The Insolvency Service has appointed its first dedicated crypto intelligence specialist, Andrew Small (a former police investigator) – marking another addition to the groundswell of crypto awareness from the UK’s law enforcement authorities – responding to the rapid rise in digital assets and electronic money involved in insolvency and enforcement proceedings.
The numbers speak for themselves. According to the latest government figures:
- Over the last five years, the number of insolvency cases where crypto was identified as an asset has increased 420%, from 14 cases in 2019/20 to 59 cases in 2024/25.
- The value of cryptoassets identified by the Insolvency Service has risen from just £1,436 in 2019/20 to £523,580 last year.
These trends are driven by wider market shifts. Crypto adoption in the UK has surged recently, with research from the Financial Conduct Authority (FCA) showing that in 2024, 7 million UK adults (12% of the population) now own crypto, up from 4.4% in 2021.
As the use and popular access to crypto grows, regulators and law enforcement are forced, in parallel, to keep step with the rapid changes to ensure asset tracing and recovery assets do not fall behind the times. Their involvement in contentious cases will of course present new challenges. Issues around ownership, disclosure, jurisdiction, and storage can complicate even the most straightforward recoveries.
The move from the Insolvency Service accompanies similar shifts in gear from other enforcement agencies. For example:
- In April 2025, the HM Treasury unveiled draft legislation explicitly targeting cryptoassets. The proposals include:
- Bringing crypto exchanges, dealers, and agents into the UK regulatory perimeter;
- Imposing transparency, consumer-protection, and resilience standards similar to traditional financial services; and
- Taking action against scams and bad actors in the sector.
- Hot on its heels, in May 2025, the FCA published its first consultation paper setting out its proposed approach to stablecoin issuance and cryptoasset custody (we explored this paper in our previous article from our Financial Services team here).
- In June 2025, the UK government allocated an additional £8 million to the SFO’s budget, with the accompanying press release noting that this funding will strengthen the SFO’s ‘ability to recover criminal assets, including crypto assets, wherever they may be’.
- In July 2025, we saw the first action from the SFO on crypto – with the SFO announcing on 18 July that it had, for the first time, used new powers to freeze the crypto wallet of a suspect in an ongoing criminal investigation.
- In December 2024, the Home Office highlighted the government’s strategy to scale-up the specialist capability of the NCA and ‘partner agencies’ including the recruitment of an additional 475 Financial Crime investigators and developing ‘improved crypto track and trace capability’ which will go live in December 2025.
How can we help?
Tracing and tackling cryptocurrency issues, including in insolvency and fraud cases, requires specialism across the board, combining legal knowledge and forensic accounting skills. Our Business Crime and Investigations and Insolvency teams work together with the support of a former-SFO forensic accountant investigator, Paul Chadwick; ensuring compliance, investigations, and litigation advice is informed by the latest practical expert advice, all in one place.
