Dr Amanda Cabrejo le Roux
Senior Specialist / Deputy Director, Green Corruption
Dr Amanda Cabrejo le Roux is a Senior Specialist and Deputy Director of the Green Corruption programme at the Basel Institute on Governance. She joined the Institute in June 2022.
Previously, Amanda worked for the United Nations Environment Programme (UNEP) for four years in various capacities. As Environmental Law Expert she supported the implementation of the Montevideo V Programme, a 10-year intergovernmental programme on strengthening environmental rule of law worldwide. She also supported UNEP’s Regional Office for Asia and the Pacific in the development and implementation of projects in the area of environmental law and governance.
Amanda was previously an Associate Legal Officer in UNEP’s Law Division at its headquarters in Nairobi, Kenya. She was the Law Division thematic focal point on environmental crime, advising on related strategies, projects and partnerships worldwide. She also coordinated the development of environmental crime reports and guidance materials and contributed to capacity-building activities for national enforcement authorities in Africa, Asia and Latin America.
Before joining UNEP, Amanda was a visiting researcher at the Centre of Criminology of the University of Cape Town (South Africa) and a junior researcher at the Sorbonne Law School, (Paris, France). She also worked as a legal consultant and is the lead author of a report entitled: “Tightening the Net: Toward a Global Legal Framework on Transnational Organized Environmental Crime” (WWF and the Global Initiative Against Transnational Organized Crime, 2015).
Amanda holds a PhD in Law from the Sorbonne Law School. She is the recipient of research prizes including the prestigious Vendôme Prize 2019 awarded by the French Ministry of Justice for her Ph.D. thesis (“Ne bis in idem – the prohibition of double jeopardy – at the crossroads of the discourses of supranational courts regarding criminal justice”). She also holds a LL.M. in International Criminal Law (University of Amsterdam/Columbia Law School), Master’s Degrees in French Law and Comparative Criminal Law (Sorbonne Law School) and Spanish Law (Universidad Complutense), and Bachelor’s Degrees in History (Universities Paris 1) and Anthropology (University Paris 8).
Publications
Addressing conflicts of interest and corruption in Indonesia’s energy transition
This U4 Issue analyses Indonesia’s ambitious energy transition and highlights how political finance, weak regulations and a “revolving door” of personnel between public office and the private sector create vulnerabilities. The publication was produced by U4 and the Basel Institute on Governance through its Green Corruption programme.
About the paper
Conflicts of interest and corruption in Indonesia’s political economy pose significant risks to its energy transition, including the Just Energy Transition Partnership. Existing legal and institutional frameworks are fragmented, inconsistently applied, and often fail to address the risk of state capture by powerful political and economic actors, especially in the extractive and energy sectors.
The reliance on fossil fuel industries for political financing and the monopolistic nature of state-owned entities further complicate the shift to a low- or no-carbon system, despite the country’s ambitious renewable energy targets.
Potential pathways to greater anti-corruption resilience lie in improvements to beneficial ownership transparency and strengthening regulation, monitoring and sanctioning of conflict of interest violations.
Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8/12 and beyond
At the 8th session of the Conference of the States Parties to the United Nations Convention against Corruption (UNCAC), in December 2019, States Parties adopted a resolution recognising the relationship between corruption and environmental crimes.
Resolution 8/12 – Preventing and combating corruption as it relates to crimes that have an impact on the environment – is a landmark Resolution. With its 23 operative paragraphs (OPs), it underlies the importance of addressing corruption linked to crimes that have an impact on the environment. It urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.
Saplings of hope presents an updated overview of emerging and promising prevention and enforcement actions, initiatives and measures implemented by UNCAC States Parties to combat corruption as it pertains to crimes that have an impact on the environment. It focuses specifically on initiatives from 2024 and 2025.
The Working Paper also underscores the valuable contributions made by non-state actors, in particular civil society, academia and the media, in this collective endeavour.
Finally, it makes the case for a paradigm shift, moving from “corruption as it relates to crimes that have an impact on the environment” to “corruption that has an impact on the environment”. The shift is necessary, because corruption can harm the environment without being linked to a crime that has an impact on the environment. Section 5 thus explores two interconnected issues which have a devastating impact on the environment: corruption linked to climate finance and renewable energy as well as corruption tied to the exploitation of critical minerals.
About this Working Paper
This report is part of the Green Corruption programme at the Basel Institute on Governance and was prepared in the context of the 11th Conference of the States Parties to the UN Convention against Corruption in Doha, Qatar, from 14–19 December 2025.
It provides an update to Working Paper 50, 'Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8/12’, which was prepared in the context of CoSP10 in Atlanta, Georgia, US in 2023.
The report is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. You may share or republish the report under a Creative Commons CC BY-NC-ND 4.0 licence.
It was made possible by the generous support of the Principality of Liechtenstein.
The contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
News and blog
From seedlings to saplings of hope: updated report on promising efforts to address environmental corruption
The diversity of activities to prevent and combat corruption that harms the environment is laudable. But it is far from the scale needed to tackle today's corruption and environmental challenges. Adopted in 2019, UNCAC Resolution 8/12 – Preventing and combating corruption as it relates to crimes that have an impact on the environment – urges States Parties to the UN Convention Against Corruption UNCAC to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment. In 2023, the Basel Institute on Governance published its Working Paper 50, Seedlings of hope , providing a panorama of emerging and promising initiatives across the world since the adoption of Resolution 8/12. The new Working Paper Saplings of hope , prepared for the 11th Conference of the States Parties CoSP in Doha, Qatar in December 2025, highlights what progress has been achieved since then. The report was made possible by the generous support of the Principality of Liechtenstein. Below are the main takeaways, but we urge you to read the full Working Paper for concrete examples from Bolivia, Canada, Indonesia, Kenya, Madagascar, Malawi, Namibia, Ukraine and other countries. Corruption prevention measures States have implemented a host of initiatives to strengthen integrity systems. Most commonly, this included the revision and adoption of internal control policies, more dedicated risk management efforts, including through the establishment of corruption prevention committees, and a range of capacity building efforts to strengthen environmental agencies’ ability to mitigate their own corruption risks, such as workshops on ethics codes and other integrity measures. Whistleblower protection programmes were increasingly designed, implemented and promoted. Corruption risk assessments were conducted in sectors such as wildlife management, forestry and fisheries. Promising corruption prevention interventions include: Conducting regular corruption perception and experience surveys among staff. This can help assess both progress and the effectiveness of corruption prevention measures. It can also create baselines against which to measure progress. Not enough interventions and reform efforts start with such a baseline, which means they then struggle to assess progress. Involving high-level management and leadership at each stage of the corruption prevention approach. This can help develop ownership and accountability. Explaining how integrity efforts support the strategic and political priorities of the leadership is crucial to achieve this. It requires adapting technocratic approaches to be relevant to the institutional leadership. Stipulating a mandatory budget for corruption prevention across ministries, agencies and departments. This can help ensure that minimal investments in integrity and anti-corruption activities are effectively prioritised and implemented. Sanctions for not respecting the mandatory budget should be imposed. Launching awareness-raising campaigns to promote knowledge of anti-corruption measures. This is an important first step to their effective implementation. Developing whistleblowing mechanisms. They can help increase reporting and detection of corruption. To achieve their potential, whistleblower mechanisms require a strong system, reliable protections and an institutional culture that welcomes such feedback. Peer-to-peer learning for government representatives from different countries and institutions to exchange on corruption prevention actions. This can be relevant, as anti-corruption officials often struggle with similar institutional challenges. Peer exchanges can help people and institutions to learn from each other’s successes and challenges and jointly identify effective mitigation measures. Enforcement actions Several countries have investigated and prosecuted corruption cases linked to crimes that have an impact on the environment. Financial investigations and money laundering legislation are more frequently used to tackle these crimes. The systematic seizure and confiscation of assets is still just beginning, as is the creation of multi-agency and interdisciplinary task forces, nationally and internationally. However, enforcement actions on corruption as it relates to crimes that have an impact on the environment are still limited. Promising enforcement interventions include: Assessing the economic, social and environmental losses from cases of corruption linked to crimes that have an impact on the environment – and using these to calculate associated penalties and fines – can help compensate and restore some of the harm done. Combining calculations of losses due to corruption with those of losses due to the environmental crimes can result in stiffer sentences and penalties. Seizing and confiscating proceeds and instrumentalities of crime bank accounts, real estate, vehicles, machineries, etc. through the diverse legal instruments available in jurisdictions can help ensure that crime does not pay. It also removes the resources needed to continue activities that harm the environment, thereby halting ongoing destruction. Exploring legal avenues outside the anti-corruption field can help strengthen enforcement. These include legislation on money laundering and tax offences as well as the social re-use of seized and confiscation assets, sanctions and visa bans. Essential role of civil society and the media Alongside States, civil society organisations and the media have played an essential role in increasing our understanding of the relationship between corruption and crimes that have an impact on the environment. Their efforts span investigative reporting, publishing evidence-based research, capacity building, creating networks to bridge the gap between anti-corruption and environmental practitioners, as well as initiating strategic litigation cases. Their involvement is all the more commendable given that they are facing an increasingly repressive environment. The way forward As the Working Paper highlights, various activities are taking place to tackle corruption linked to crimes that have an impact on the environment. The paper picks out those that show significant promise. The diversity of engagements is laudable, but it is far from the scale needed to make a systemic difference to both societal corruption and environmental challenges. States Parties need to adapt and scale up initiatives that are effective or look promising, by, among other things: Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources. Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment. Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms. Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment. Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment. Making use of legal frameworks and testing new legal avenues to hold individuals and legal persons accountable, including through asset recovery and remedies to repair the damage. Engaging in platforms for representatives from governments, civil society and other stakeholder groups to exchange experiences and know-how in tackling corruption that has an impact on the environment. Sharing knowledge, case law, success stories, etc. Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity. Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related issues. As these initiatives have now been conducted for six years, there is a sufficient body to scrutinise their effectiveness and efficiency. It is therefore essential to rigorously assess these measures, especially in an environment of increasingly scarce financial resources. Addressing corruption that has an impact on the environment The Working Paper also makes a case for moving from the concept of “corruption as it relates to crimes that have an impact on the environment” to “corruption that has an impact on the environment”. Focusing solely on corruption linked to crimes that have an impact on the environment overlooks situations where corruption causes environmental harm without an associated criminal offence. It does not take into consideration pressing issues such as corruption linked to climate finance, renewable energy and the exploitation of critical minerals. Adopting a holistic approach is crucial to address all forms of corruption that affect the environment, and thus to protect the environment and people. Learn more Read the full Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8/12 and beyond View the recordings of the "Environment Day" at the 11th CoSP. Learn more about our Green Corruption programme
How tackling green corruption can help us get ahead in the race to net zero
Juhani Grossmann and Amanda Cabrejo le Roux explain the strategic re-focusing of our Green Corruption programme on energy and climate: What is “green” corruption and why does it matter? Green corruption refers to corruption and other financial crimes and governance failures that harm the environment and hinder global efforts to combat climate change. It’s the reason crimes such as illicit deforestation, mining and wildlife trade continue to be multimillion-dollar illegal industries making organised criminals rich at the expense of our planet and the livelihoods of local communities. Green corruption also diverts crucial investments intended for renewable energy and other climate-related projects. Adapting to humanity’s changing energy needs in a just and sustainable manner are challenging enough. We cannot afford to let corruption undermine these generational challenges. What are some key achievements of the programme so far? We are proud that since its launch in 2018, the Green Corruption programme has contributed to significant strides in tackling corruption affecting the environment. Our programme started with an enforcement focus: applying “follow the money” approaches to environmental crimes like illegal wildlife trade and illegal logging. In practice, that means mentoring and training law enforcement officers of national partner agencies to investigate financial transactions that fuel environmental crimes, including between criminal groups and corrupt facilitators. And ideally, to seize and confiscate illicit profits or assets used in the crimes. That’s the only way to get beyond the low-level perpetrators – such as poachers – to the high-level facilitators and organised crime networks. And the only way to take the profit out of the crime, reducing the incentives to engage in it. At the end of 2024, assets worth around CHF 29.6 million were being targeted in 56 cases directly supported by our advisors. We had quite a few “firsts” – like Uganda’s first ever indictment for tax evasion and money laundering against a wildlife trafficking syndicate, Malawi’s first ever corruption cases related to natural resource crimes, Peru’s confiscation of over CHF 3 million in assets related to forestry and gold trafficking, and Indonesia’s first ever conviction on money laundering in relation to an illegal logging case. Behind the headlines lie many more positive steps towards changing mindsets and the priorities of law enforcement agencies to go after the finances of environmental criminals. Our prevention work rapidly grew as we and our partners realised the chronic under-investment in building systems that strengthen resilience to corruption in the environmental sector. Government agencies and state-owned enterprises in countries as diverse as Indonesia, Malawi, Ukraine and Bolivia have now begun to systematically assess and address corruption risks that are affecting their ability to carry out their important functions of protecting the environment and natural resources. Our prevention specialists supported these in applying our bespoke methodology of assessing and prioritising corruption risks and implementing targeted mitigation measures. We developed a customised internal controls maturity assessment tool to reflect the historic lack of investment in this space, which meant that mainstream assessment tools were insufficiently granular at the first stage of maturity to reflect nuances and chart paths to growth. As result of our partnerships, mitigation measures have been institutionalised in many agencies – for example: in Malawi through the creation of Internal Integrity Committees in environmental agencies; in Ukraine through the empowerment of anti-corruption officers to participate in key decision-making processes; in Ecuador by reducing unsupervised discretion in environmental inspections; in Indonesia in the adoption of conflict of interest regulations in the management of timber sales; and in Peru through the automation and digitalisation of numerous permitting and licensing processes related to the wood value chain. Also pleasing to see are the many collaborations and partnerships that have sprung from our work. In Latin America, for example, forestry officials in Peru, Bolivia and Ecuador are now collaborating on protecting the Amazon rainforest through corruption prevention. Still, targeting and preventing corruption tends to be a lonely effort. So, we have established the Countering Environmental Corruption Practitioners Forum together with WWF, TRAFFIC and Transparency International as a support network, and it has now grown to over 800 members and four working groups. There are frequent meetings and collaborations between practitioners dedicated to tackling corruption and improving governance, and those specialised in environmental conservation or climate initiatives. It’s a sign there’s much appetite and energy for action against green corruption Why is now the time to focus on the energy transition? Whatever happens in these volatile times, one thing is certain: we’ll continue to see growing demands for energy transition and climate mitigation and adaptation. The urgency of tackling the energy transition, and the rapid increase in investments from both the public and private sectors, leaves the door wide open to criminals and the corrupt seeking to profit at the expense of investors and donors – as well as the planet. A clear example in this space is the growing geopolitical centrality of critical minerals and rare earths. The rapid rise in demand has been accompanied by particularly fragile governance structures, intense political and economic subsidies, and even warfare. Our experience shows that these are all breeding grounds for corruption. We are therefore prioritising efforts to analyse and mitigate corruption risks in this space in Bolivia, Indonesia and Ukraine. Ensuring that the energy transition is safeguarded from corruption is essential for achieving net-zero goals. As outlined in our Working Paper on good governance and the just transition, corrupt practices can jeopardise renewable energy investments and hinder the development of clean energy infrastructure. Rapidly emerging market-based solutions to stimulate responsible behaviour, such as carbon offsets, are also affected by weak governance systems and opportunities for corruption. The fast-evolving and highly technical nature of these activities only increases this risk. Corruption risks similarly threaten the effectiveness of climate mitigation and adaptation efforts. If funds are embezzled, used fraudulently or diverted to benefit powerful elites, that’s bad for donors and investors. And it’s bad for local communities, many of which are also directly affected by climate change. On the other hand, there are opportunities. Using corruption risk management tools and enhancing enforcement capabilities can help companies and governments to create thriving, profitable supply chains of critical minerals needed for renewable energy facilities, electric vehicles and the like. What does this shift in priorities mean in practice? Through our Green Corruption programme, we are adapting to this evolving landscape by sharpening our focus on transition minerals and the renewable energy sector. We will continue our dual approach of prevention and enforcement, working closely with long-standing partners in Ukraine, Indonesia, Madagascar, Malawi, Uganda, Peru, Bolivia and Ecuador. Some things you might see us doing in the next years: Strengthening transparency and anti-corruption measures in the extraction and trade of lithium, nickel, germanium and other minerals and rare earths essential for the energy transition. Customising financial investigation and asset recovery tools to the specifics of the energy transition. Working with governments, financial institutions and civil society to safeguard energy transition and climate mitigation funds from corruption, fraud and related crimes. We will continue full force our ongoing engagement related to metals gold in particular and the forestry sector, which remain highly strategic. In other areas, such as illegal wildlife trade, fisheries and waste, we will be more discerning, carefully assessing the potential of engagements prior to pursuing them. What impact do we hope to achieve? By applying our expertise to emerging climate and energy challenges, we want to contribute to measurable improvements in the energy transition, environmental conservation, climate change mitigation and equitable economic development. Through these efforts, our Green Corruption programme will continue to play a vital role in ensuring that the green transition is not only sustainable but also just, transparent and a win-win for all: businesses, local communities and society at large – as well as our planet.
New insights into corruption in waste management and trade
The waste management sector provides a vital service for the good functioning of communities and economies and is essential for the protection of the environment and public health. This sector has been under increased scrutiny in recent years. Waste crime has become a growing concern around the world because of its dire impact on the environment and human health. In addition to challenges related to local waste management, the public has become more aware of the fact that this is an international issue. The transboundary movement of waste may pose risks to the environment and people in countries receiving large quantities of other countries’ waste. Policies and legal frameworks are evolving to better address waste management challenges. There has also been some research on waste-related crimes. However, the role that corruption plays in facilitating waste crimes is yet to be unpacked and addressed effectively to ensure better governance in this sector. As part of an ambitious “Environmental Corruption Deep Dive” research project, we decided to look at cases of corruption in waste management and trade. The entire research project is funded by Liechtenstein, a core donor to the Basel Institute and its Green Corruption programme. The research involves extensive desk research, an analysis of relevant cases and a series of interviews with experts from across sectors. Legal loopholes and gaps in implementation In brief, we conclude that complex legal frameworks and their weak implementation open up spaces for criminals to profit from illegally managing or trading in waste. The consequences on the environment and human health can be severe. We analysed five cases in Albania, Lebanon, North Macedonia, the U.S and Canada–Philippines. We found a variety of corruption risks even in this small initial set of cases. They include the potential for corruption to play a role in: influencing policy decisions involving waste management; corrupt deals involving the selection of waste management companies linked to powerful elites; schemes to gain lucrative waste management contracts through systematic bribery; illegal imports of hazardous waste for profit, avoiding or suppressing formal controls. Complex waste management chains Graphics in our report highlight different steps of the waste management chain and where corruption risks may arise. Again, these are both complex and numerous. The main areas are: Policies and procedures around waste management and trade: Liable to undue influence and state capture. Procurement for waste contracts: Like any sector, these are open to bribery, nepotism and favouritism. Inspections of waste: As a result of discretion, these are open to bribery, undue influence and collusion. What to do? This research is only an initial step to shine a light on potentially risky areas of waste management and trade. However, we note several external factors that make corruption and crime linked to waste management easier to get away with. Ongoing efforts to address these will help to reduce the space for corruption. These external factors include: poor record keeping and a lack of access to information even where records exist; low awareness and understanding of the field among public procurement officers, law enforcement and the judiciary; insufficient monitoring and lack of inspection and enforcement capacities; poor cooperation between environmental, financial investigation and other government agencies. In addition to addressing external factors and potentially reforming the legal frameworks governing waste, we and our interviewees identify a few basic steps to start addressing corruption risks. More research and corruption risk assessments on waste management supply chains. Greater investment in preventive measures, starting with digitalising administrative processes. More joined-up enforcement of waste management legislation through inter-agency cooperation and joint investigations. Extending wider transparency and accountability measures like open data and whistleblowing systems to the waste management field. Targeted capacity building and awareness raising for regulators and law enforcement. Collective Action initiatives between public, private and civil society actors in the waste management field, to build trust and understanding, share good practices and co-develop self-regulatory standards. Overall, more research is urgently needed to understand both the role of corruption in undermining proper waste management and trade, and the potential consequences of mitigation measures. Learn more Watch the launch webinar on YouTube View and download Working Paper 49: Dirty deals – Case studies on corruption in waste management and trade Find all Environmental Corruption Deep Dive reports and other resources from the Green Corruption team.
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