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.