overseas Territory or Crown Dependency, its records are accessible in the same way as UK records — they are not.
- Not seeking legal advice on defamation risk in the foreign jurisdictions where your story will be published or read.
- Failing to coordinate publication timing when working with international partners — staggered publication allows subjects to respond to the first story before the others land.
- Contacting a foreign regulatory body in a way that tips off the subject before publication.
- Relying on translation tools for documents in other languages without having a native speaker verify key passages.
Related guides
Primary sources
- ICIJ Offshore Leaks database — Panama Papers, Paradise Papers, Pandora Papers entities
- OCCRP Aleph — cross-jurisdictional document search
- OpenCorporates — international company database (200+ jurisdictions)
- FATF — Financial Action Task Force jurisdiction risk assessments
- UK Government: Crown Dependencies and Overseas Territories
- Financial Conduct Authority — firm and individual register
- HMRC Fraud Investigation Service — referrals and disclosures
Frequently asked questions
What is OCCRP and how can UK journalists work with it?
How does ICIJ membership work for UK journalists?
What are the most commonly used offshore jurisdictions for UK actors?
How do I search international company registries?
When should I publish versus refer to UK authorities?
Related guides
Primary sources
- ICIJ Offshore Leaks Database— ICIJ
- OCCRP Aleph — Document and Data Platform— OCCRP
- OpenCorporates — Global Company Database (200+ Jurisdictions)— OpenCorporates
- Companies House — PSC Register and Filing History— Companies House
- HMRC — Tax Compliance and Reporting— HMRC
- FATF — Anti-Money Laundering Guidance— FATF
- Global Witness — Investigations into Offshore Finance— Global Witness