From Luxury Shopping Sprees to Legal Scrutiny
How Unexplained Wealth Orders Unraveled a Financial Mystery
In 2023, Zamira Hajiyeva was sentenced to prison after years of legal scrutiny into how she acquired millions in luxury assets.
She wasn’t caught with stacks of illicit cash or fleeing from law enforcement — instead, it started with questions. How could the wife of a state bank chairman, earning a modest official salary, afford a £15 million home in London’s Knightsbridge, a private golf club in Ascot, and a £16 million shopping spree at Harrods?
The answer? She couldn’t — at least not legally. And that’s where the UK’s first-ever Unexplained Wealth Order (UWO) came into play.
The Case That Shook the Compliance World
In 2018, Hajiyeva made headlines as the first individual to face a UWO under new UK anti-corruption powers. Investigators focused not on what she bought — but how she could afford it. The numbers didn’t add up. Her husband, Jahangir Hajiyev, was already serving time in Azerbaijan for fraud and embezzlement, and soon, attention turned to her.
Over the course of ten years, she had spent eye-watering sums at Harrods:
£32,000 on chocolates
£24,000 on tea and coffee
£5.75 million on jewellery
Plus luxury flights on private jets
None of this aligned with any legitimate, verifiable source of income.
When she failed to provide a satisfactory explanation, the UK’s National Crime Agency moved to seize the properties. In 2023, a final court ruling upheld the forfeiture — and Hajiyeva herself was sentenced to jail for breaching bail conditions tied to the investigation.
What Is an Unexplained Wealth Order (UWO)?
A UWO is a powerful legal tool that allows UK authorities to demand that individuals explain how they acquired assets that appear disproportionate to their known income. It flips the traditional burden of proof:
“You don’t have to prove a crime. They have to prove the wealth is legitimate.”
For compliance professionals, UWOs are a formal extension of what due diligence aims to do every day: ensure that wealth and transactions make sense, and are traceable to lawful origins.
The Role of Source of Wealth in Modern Compliance
Zamira Hajiyeva’s story might be extreme — but it reflects a common and crucial pattern: unexplained wealth is often the first clue that something isn’t right.
That’s why Anqa Compliance urges institutions to go beyond surface-level checks. Our Enhanced Source of Wealth (SoW) and Source of Funds (SoF) Guidelines outline how to assess the origin of both a customer’s broader financial standing (SoW) and the immediate source behind specific transactions (SoF).
These checks are essential, especially when:
A customer’s lifestyle doesn’t match their declared income
Assets are held through complex or offshore structures
There’s reliance on unverifiable gifts or vague business income
You’re dealing with Politically Exposed Persons (PEPs)
Why It Matters in Africa and Asia
In many African and Asian jurisdictions, wealth can be held or transferred through informal systems, family networks, or cash-based economies. That doesn’t mean the wealth is illegal — but it makes verification harder.
That’s exactly why Anqa tailors its compliance resources to reflect these realities:
Tools for assessing SoW from family businesses or diaspora remittances
Guidance for verifying land or asset ownership in jurisdictions with limited registries
Enhanced risk flags for sectors prone to corruption (natural resources, construction, NGOs)
Don’t Wait for a Scandal
Not every client will have a £10M golf club in Ascot — but every financial institution will, at some point, face a decision: does this wealth make sense?
As regulators around the world sharpen their focus on beneficial ownership, sanctions evasion, and illicit fund flows, SoW/SoF checks are no longer a “nice to have.” They are frontline defense tools.
🔍 Want to avoid the next financial mystery?
Train your team to spot the red flags before regulators do.
Download Anqa’s SoW/SoF checklist — or explore our free AML tools, designed for compliance teams across emerging markets.
