Company registration number 05716642 (England and Wales)
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
ANNUAL REPORT AND FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2025
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
COMPANY INFORMATION
Directors
Mr P K Mukundan
Mr M C Howlett
Mr C F Mody
Mr E Jolivet
Mrs J A Knights
Mr D J Cuckney
Secretary
Mr M C Howlett
Company number
05716642
Registered office
Cinnabar Wharf
26 Wapping High Street
London
E1W 1NG
Auditor
Gravita Audit II Limited
Aldgate Tower
2 Leman Street
London
E1 8FA
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
CONTENTS
Page
Strategic report
1 - 2
Directors' report
3 - 4
Independent auditor's report
5 - 8
Statement of comprehensive income
9
Balance sheet
10
Statement of changes in equity
11
Statement of cash flows
12
Notes to the financial statements
13 - 25
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
STRATEGIC REPORT
FOR THE YEAR ENDED 31 DECEMBER 2025
- 1 -

The directors present the strategic report for the year ended 31 December 2025.

Review of the business

CCS is a company limited by guarantee providing advice to businesses around the world on the prevention and response to commercial crime and malpractice. The sectors in which it provides this advice include shipping, trade, trade finance, banking and intellectual property. It also runs FraudNet, a network of lawyers in around 70 countries specialising in recovery of losses due to fraud.

 

CCS meets its day to day working capital requirements from its own cash flow.

 

96% of its income comes from membership subscription. Other income streams include investigations and conferences.

 

CCS’s turnover was £5.37m in 2025 compared to £5.34m in 2024. Furthermore, the 2025 surplus decreased to £0.96m compared to £1.05m in 2024. Income generated from memberships has remained consistent with prior years.

 

In the years leading up to 2015, CCS had seen a significant increase in its business which it managed within existing infrastructure and resources. To continue to meet service standards to clients, it was necessary to upgrade its resources, particularly IT infrastructure and software development. Expenditure has increased since 2017 as a result. The key items of increased expenditure were increase in staff costs and IT costs, and the increase in associated costs of creating a third office in Dubai.

 

Despite the unprecedented increase in the business over the past years, the Board of CCS remain of the view that the business may not continue to rise in the medium term. Turnover increased marginally in 2025 by 0.7% compared to 2024, with administrative expenses rising by 5.9% across the same period. The Board intends that CCS will always operate at a surplus and will fund its expenses through its cash flow.

Credit control is closely monitored and managed. Our membership income is largely invoiced in advance of the subscription period and all subscriptions are closely monitored. All major items of expenditure and most other expenses are all approved by the members of the Board.

 

In March 2018, CCS received its ISO 27001/2013 certification – now revised to ISO 27001/2022. CCS passed its seventh annual external ISO audit in May 2025 and is also Cyber Essentials Plus certified.

 

Given all the circumstances, the Board is satisfied with the financial performance of CCS but continues to seek new areas for diversification.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
STRATEGIC REPORT (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 2 -
Principal risks and uncertainties

One of CCS’s important contributors to its revenue has been the provision of advice on the fraud risk in trade finance. This has been driven by enforcement of regulation in countries where CCS clients operate. It is expected that the regulations will remain in place or be strengthened. Nevertheless, with severe competition in trade finance for its clients, CCS clients are constantly looking to reduce costs in an increasingly digital and uncertain world. This will continue to impact the CCS business model.

 

Other general factors of risk remain:

  1. Technology. FinTech and RegTech products, and new disruptive technologies such as AI and Blockchain threaten the traditional ways in which trade finance is done.

  2. Staff. As with all similar organisations, fully trained competent staff are key to the smooth operation of CCS’s business. A loss of a significant number of important members of the CCS team could have an adverse impact on its performance in the short term.

     

  3. Uncertainty over China trade volumes. CCS clients based in Asia providing trade finance have been affected by the downturn in volumes of trade into and out of China. This has led to a reduction in the compliance work referred to CCS by these banks.

  4. External factors such as COVID 19, which may create general uncertainty.

     

  5. Geo-political risk. Uncertainties caused by the ongoing tensions in Ukraine and the Middle East.

  6. Data sources. The ready availability and accessibility of reliable sources of information.

Development and performance

The provision of due diligence services to banks are evolving with new online platforms being tested and improved. CCS recognises that there are challenges ahead and continues to develop its own plans to counter this by offering fully integrated solutions to members.

Legal and compliance

CCS is advised by professional advisors on employment, health, governance and safety matters. It maintains its procedures, contracts and working environment in compliance with their advice.

In addition, CCS is subject to various UK and EU legal and compliance regulations. CCS takes its responsibilities in this area seriously and ensures that its policies, systems and processes are continually updated to comply with legal requirement in the sectors it operates in.

Mr M C Howlett
Director
17 April 2026
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
DIRECTORS' REPORT
FOR THE YEAR ENDED 31 DECEMBER 2025
- 3 -

The directors present their annual report and financial statements for the year ended 31 December 2025.

Principal activities

The principal activity of the company continued to be that of providing advice to businesses around the world, on the prevention and response to commercial crime and malpractice.

Branches

The company has two branches, ICC International Maritime Bureau (Far East Regional Office), which is based in Kuala Lumpur and ICC Commercial Crime Services (FZ Branch), which is based in DMCC, Dubai.

Results

The results for the year are set out on page 9.

Directors

The directors who held office during the year and up to the date of signature of the financial statements were as follows:

Mr P K Mukundan
Mr M C Howlett
Mr C F Mody
Mr E Jolivet
Mrs J A Knights
Mr D J Cuckney
Financial instruments
Treasury operations and financial instruments

The company’s principal financial instruments include investments and cash at bank, the main purpose of which is to raise finance for the company’s operations. In addition, the company has various other financial assets and liabilities such as trade debtors and trade creditors arising directly from its operations.

Liquidity risk

The company manages its cash and borrowing requirements in order to maximise interest income and minimise interest expense, whilst ensuring the company has sufficient liquid resources to meet the operating needs of the business.

Interest rate risk

The company is exposed to fair value interest rate risk on its fixed and floating rate bank deposits.

Foreign currency risk

The company’s principal foreign currency exposures arise from the operation of its overseas branches and its trading with overseas companies.

Credit risk

Investments of cash surpluses are made through investment houses and banks, which must fulfil credit rating criteria approved by the board.

 

All customers who wish to trade on credit terms are subject to credit verification procedures. Trade debtors are monitored on an ongoing basis and provision is made for doubtful debts where necessary.

Research and development

The company has a dedicated quality control and research department. It looks at current trends in shipping and trade risks, primarily this is aimed at analysis of the growing CCS database. The results of the analysis are fed back to clients via bulletins and quarterly reports. CCS's IT platforms are regularly updated based upon feedback from clients and other users.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
DIRECTORS' REPORT (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 4 -
Post reporting date events

There are no post reporting date events.

Future developments

The company expects to continue providing its current services to its members. It closely reviews the areas of risk to its business, which may be caused by factors outside of its control. The company is looking to develop new services to the shipping and trading environment.

Statement of directors' responsibilities

The directors are responsible for preparing the annual report and the financial statements in accordance with applicable law and regulations.

Company law requires the directors to prepare financial statements for each financial year. Under that law the directors have elected to prepare the financial statements in accordance with United Kingdom Generally Accepted Accounting Practice (United Kingdom Accounting Standards and applicable law). Under company law, the directors must not approve the financial statements unless they are satisfied that they give a true and fair view of the state of affairs of the company and of the surplus or deficit of the company for that period.

In preparing these financial statements, the directors are required to:

The directors are responsible for keeping adequate accounting records that are sufficient to show and explain the company’s transactions and disclose with reasonable accuracy at any time the financial position of the company and enable them to ensure that the financial statements comply with the Companies Act 2006. They are also responsible for safeguarding the assets of the company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.

Statement of disclosure to auditor

So far as each person who was a director at the date of approving this report is aware, there is no relevant audit information of which the company’s auditor is unaware. Additionally, the directors individually have taken all the necessary steps that they ought to have taken as directors in order to make themselves aware of all relevant audit information and to establish that the company’s auditor is aware of that information.

On behalf of the board
Mr M C Howlett
Director
17 April 2026
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
INDEPENDENT AUDITOR'S REPORT
TO THE MEMBERS OF ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
- 5 -
Opinion

We have audited the financial statements of ICC Commercial Crime Services (a Company Limited by Guarantee) (the 'company') for the year ended 31 December 2025 which comprise the statement of comprehensive income, the balance sheet, the statement of changes in equity, the statement of cash flows and notes to the financial statements, including significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including Financial Reporting Standard 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland (United Kingdom Generally Accepted Accounting Practice).

In our opinion the financial statements:

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor's responsibilities for the audit of the financial statements section of our report. We are independent of the company in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, including the FRC’s Ethical Standard, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Conclusions relating to going concern

In auditing the financial statements, we have concluded that the directors' use of the going concern basis of accounting in the preparation of the financial statements is appropriate.

 

Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the company's ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.

 

Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of this report.

Other information

The other information comprises the information included in the annual report other than the financial statements and our auditor's report thereon. The directors are responsible for the other information contained within the annual report. Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon. Our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the course of the audit, or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact.

 

We have nothing to report in this regard.

Opinions on other matters prescribed by the Companies Act 2006

In our opinion, based on the work undertaken in the course of our audit:

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
INDEPENDENT AUDITOR'S REPORT (CONTINUED)
TO THE MEMBERS OF ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
- 6 -
Matters on which we are required to report by exception

In the light of the knowledge and understanding of the company and its environment obtained in the course of the audit, we have not identified material misstatements in the strategic report or the directors' report.

 

We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 requires us to report to you if, in our opinion:

Responsibilities of directors

As explained more fully in the directors' responsibilities statement, the directors are responsible for the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal control as the directors determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, the directors are responsible for assessing the company's ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the directors either intend to liquidate the company or to cease operations, or have no realistic alternative but to do so.

Auditor's responsibilities for the audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

The extent to which our procedures are capable of detecting irregularities, including fraud, is detailed below.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
INDEPENDENT AUDITOR'S REPORT (CONTINUED)
TO THE MEMBERS OF ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
- 7 -

We ensured that the engagement team collectively had the appropriate competence, capabilities and skills to identify or recognise non-compliance with applicable laws and regulations. The laws and regulations applicable to the company were identified through discussions with directors and other management, and from our commercial knowledge and experience of ICC Commercial Crime Services. Of these laws and regulations, we focused on those that we considered may have a direct material effect on the financial statements or the operations of the company, including the Companies Act 2006, taxation legislation, data protection, anti-bribery, anti-money-laundering, employment and health and safety. The extent of compliance with these laws and regulations identified above was assessed through making enquiries of management and inspecting legal correspondence. The identified laws and regulations were communicated within the audit team regularly and the team remained alert to instances of non-compliance throughout the audit.

 

We assessed the susceptibility of the company’s financial statements to material misstatement, including obtaining an understanding of how fraud might occur, by:

 

To address the risk of fraud through management bias and override of controls, we:

 

In response to the risk of irregularities and non-compliance with laws and regulations, we designed procedures which included, but were not limited to:

 

There are inherent limitations in our audit described above. The more removed that laws and regulations are from financial transactions, the less likely it is that we would become aware of non-compliance. Auditing standards also limit the audit procedures required to identify non-compliance with laws and regulations to enquiry of the directors and other management and the inspection of regulatory and legal correspondence, if any. Material misstatements that arise due to fraud can be harder to detect than those that arise from error as they may involve deliberate concealment or collusion.

A further description of our responsibilities is available on the Financial Reporting Council’s website at: https://www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor's report.

Use of our report

This report is made solely to the company's members, as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006. Our audit work has been undertaken so that we might state to the company's members those matters we are required to state to them in an auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the company and the company's members as a body, for our audit work, for this report, or for the opinions we have formed.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
INDEPENDENT AUDITOR'S REPORT (CONTINUED)
TO THE MEMBERS OF ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
- 8 -
Luke Metson
For and on behalf of Gravita Audit II Limited
17 April 2026
Chartered Accountants
Statutory Auditor
Aldgate Tower
2 Leman Street
London
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
STATEMENT OF COMPREHENSIVE INCOME
FOR THE YEAR ENDED 31 DECEMBER 2025
- 9 -
2025
2024
Notes
£
£
Income
3
5,374,095
5,335,097
Cost of sales
(743,084)
(733,017)
Gross surplus
4,631,011
4,602,080
Administrative expenses
(4,379,658)
(4,135,739)
Other operating income
80,286
80,893
Operating surplus
4
331,639
547,234
Interest receivable and similar income
8
469,790
362,398
Fair value gains/(losses) on financial instruments
9
308,406
236,711
Surplus before taxation
1,109,835
1,146,343
Tax on surplus
10
(164,878)
(110,598)
Surplus for the financial year
944,957
1,035,745
Other comprehensive income
Tax relating to other comprehensive income
13,145
13,145
Total comprehensive income for the year
958,102
1,048,890

The comprehensive income has been prepared on the basis that all operations are continuing operations.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
BALANCE SHEET
AS AT
31 DECEMBER 2025
31 December 2025
- 10 -
2025
2024
Notes
£
£
£
£
Fixed assets
Tangible assets
11
2,428,908
2,512,779
Investments
12
4,719,301
4,376,040
7,148,209
6,888,819
Current assets
Debtors
13
2,474,565
2,237,645
Cash at bank and in hand
11,479,830
10,727,907
13,954,395
12,965,552
Creditors: amounts falling due within one year
14
(5,574,596)
(5,277,845)
Net current assets
8,379,799
7,687,707
Total assets less current liabilities
15,528,008
14,576,526
Provisions for liabilities
Deferred tax liability
15
332,212
338,832
(332,212)
(338,832)
Net assets
15,195,796
14,237,694
Reserves
Revaluation reserve
977,058
1,016,494
Income and expenditure account
14,218,738
13,221,200
Total members' funds
15,195,796
14,237,694

These financial statements have been prepared in accordance with the provisions relating to medium-sized companies.

The financial statements were approved by the board of directors and authorised for issue on 17 April 2026 and are signed on its behalf by:
Mr M C Howlett
Director
Company registration number 05716642 (England and Wales)
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
STATEMENT OF CHANGES IN EQUITY
FOR THE YEAR ENDED 31 DECEMBER 2025
- 11 -
Revaluation reserve
Income and expenditure
Total
£
£
£
Balance at 1 January 2024
1,055,930
12,132,874
13,188,804
Year ended 31 December 2024:
Surplus
-
1,035,745
1,035,745
Other comprehensive income:
Tax relating to other comprehensive income
13,145
-
0
13,145
Total comprehensive income
13,145
1,035,745
1,048,890
Transfers
(52,581)
52,581
-
Balance at 31 December 2024
1,016,494
13,221,200
14,237,694
Year ended 31 December 2025:
Surplus
-
944,957
944,957
Other comprehensive income:
Tax relating to other comprehensive income
13,145
-
0
13,145
Total comprehensive income
13,145
944,957
958,102
Transfers
(52,581)
52,581
-
Balance at 31 December 2025
977,058
14,218,738
15,195,796
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
STATEMENT OF CASH FLOWS
FOR THE YEAR ENDED 31 DECEMBER 2025
- 12 -
2025
2024
Notes
£
£
£
£
Cash flows from operating activities
Cash generated from operations
22
485,797
993,178
Income taxes paid
(116,630)
(78,287)
Net cash inflow from operating activities
369,167
914,891
Investing activities
Purchase of tangible fixed assets
(2,802)
(4,228)
Proceeds from disposal of tangible fixed assets
(23,048)
(11,507)
Purchase of investments
(417,833)
(1,000,000)
Proceeds from disposal of investments
391,504
-
Interest received
424,112
362,398
Other income received from investments
10,823
7,242
Net cash generated from/(used in) investing activities
382,756
(646,095)
Net increase in cash and cash equivalents
751,923
268,796
Cash and cash equivalents at beginning of year
10,727,907
10,459,111
Cash and cash equivalents at end of year
11,479,830
10,727,907
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2025
- 13 -
1
Accounting policies
Company information

ICC Commercial Crime Services (a Company Limited by Guarantee) is a private company limited by guarantee incorporated in England and Wales. The registered office is Cinnabar Wharf, 26 Wapping High Street, London, E1W 1NG.

1.1
Basis of preparation

These financial statements have been prepared in accordance with FRS 102 “The Financial Reporting Standard applicable in the UK and Republic of Ireland” (“FRS 102”) and the requirements of the Companies Act 2006.

The financial statements are prepared in sterling, which is the functional currency of the company. Monetary amounts in these financial statements are rounded to the nearest £.

The financial statements have been prepared under the historical cost convention, modified to include certain financial instruments at fair value and certain tangible fixed assets held at depreciated, revalued amounts. The principal accounting policies adopted are set out below.

The entity is a Company Limited by Guarantee, and a 'not-for-profit organisation.' As such, the Company has disclosed a 'surplus or deficit,' rather than a 'profit or loss account.'

 

Management have concluded that the financial statements present a true and fair view and have complied with accounting standards and applicable legislation.

1.2
Going concern

Atruet the time of approving the financial statements, the directors have a reasonable expectation that the company has adequate resources to continue in operational existence for the foreseeable future. Thus the directors continue to adopt the going concern basis of accounting in preparing the financial statements.

1.3
Income and expenditure

Income and expenses are included in the financial statements as they become receivable or due, net of VAT.

 

The Company's income is generated through the provision of services to its members. Income is mainly derived through membership fees, which provides customers a set number of enquiries they are permitted to use over a specified period of time. As all enquiries permitted may or may not be utilised by the customer, the volume used cannot be predicted from the outset of the membership period. In accordance with the applicable financial reporting framework, the contract value for membership fees is therefore recognised on a straight line basis evenly over the life of the membership period.

 

For the Company's other revenue streams, such as investigations, seminars, and hologram, revenue is recognised by reference to the stage of completion, when the stage of completion, costs incurred and costs to complete can be estimated reliably.

1.4
Tangible fixed assets

Tangible fixed assets are initially measured at cost and subsequently measured at cost or valuation, net of depreciation and any impairment losses.

Depreciation is recognised so as to write off the cost or valuation of assets less their residual values over their useful lives on the following bases:

Long leasehold land and buildings
straight line over 50 years on the building and 25 years on the refurbishment costs
Plant and equipment
straight line over 3 years for computers and 5-10 years for other office furniture and fittings
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
1
Accounting policies
(Continued)
- 14 -

The gain or loss arising on the disposal of an asset is determined as the difference between the sale proceeds and the carrying value of the asset, and is credited or charged to surplus or deficit.

1.5
Fixed asset investments

Fixed asset investments are initially measured at transaction price excluding transaction costs, and are subsequently measured at fair value at each reporting date. Changes in fair value are recognised in surplus or deficit. Transaction costs are expensed to surplus or deficit as incurred.

1.6
Impairment of fixed assets

At each reporting period end date, the company reviews the carrying amounts of its tangible assets to determine whether there is any indication that those assets have suffered an impairment loss. If any such indication exists, the recoverable amount of the asset is estimated in order to determine the extent of the impairment loss (if any). Where it is not possible to estimate the recoverable amount of an individual asset, the company estimates the recoverable amount of the cash-generating unit to which the asset belongs.

Recoverable amount is the higher of fair value less costs to sell and value in use. In assessing value in use, the estimated future cash flows are discounted to their present value using a pre-tax discount rate that reflects current market assessments of the time value of money and the risks specific to the asset for which the estimates of future cash flows have not been adjusted. If the recoverable amount of an asset (or cash-generating unit) is estimated to be less than its carrying amount, the carrying amount of the asset (or cash-generating unit) is reduced to its recoverable amount. An impairment loss is recognised immediately in surplus or deficit, unless the relevant asset is carried at a revalued amount, in which case the impairment loss is treated as a revaluation decrease.

Recognised impairment losses are reversed if, and only if, the reasons for the impairment loss have ceased to apply. Where an impairment loss subsequently reverses, the carrying amount of the asset (or cash-generating unit) is increased to the revised estimate of its recoverable amount, but so that the increased carrying amount does not exceed the carrying amount that would have been determined had no impairment loss been recognised for the asset (or cash-generating unit) in prior years. A reversal of an impairment loss is recognised immediately in surplus or deficit, unless the relevant asset is carried at a revalued amount, in which case the reversal of the impairment loss is treated as a revaluation increase.

1.7
Cash and cash equivalents

Cash at bank is a basic financial asset and include deposits held at call with banks, other short-term liquid investments with original maturities of three months or less.

1.8
Financial instruments

The company has elected to apply the provisions of Section 11 ‘Basic Financial Instruments’ and Section 12 ‘Other Financial Instruments Issues’ of FRS 102 to all of its financial instruments.

 

Financial instruments are recognised in the company's balance sheet when the company becomes party to the contractual provisions of the instrument.

 

Financial assets and liabilities are offset, with the net amounts presented in the financial statements, when there is a legally enforceable right to set off the recognised amounts and there is an intention to settle on a net basis or to realise the asset and settle the liability simultaneously.

Basic financial assets

Basic financial assets, which include debtors and bank balances, are initially measured at transaction price including transaction costs and are subsequently carried at amortised cost using the effective interest method unless the arrangement constitutes a financing transaction, where the transaction is measured at the present value of the future receipts discounted at a market rate of interest. Financial assets classified as receivable within one year are not amortised.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
1
Accounting policies
(Continued)
- 15 -
Other financial assets

Other financial assets, including investments in equity instruments which are not subsidiaries, associates or joint ventures, are initially measured at fair value, which is normally the transaction price. Such assets are subsequently carried at fair value and the changes in fair value are recognised in surplus or deficit, except that investments in equity instruments that are not publicly traded and whose fair values cannot be measured reliably are measured at cost less impairment.

 

Impairment of financial assets

Financial assets, other than those held at fair value through surplus and deficit, are assessed for indicators of impairment at each reporting end date.

 

Financial assets are impaired where there is objective evidence that, as a result of one or more events that occurred after the initial recognition of the financial asset, the estimated future cash flows have been affected. If an asset is impaired, the impairment loss is the difference between the carrying amount and the present value of the estimated cash flows discounted at the asset’s original effective interest rate. The impairment loss is recognised in surplus or deficit.

 

If there is a decrease in the impairment loss arising from an event occurring after the impairment was recognised, the impairment is reversed. The reversal is such that the current carrying amount does not exceed what the carrying amount would have been, had the impairment not previously been recognised. The impairment reversal is recognised in surplus or deficit.

Derecognition of financial assets

Financial assets are derecognised only when the contractual rights to the cash flows from the asset expire or are settled, or when the company transfers the financial asset and substantially all the risks and rewards of ownership to another entity, or if some significant risks and rewards of ownership are retained but control of the asset has transferred to another party that is able to sell the asset in its entirety to an unrelated third party.

Classification of financial liabilities

Financial liabilities are classified according to the substance of the contractual arrangements entered into.

Basic financial liabilities

Basic financial liabilities, including creditors and bank loans are initially recognised at transaction price unless the arrangement constitutes a financing transaction, where the debt instrument is measured at the present value of the future receipts discounted at a market rate of interest. Financial liabilities classified as payable within one year are not amortised.

 

Debt instruments are subsequently carried at amortised cost, using the effective interest rate method.

 

Trade creditors are obligations to pay for goods or services that have been acquired in the ordinary course of business from suppliers. Amounts payable are classified as current liabilities if payment is due within one year or less. If not, they are presented as non-current liabilities. Trade creditors are recognised initially at transaction price and subsequently measured at amortised cost using the effective interest method.

Derecognition of financial liabilities

Financial liabilities are derecognised when the company’s contractual obligations expire or are discharged or cancelled.

1.9
Taxation
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
1
Accounting policies
(Continued)
- 16 -

The tax currently payable is based on taxable surplus for the year. Taxable surplus differs from net surplus as reported in the profit and loss account because it excludes items of income or expense that are taxable or deductible in other years and it further excludes items that are never taxable or deductible. The company’s liability for current tax is calculated using tax rates that have been enacted or substantively enacted by the reporting end date.

1.10
Employee benefits

The costs of short-term employee benefits are recognised as a liability and an expense.

 

The cost of any unused holiday entitlement is recognised in the period in which the employee’s services are received.

 

Termination benefits are recognised immediately as an expense when the company is demonstrably committed to terminate the employment of an employee or to provide termination benefits.

1.11
Retirement benefits

Payments to defined contribution retirement benefit schemes are charged as an expense as they fall due.

The company has established a trust for the benefit of employees and certain of their dependants. Monies held in the trust are held by independent trustees and managed at their discretion.

 

Where monies held in the trust are determined by the company (on the basis of employees past services to the company), and the company can obtain no future economic benefit from these monies, such monies, whether in the trust or accrued for by the company, are charged as an expense as they fall due.

1.12
Leases
As lessee

Rentals payable under operating leases, including any lease incentives received, are charged to income and expenditure on a straight line basis over the term of the relevant lease except where another more systematic basis is more representative of the time pattern in which economic benefits from the leases asset are consumed.

1.13
Foreign exchange

Transactions in currencies other than pounds sterling are recorded at the rates of exchange prevailing at the dates of the transactions. At each reporting end date, monetary assets and liabilities that are denominated in foreign currencies are retranslated at the rates prevailing on the reporting end date. Gains and losses arising on translation are included in the income and expenditure account for the period.

2
Judgements and key sources of estimation uncertainty

In the application of the company’s accounting policies, the directors are required to make judgements, estimates and assumptions about the carrying amount of assets and liabilities that are not readily apparent from other sources. The estimates and associated assumptions are based on historical experience and other factors that are considered to be relevant. Actual results may differ from these estimates.

 

The estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognised in the period in which the estimate is revised where the revision affects only that period, or in the period of the revision and future periods where the revision affects both current and future periods.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
2
Judgements and key sources of estimation uncertainty
(Continued)
- 17 -
Key sources of estimation uncertainty

The estimates and assumptions which have a significant risk of causing a material adjustment to the carrying amount of assets and liabilities are as follows.

Land and buildings

The building element of the long leasehold property has been estimated to be 80% of the total cost.

Valuation of land and buildings

The key estimation judgement is the fair value assessment of the land and building which has been based on a professional valuation using market values of comparable properties in the area. The value included at 31 December 2025 is £2,406,298. Please refer to note 12.

3
Income

An analysis of the company's income is as follows:

2025
2024
£
£
Income analysed by class of business
Membership fees
5,132,261
5,145,976
Investigations
122,648
91,465
Seminars
73,552
49,082
Other income
7,134
10,074
Hologram
38,500
38,500
5,374,095
5,335,097
2025
2024
£
£
Income analysed by geographical market
United Kingdom
508,974
330,120
European Union
310,361
269,263
Rest of the world
4,554,523
3,490,063
5,374,095
4,089,446
2025
2024
£
£
Other operating income
Recognised income - donations
87,075
92,059
Piracy
(6,182)
(4,628)
80,893
87,431
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
3
Income
(Continued)
- 18 -
2025
2024
£
£
Other income
Interest income
469,790
362,398
4
Operating surplus
2025
2024
Operating surplus for the year is stated after charging:
£
£
Depreciation of tangible fixed assets
86,673
90,028
Loss on disposal of tangible fixed assets
23,048
11,507
Operating lease charges
69,766
65,169
5
Auditor's remuneration
2025
2024
Fees payable to the company's auditor and associates:
£
£
For audit services
Audit of the financial statements of the company
39,000
36,000
6
Employees

The average monthly number of persons (including directors) employed by the company during the year was:

2025
2024
Number
Number
Directors
3
3
Managers
6
6
Administrative
2
2
Analysts/information officers
63
63
Total
74
74

Their aggregate remuneration comprised:

2025
2024
£
£
Wages and salaries
2,552,792
2,441,238
Social security costs
180,926
152,628
Pension costs
186,883
178,548
2,920,601
2,772,414
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 19 -
7
Directors' remuneration
2025
2024
£
£
Remuneration for qualifying services
444,834
429,500
Company pension contributions to defined contribution schemes
112,200
108,691
557,034
538,191

The number of directors for whom retirement benefits are accruing under defined contribution schemes amounted to 3 (2024 - 3).

Remuneration disclosed above include the following amounts paid to the highest paid director:
2025
2024
£
£
Remuneration for qualifying services
116,333
110,000
Company pension contributions to defined contribution schemes
44,800
53,642
Accrued lump sum at the end of the year
74,000
74,000
8
Interest receivable and similar income
2025
2024
£
£
Interest income
Interest on bank deposits
422,978
362,398
Other interest income
46,812
-
0
Total income
469,790
362,398
2025
2024
Investment income includes the following:
£
£
Interest on financial assets not measured at fair value through surplus or deficit
422,978
362,398
9
Fair value movements on financial instruments
2025
2024
£
£
Fair value gains/(losses) on financial instruments
Gain on financial assets held at fair value through profit or loss
308,406
236,711
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 20 -
10
Taxation
2025
2024
£
£
Current tax
UK corporation tax on surplus for the current period
132,323
90,600
UK tax on EBT
26,030
19,998
Total current tax
158,353
110,598
Deferred tax
Origination and reversal of timing differences
6,525
-
0
Total tax charge
164,878
110,598

The actual charge for the year can be reconciled to the expected charge for the year based on the surplus or deficit and the standard rate of tax as follows:

2025
2024
£
£
Profit before taxation
1,109,835
1,146,343
Expected tax charge based on the standard rate of corporation tax in the UK of 25%
277,459
286,586
Tax effect of expenses that are not deductible in determining taxable profit
23,565
21,711
Tax effect of income not taxable in determining taxable surplus
(106,474)
(308,297)
Tax on investment income
(62,227)
90,600
Effect of revaluations of investments
6,525
-
Employee benefit trust payment charge
26,030
19,998
Taxation charge for the year
164,878
110,598

In addition to the amount charged to the profit and loss account, the following amounts relating to tax have been recognised directly in other comprehensive income:

2025
2024
£
£
Deferred tax arising on:
Revaluation of property
(13,145)
(13,145)
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 21 -
11
Tangible fixed assets
Long leasehold land and buildings
Plant and equipment
Total
£
£
£
Cost or valuation
At 1 January 2025
2,570,000
216,205
2,786,205
Additions
-
0
2,802
2,802
At 31 December 2025
2,570,000
219,007
2,789,007
Depreciation and impairment
At 1 January 2025
81,851
191,575
273,426
Depreciation charged in the year
81,851
4,822
86,673
At 31 December 2025
163,702
196,397
360,099
Carrying amount
At 31 December 2025
2,406,298
22,610
2,428,908
At 31 December 2024
2,488,149
24,630
2,512,779

Long leasehold land and buildings were revalued on 29 November 2023 by Dunsin Surveyors, independent valuers not connected with the company on the basis of market value. This valuation conformed to RICS Property Measure Professional Standards and Guidance, which incorporates the International Property Measurement Standards and was based on recent market transactions on arm's length terms for similar properties.

 

Long leasehold land and buildings are therefore now carried at depreciated, revalued amount of £2,406,298. If land and buildings were measured using the cost model, the carrying amounts would have been approximately £1,103,553 (2024: £1,132,823), being cost of £1,660,771 (2024: £1,660,771) and depreciation of £557,218 (2024: £527,948).

 

12
Fixed asset investments
2025
2024
£
£
Listed investments
4,719,301
4,376,040
Fixed asset investments revalued

Listed investments include investments held with Coutts & Co. and LGT Wealth Management. These funds have been used to invest in UK and overseas corporate bonds, as well as cash and alternative cash investments. At the reporting date, listed investments are held at their market value, in according with the valuation reports prepared by both Coutts & Co. and LGT Wealth Management.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
12
Fixed asset investments
(Continued)
- 22 -
Movements in fixed asset investments
Investments
£
Cost or valuation
At 1 January 2025
4,376,040
Additions
417,833
Valuation changes
282,077
Service charge fees
(10,823)
Income transferred from capital
45,678
Disposals
(391,504)
At 31 December 2025
4,719,301
Carrying amount
At 31 December 2025
4,719,301
At 31 December 2024
4,376,040
13
Debtors
2025
2024
Amounts falling due within one year:
£
£
Trade debtors
1,924,335
1,810,810
Other debtors
20,689
56,149
Prepayments and accrued income
529,541
370,686
2,474,565
2,237,645
14
Creditors: amounts falling due within one year
2025
2024
£
£
Trade creditors
358,298
362,139
Corporation tax
132,745
91,022
Other taxation and social security
102,543
96,560
Other creditors
801,704
761,597
Accruals and deferred income
4,179,306
3,966,527
5,574,596
5,277,845
ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 23 -
15
Deferred taxation
Liabilities
Liabilities
2025
2024
Balances:
£
£
Deferred tax on revaluation
325,687
338,832
Investments
6,525
-
332,212
338,832
2025
Movements in the year:
£
Liability at 1 January 2025
338,832
Charge to profit or loss
6,525
Credit to other comprehensive income
(13,145)
Liability at 31 December 2025
332,212

Deferred tax relates to the revaluation of the long leasehold land and buildings and the unrealised gains on listed investments.

 

The £325,687 (2024: £338,832) deferred tax liability has been calculated at a rate of 25% on the revaluation gain of long leasehold land and buildings. Furthermore, £6,252 (2024: £nil) has been calculated at a rate of 25% on unrealised gains arising from the remeasurement of listed investments to fair value at the reporting date.

 

These gains give rise to temporary differences between the carrying amounts of the assets in the financial statements and their tax bases, as the gains are not taxable until realised. The deferred tax liability will crystallise upon sale or disposal of these assets.

 

 

16
Retirement benefit schemes
2025
2024
Defined contribution schemes
£
£
Charge to profit or loss in respect of defined contribution schemes
186,883
178,548

The company operates a defined contribution pension scheme for all qualifying employees. The assets of the scheme are held separately from those of the company in an independently administered fund.

17
Members' liability

The company is limited by guarantee. Not having a share capital and the liability of members being limited, subject to an undertaking by each member to contribute to the net assets or liabilities of the company on winding up, such amounts may be required but not exceeding £10.

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 24 -
18
Income and expenditure account

The company is limited by guarantee. Not having a share capital, if on a winding up there remains after the satisfaction of all its debts and liabilities, any property whatsoever, the same shall not be paid to or distributed among the members of the company. It shall be given or transferred to some other institution or institutions having objects similar to the objects of the company and in so far as effect cannot be given to such provision, then to some charitable object.

19
Other commitments

The company is obligated to pay certain costs totalling £270,608 due within 1 year and £248,057 due within 2 to 5 years.

20
Operating lease commitments
As lessee

At the reporting end date the company had outstanding commitments for future minimum lease payments under non-cancellable operating leases, regarding office rentals, which fall due as follows:

2025
2024
£
£
Within 1 year
70,182
57,947
Years 2-5
80,318
69,693
150,500
127,640
21
Related party transactions

During the reporting period the paid consultancy fees to directors amounting to £46,525 (2024: £51,820).

 

Affiliation fees have been accrued and expensed for £463,101 (2024: £452,972). The affiliation fee is charged by the International Chamber of Commerce, an organisation in which a director of the company, is also a director.

 

 

ICC COMMERCIAL CRIME SERVICES (A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS (CONTINUED)
FOR THE YEAR ENDED 31 DECEMBER 2025
- 25 -
22
Cash generated from operations
2025
2024
£
£
Surplus after taxation
944,957
1,035,745
Adjustments for:
Taxation charged
164,878
110,598
Investment income
(469,790)
(362,398)
Loss on disposal of tangible fixed assets
23,048
11,507
Depreciation of tangible fixed assets
86,673
90,028
Other gains and losses
(282,077)
(236,711)
Movements in working capital:
(Increase)/decrease in debtors
(236,920)
344,511
Increase/(decrease) in creditors
255,028
(102)
Cash generated from operations
485,797
993,178
23
Analysis of changes in net funds
1 January 2025
Cash flows
31 December 2025
£
£
£
Cash at bank and in hand
10,727,907
751,923
11,479,830
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