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 for broad Russian influence in the UK. To a certain extent, this cannot be untangled and the priority now must be to mitigate the risk and ensure that, where hostile activity is uncovered, the tools exist to tackle it at source.

53.The extent to which Russian expatriates are using their access to UK businesses and politicians to exert influence in the UK is ***: it is widely recognised that Russian intelligence and business are completely intertwined. The Government must ***, take the necessary measures to counter the threat and challenge the impunity of Putin-linked elites. Legislation is a key step, and is addressed later in this Report.

54.Several members of the Russian elite who are closely linked to Putin are identified as being involved with charitable and/or political organisations in the UK, having donated to political parties, with a public profile which positions them to assist Russian influence operations. It is notable that a number of Members of the House of Lords have business interests linked to Russia, or work directly for major Russian companies linked to the Russian state – these relationships should be carefully scrutinised, given the potential for the Russian state to exploit them. It is important that the Code of Conduct for Members of the House of Lords, and the Register of Lords' interests, including financial interests, provide the necessary transparency and are enforced. In this respect, we note that the Code of Conduct for Members of Parliament requires that MPs register individual payments of more than £100 which they receive for any employment outside the House – this does not apply to the House of Lords, and consideration should be given to introducing such a requirement. A 'Foreign Agents Registration Act' (an issue which is addressed in the section on Legislation) would also be helpful in this respect.

55.The Government effort on the disruption of Russian illicit financial activity in the UK is led and co-ordinated by the National Crime Agency (NCA). Its work also encompasses the investigation of UK-based professional enablers in the financial and property sectors, with the aim of hardening the UK financial and property markets from the proceeds of crime, and challenging any perception that the UK is a safe haven for illicit funds. The extent to which this money has now been invested, and reinvested, calls into question the efficacy of the recently introduced Unexplained Wealth Orders when applied to the investigation of individuals with such long-established – and to all intents and purposes now apparently legitimate – financial interests in the UK. Whilst the Orders appear to provide the NCA with more clout and greater powers, the reality is that it is highly probable that the oligarchy will have the financial means to ensure their lawyers – a key group of professional enablers – find ways to circumvent this legislation (we return to this issue later in the Report). By contrast, the NCA lacks the resources required in terms of financial investigators, technical experts and legal expertise – this must be rectified.

56.The inherent tension between the Government's prosperity agenda and the need to protect national security that has led to the current situation has been played out across Whitehall departments. However, the formation of the new Serious and Organised Crime (SOC) Group within the Home Office at the end of 2018 was a tangible acknowledgement of economic crime as a national security issue. The SOC Group has a wide-ranging remit – it is hoped that it will be provided with the necessary resources and will give sufficient