[{"data":1,"prerenderedAt":905},["ShallowReactive",2],{"country-australia":3,"country-stories-australia-1":7,"country-publications-australia-1":10,"country-news-australia-1":526},{"name":4,"ids":5},"Australia",[6],14,{"items":8,"total":9},[],0,{"items":11,"total":525},[12,229,411],{"id":13,"status":14,"sort":15,"date_created":16,"date_updated":17,"nid":18,"slug":19,"title":20,"body":21,"citation":22,"language":23,"year":24,"publisher":25,"date_published":26,"external":27,"topic":28,"link_internal":30,"link_external":40,"featured":27,"topics":44,"languages":15,"type":46,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":15,"subtitle":15,"image":48,"countries":59,"tags":131,"pdf":186,"authors":210},2446,"published",null,"2026-06-04T21:25:14.000Z","2026-06-04T21:40:35.000Z",2971,"quick-guide-43-corruption-sanctions","Quick Guide 43: Corruption sanctions","How can governments respond to serious corruption when those responsible are beyond the reach of the law?\n\nWeak institutions, political protection or limited law enforcement capacity can make it difficult to investigate or prosecute powerful individuals suspected of corruption. In response, some governments have turned to corruption sanctions.\n\nCorruption sanctions allow governments to impose restrictions on people suspected of serious corruption even without a criminal conviction.\n\nThis Quick Guide introduces corruption sanctions, explains how they work and highlights both their potential and the concerns they raise.\n\n### About this Quick Guide\n\nYou are free to share and republish this work under a Creative Commons \u003Ca href=\"http:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">BY-NC-ND 4.0 Licence\u003C\u002Fa>. It is part of the Basel Institute on Governance Quick Guide series, \u003Ca href=\"https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428\">ISSN 2673-5229\u003C\u002Fa>.","","English",2026,"Basel Institute on Governance","2026-06-02",false,[29],"Asset Recovery",[31,34,37],{"url":32,"caption":33},"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-62"," Read related Working Paper",{"url":35,"caption":36},"https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F2968"," See related webinar",{"url":38,"caption":39},"https:\u002F\u002Fbaselgovernance.org\u002Fpublications?type=2428"," View all Quick Guides",[41],{"url":42,"caption":43},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=386"," View online on LEARN",[45],"Asset Recovery and Enforcement",[47],"Quick guide",{"id":49,"storage":50,"filename_disk":51,"filename_download":52,"title":53,"type":54,"created_on":16,"modified_on":16,"charset":15,"filesize":55,"width":56,"height":57,"duration":15,"embed":15,"description":15,"location":15,"tags":15,"metadata":58,"focal_point_x":15,"focal_point_y":15,"tus_id":15,"tus_data":15,"uploaded_on":16},"e0094eda-5362-4227-966b-d676340e21be","local","e0094eda-5362-4227-966b-d676340e21be.jpg?itok=pUB5SrLa","QG43-Corruption-sanctions-cover.jpg?itok=pUB5SrLa","Cover page of Quick Guide 43 Corruption sanctions","image\u002Fjpeg",42583,500,707,{},[60,91,112],{"id":61,"publications_id":62,"countries_id":85},1164,{"id":13,"status":14,"sort":15,"user_created":63,"date_created":16,"user_updated":64,"date_updated":17,"nid":18,"slug":19,"image":49,"title":20,"body":21,"citation":22,"language":23,"year":24,"publisher":25,"date_published":26,"external":27,"topic":65,"link_internal":66,"link_external":70,"featured":27,"topics":72,"languages":15,"type":73,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":15,"subtitle":15,"countries":74,"tags":77,"pdf":81,"authors":83},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","3d9ff205-1640-4f34-b5b6-86977f51bbd6",[29],[67,68,69],{"url":32,"caption":33},{"url":35,"caption":36},{"url":38,"caption":39},[71],{"url":42,"caption":43},[45],[47],[61,75,76],1165,1166,[78,79,80],5232,5233,5234,[82],2499,[84],2643,{"id":86,"name":87,"code":88,"latitude":89,"longitude":90},225,"Ukraine","UA",48.37943,31.16558,{"id":75,"publications_id":92,"countries_id":106},{"id":13,"status":14,"sort":15,"user_created":63,"date_created":16,"user_updated":64,"date_updated":17,"nid":18,"slug":19,"image":49,"title":20,"body":21,"citation":22,"language":23,"year":24,"publisher":25,"date_published":26,"external":27,"topic":93,"link_internal":94,"link_external":98,"featured":27,"topics":100,"languages":15,"type":101,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":15,"subtitle":15,"countries":102,"tags":103,"pdf":104,"authors":105},[29],[95,96,97],{"url":32,"caption":33},{"url":35,"caption":36},{"url":38,"caption":39},[99],{"url":42,"caption":43},[45],[47],[61,75,76],[78,79,80],[82],[84],{"id":107,"name":108,"code":109,"latitude":110,"longitude":111},36,"Canada","CA",56.13037,-106.34677,{"id":76,"publications_id":113,"countries_id":127},{"id":13,"status":14,"sort":15,"user_created":63,"date_created":16,"user_updated":64,"date_updated":17,"nid":18,"slug":19,"image":49,"title":20,"body":21,"citation":22,"language":23,"year":24,"publisher":25,"date_published":26,"external":27,"topic":114,"link_internal":115,"link_external":119,"featured":27,"topics":121,"languages":15,"type":122,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":15,"subtitle":15,"countries":123,"tags":124,"pdf":125,"authors":126},[29],[116,117,118],{"url":32,"caption":33},{"url":35,"caption":36},{"url":38,"caption":39},[120],{"url":42,"caption":43},[45],[47],[61,75,76],[78,79,80],[82],[84],{"id":6,"name":4,"code":128,"latitude":129,"longitude":130},"AU",-25.2744,133.77515,[132,150,168],{"id":78,"publications_id":133,"tags_id":147},{"id":13,"status":14,"sort":15,"user_created":63,"date_created":16,"user_updated":64,"date_updated":17,"nid":18,"slug":19,"image":49,"title":20,"body":21,"citation":22,"language":23,"year":24,"publisher":25,"date_published":26,"external":27,"topic":134,"link_internal":135,"link_external":139,"featured":27,"topics":141,"languages":15,"type":142,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":15,"subtitle":15,"countries":143,"tags":144,"pdf":145,"authors":146},[29],[136,137,138],{"url":32,"caption":33},{"url":35,"caption":36},{"url":38,"caption":39},[140],{"url":42,"caption":43},[45],[47],[61,75,76],[78,79,80],[82],[84],{"id":148,"name":149},1227,"Sanctions",{"id":79,"publications_id":151,"tags_id":165},{"id":13,"status":14,"sort":15,"user_created":63,"date_created":16,"user_updated":64,"date_updated":17,"nid":18,"slug":19,"image":49,"title":20,"body":21,"citation":22,"language":23,"year":24,"publisher":25,"date_published":26,"external":27,"topic":152,"link_internal":153,"link_external":157,"featured":27,"topics":159,"languages":15,"type":160,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":15,"subtitle":15,"countries":161,"tags":162,"pdf":163,"authors":164},[29],[154,155,156],{"url":32,"caption":33},{"url":35,"caption":36},{"url":38,"caption":39},[158],{"url":42,"caption":43},[45],[47],[61,75,76],[78,79,80],[82],[84],{"id":166,"name":167},843,"Asset 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PDF",[211],{"id":84,"publications_id":212,"authors_id":226},{"id":13,"status":14,"sort":15,"user_created":63,"date_created":16,"user_updated":64,"date_updated":17,"nid":18,"slug":19,"image":49,"title":20,"body":21,"citation":22,"language":23,"year":24,"publisher":25,"date_published":26,"external":27,"topic":213,"link_internal":214,"link_external":218,"featured":27,"topics":220,"languages":15,"type":221,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":15,"subtitle":15,"countries":222,"tags":223,"pdf":224,"authors":225},[29],[215,216,217],{"url":32,"caption":33},{"url":35,"caption":36},{"url":38,"caption":39},[219],{"url":42,"caption":43},[45],[47],[61,75,76],[78,79,80],[82],[84],{"id":227,"name":228,"position":15,"image":15},597,"Dr Anton Moiseienko",{"id":230,"status":14,"sort":15,"date_created":231,"date_updated":232,"nid":233,"slug":234,"title":235,"body":236,"citation":237,"language":15,"year":24,"publisher":25,"date_published":238,"external":27,"topic":15,"link_internal":239,"link_external":243,"featured":27,"topics":244,"languages":245,"type":246,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":248,"subtitle":15,"image":249,"countries":259,"tags":331,"pdf":358,"authors":395},2436,"2026-06-01T22:10:25.000Z","2026-06-02T14:08:57.000Z",2970,"wp-62","Working Paper 62: Corruption sanctions: What governments need to know","How can governments respond to serious corruption when those responsible are beyond the reach of the law? Some governments have turned to corruption sanctions to address this issue.\n\nThis Working Paper examines how corruption sanctions – tools that allow governments to impose asset freezes and travel bans on individuals suspected of corruption without any finding of guilt in a court – have evolved over the past decade, and offers recommendations for their more effective and legitimate use.\n\n::: button https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-05\u002F260529_WP-62.pdf\n**Download the Working Paper here**\n:::\n\n### Advantages and limitations of corruption sanctions\n\nCorruption sanctions emerged primarily to address situations where notoriously corrupt individuals enjoy impunity within their own legal systems. Their key strengths lie in their flexibility and versatility:\n\n- they can be applied regardless of any geographical link between the sanctioning state and the alleged corruption, based on relatively low evidentiary thresholds; and \n- they can serve a wide range of objectives – from disrupting and deterring corrupt activity to condemning corruption, facilitating asset recovery and signalling support for another country's law enforcement efforts.\n\nHowever, the paper also highlights important limitations. Corruption sanctions are often wielded without a clear post-imposition strategy. And: their inherent flexibility comes with due process trade-offs, including broad governmental discretion and limited judicial oversight.\n\n### Recommendations\n\nDrawing on an extensive analysis of the experiences of key jurisdictions – including the US, UK, EU, Canada and Australia – the author puts forward nine recommendations for governments on how to design and maintain credible and effective corruption sanctions regimes. These include publishing clear criteria for high-priority targets, strengthening transparency around licensing and delisting decisions, and exploring sanctions against professional enablers in major financial centres.\n\nThe paper is aimed primarily at policymakers but will also be of interest to anti-corruption activists, private-sector financial crime specialists and academics.\n\n### About this paper\n\nThis paper is published as part of the Basel Institute on Governance Working Paper series, ISSN: 2624-9650. You may share or republish it under a Creative Commons [BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002Fdeed.en) International Licence.\n\nThis is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.\n\nThe contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n","Moiseienko, Anton. 2026. “Corruption sanctions: What governments need to know.” Working Paper 62, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002Fwp-62","2026-05-28",[240],{"url":241,"caption":242},"\u002Fresources\u002Fpublications?type=Working%20Paper","View all Working Papers",[],[45],[23],[247],"Working Paper","Corruption sanctions allow governments to impose financial and travel\nrestrictions, such as asset freezes and visa bans, on persons (mostly foreigners)\nsuspected of corruption without any finding of guilt in a court of law. Such\nsanctions have emerged over the past decade primarily to address situations\nwhere notoriously corrupt individuals enjoy impunity within their own legal\nsystems. They are also occasionally used to support foreign investigations by\nenabling authorities to swiftly freeze suspected proceeds of corruption.\n\n### Advantages\nCorruption sanctions regimes offer two main advantages that make them a useful\naddition to a government’s anti-corruption arsenal: flexibility and versatility.\n\nThe flexibility of corruption sanctions stems from the relatively low evidentiary\nstandards required to implement them, which are far less exacting than\nthe civil or criminal standards of proof. It also reflects there being no need\nfor any geographical nexus between the sanctioning state and the alleged\ncorruption, such that sanctions can be wielded against anyone involved in\ncorruption anywhere in the world. These features allow governments to resort\nto corruption sanctions in circumstances where conventional law enforcement\naction, such as prosecutions or confiscation proceedings, would be out of\nreach.\n\nThe versatility of such sanctions is a product of the freedom that governments\nenjoy in their imposition. Corruption sanctions can be, and have been, put\nto use to achieve a varied set of objectives. Those include disrupting corrupt\nactivity; deterring would-be corruption or corruption facilitation; condemning\ncorruption; punishing the perpetrators; facilitating asset recovery; or signalling\nsupport for another country’s law enforcement actions.\n\n### Limitations\nThis flexibility and versatility combine to produce a unique and valuable anticorruption tool. However, all too often it is wielded without a clear post-imposition\nstrategy, namely a coherent and credible approach to what the sanctions are\nmeant to achieve once they are in effect; how long they will be kept in place;\nand how they interact with other available law enforcement tools. In some cases,\nthe imposition of sanctions may be predicated on the expectation that other\nmeasures – such as asset confiscation – will follow. In others, they may be a selfstanding response to allegations of serious corruption.\n\nThe inherent flexibility in these tools also comes with due process trade-offs.\nCorruption sanctions regimes grant governments broad powers, including a\nwide discretion in imposing and lifting corruption sanctions or granting licences\nfor transactions that would otherwise be prohibited under such sanctions.\nThese powers are often subject only to light-touch judicial oversight. This has\nunderstandably raised concerns over their vulnerability to errors or, in extreme\ncases, abuse.\n\nTo ensure consistent and credible use of corruption sanctions, policymakers\nshould review applicable evidentiary standards and judicial review rules;\npublish clear criteria outlining what makes for a high-priority target for\ncorruption sanctions; publish clear criteria for sanctions licences and delisting;\nand set out processes and expectations for sanctions dossier submissions from\ncivil society organisations. While all of these measures preserve governments’\nflexibility in the imposition of corruption sanctions, taken together they will go\nsome way towards minimising the risks of politicisation or abuse.\n\n### A useful addition to the anti-corruption toolbox\nAll in all, corruption sanctions have transformed and enriched the anticorruption enforcement landscape. Their evident advantages suggest that\nstates that have not yet done so should consider whether the introduction of\ncorruption sanctions is right for them, and that those states that already have a\nmechanism in place should explore how they can use it to the greatest effect.\nSometimes, governments are reluctant to make full use of corruption sanctions\nfor fears of foreign policy repercussions. But, as the analysis in this paper\nsuggests, such sensitivities can be managed through careful target selection.\n\nIn summary, if designed and implemented transparently and responsibly – not\nas a low-cost substitute for traditional enforcement tools but as a complement\nto them when they are not available – these mechanisms can be used to target\nand challenge otherwise unchecked corruption globally. The analysis in this\npaper, and the recommendations it contains in its conclusion, aim to support\nthis endeavour.",{"id":250,"storage":50,"filename_disk":251,"filename_download":252,"title":253,"type":54,"created_on":254,"modified_on":254,"charset":15,"filesize":255,"width":256,"height":257,"duration":15,"embed":15,"description":15,"location":15,"tags":15,"metadata":258,"focal_point_x":15,"focal_point_y":15,"tus_id":15,"tus_data":15,"uploaded_on":254},"0b54d63b-364d-478e-b7a6-29c8a4f6333b","0b54d63b-364d-478e-b7a6-29c8a4f6333b.jpg","WP62_Corruption-sanctions_cover.jpg","Working Paper 62_Corruption 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through key insights",1215834,[396],{"id":280,"publications_id":397,"authors_id":408},{"id":230,"status":14,"sort":15,"user_created":64,"date_created":231,"user_updated":64,"date_updated":232,"nid":233,"slug":234,"image":250,"title":235,"body":236,"citation":237,"language":15,"year":24,"publisher":25,"date_published":238,"external":27,"topic":15,"link_internal":398,"link_external":400,"featured":27,"topics":401,"languages":402,"type":403,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":15,"short_version":248,"subtitle":15,"countries":404,"tags":405,"pdf":406,"authors":407},[399],{"url":241,"caption":242},[],[45],[23],[247],[261,270,271,272],[274,275],[277,278],[280],{"id":409,"name":410,"position":15,"image":15},583,"Anton Moiseienko",{"id":412,"status":14,"sort":15,"date_created":413,"date_updated":414,"nid":415,"slug":416,"title":417,"body":418,"citation":419,"language":23,"year":420,"publisher":421,"date_published":422,"external":27,"topic":423,"link_internal":424,"link_external":428,"featured":27,"topics":429,"languages":15,"type":430,"area":15,"programme":15,"websites":15,"summary":15,"pdf_text":15,"main_points":432,"short_version":15,"subtitle":15,"image":433,"countries":440,"tags":490,"pdf":506,"authors":524},2427,"2025-11-18T17:05:42.000Z","2026-06-02T14:08:56.000Z",2870,"cs-11","International cooperation in the Migori County corruption case","This Case Study describes how Kenya obtained crucial overseas intelligence in a corruption case through the International Anti-Corruption Coordination Centre, leading to the recovery of USD 1.8 million in assets for the Kenyan people.\n\n### About this Case Study\n\nThis publication is part of the Basel Institute on Governance Case Study series, \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fcase-studies\">ISSN 2813-3900\u003C\u002Fa>. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (\u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa>).\n\nIt is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.\n\nWhile we have made reasonable efforts to ensure the accuracy of information provided in this Case Study, neither the authors nor the Basel Institute’s donors and partners assume any responsibility or liability for any errors or omissions.","Basel Institute on Governance, Ethics and Anti-Corruption Commission (Kenya) and International Anti-Corruption Coordination Centre. 2025. “International cooperation in the Migori County corruption case.” Case Study 11, Basel Institute on Governance. Available at: \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-11\">baselgovernance.org\u002Fpublications\u002Fcs-11\u003C\u002Fa>",2025,"Basel Institute on Governance, Ethics and Anti-Corruption Commission (Kenya) and International Anti-Corruption Coordination Centre","2025-11-18",[29],[425],{"url":426,"caption":427},"\u002Fresources\u002Fpublications?type=Case%20Study"," View all Case Studies",[],[45],[431],"Case Study","- Kenya’s Ethics and Anti-Corruption Commission (EACC) established that between 2013 and 2017, around KES 2 billion (USD 15.5 million) was embezzled from the County Government of Migori in southwest Kenya through unlawful and irregular procurement contracts. The money was spent on property, high-end vehicles and university tuition fees for the former County Governor’s children.\n- Through the International Anti-Corruption Coordination Centre (IACCC), the EACC obtained crucial intelligence on the suspect’s assets, travels and purchases in several jurisdictions.\n- This enabled the EACC to prepare and submit precise mutual legal assistance requests, with the assistance of a mentor from the Basel Institute’s International Centre for Asset Recovery (ICAR).\n- The end result was timely evidence collection and an out-of-court settlement worth KES 235.6 million (USD 1.8 million) in property and vehicles. The assets will be liquidated and ultimately returned to the Kenyan treasury.\n- The case highlights the value of the IACCC as a mechanism for efficient and coordinated international cooperation in grand corruption investigations, and the benefits of ICAR’s case-based technical assistance in complex, cross-border corruption cases.",{"id":434,"storage":50,"filename_disk":435,"filename_download":436,"title":437,"type":54,"created_on":413,"modified_on":413,"charset":15,"filesize":438,"width":56,"height":57,"duration":15,"embed":15,"description":15,"location":15,"tags":15,"metadata":439,"focal_point_x":15,"focal_point_y":15,"tus_id":15,"tus_data":15,"uploaded_on":413},"b444532c-4291-4a7f-a981-5d08183eb628","b444532c-4291-4a7f-a981-5d08183eb628.jpg?itok=dPf9Eyx-","Pages-from-CaseStudy11.jpg?itok=dPf9Eyx-","Case Study 11 cover 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the corrupt to account: the promise and potential of corruption sanctions","Blog","When states fail to hold corrupt actors to account, ordinary citizens pay the price. Corruption sanctions were born from the idea that no one should be above the law, no matter where they are in the world. In a new Working Paper, Dr Anton Moiseienko explores how these tools have evolved and offers recommendations for their more effective and legitimate use.\n\nHere we share the foreword to his paper by the Basel Institute's Andrew Dornbierer, Head of Policy and Research, International Centre for Asset Recovery.\n\n> ### Foreword\n> \n> Every state has an obligation to investigate and prosecute corruption within their jurisdiction. Unfortunately, many states around the world are not willing to fulfil this responsibility.\n> \n> As a result, the very individuals within these states tasked with serving the public interest are instead given free rein to commit acts that not only serve themselves but also corrode the fabric of the state. And ordinary citizens have no alternative but to endure the ensuing economic and social damage.\n> \n> The development of sanctions tools targeting corruption stemmed from the idea that justice should be universal; that no one in any society around the world should be above the law.\n> \n> They are powerful tools, built on powerful principles. States introducing them understand that unchecked corruption will always suffocate a state’s ability to provide security, fairness and prosperity to its citizens.\n> \n> Comparatively though, corruption sanctions are still an underdeveloped concept and are far from perfect. Only a handful of states have introduced them, and those that have are not often using them to their full potential.\n> \n> They also spark valid concerns surrounding due process. These criticisms shouldn’t be ignored: they offer an insight on how these tools could be further developed and enhanced to ensure that they are more credibly and consistently applied.\n> \n> In his paper, Anton Moiseienko provides an excellent and well-researched overview of how corruption sanctions could be designed and employed to better achieve their potential. He explains how these tools have evolved over the last two decades and how they could be further refined to be more effective and achieve a wider range of impact.\n> \n> Critically, his paper is an indispensable resource for those looking to understand exactly how such sanctions can help states deter, disrupt and debilitate the notoriously corrupt that are unreachable through standard criminal justice tools.\n\n### Learn more\n\n*   Read Dr Anton Moiseienko’s Working Paper “[Corruption sanctions: What governments need to know](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-62)” for a deeper analysis of the topic and key policy recommendations.\n*   Get a brief introduction to corruption sanctions from our related [Quick Guide](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fqg43).\n*   Register for our public webinar \"[Corruption sanctions – reaching those beyond the law](https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F2968)\" on 18 June 2026, marking the launch of Dr Moiseienko's Working Paper.","2026-06-03",[29],"holding-the-corrupt-to-account-the-promise-and-potential-of-corruption-sanctions-2979",[539,540],"Reports","Insights",2979,[29],[539,540],{"id":545,"storage":50,"filename_disk":546,"filename_download":547,"title":532,"type":548,"created_on":530,"modified_on":530,"charset":15,"filesize":549,"width":550,"height":551,"duration":15,"embed":15,"description":15,"location":15,"tags":15,"metadata":552,"focal_point_x":15,"focal_point_y":15,"tus_id":15,"tus_data":15,"uploaded_on":530},"9f5fad98-9243-40da-98d0-1271edd00df2","9f5fad98-9243-40da-98d0-1271edd00df2.webp","tmp.webp","image\u002Fwebp",13600,800,453,{},[554,573],{"id":555,"news_id":556,"countries_id":572},7808,{"id":529,"status":14,"user_created":63,"date_created":530,"user_updated":63,"date_updated":531,"title":532,"type":533,"body":534,"image":545,"date":535,"topic":557,"slug":537,"activity":558,"nid":541,"topics":559,"activities":560,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":561,"tags":563,"authors":567,"images":569,"translations":570,"content":571},[29],[539,540],[29],[539,540],[555,562],7809,[564,565,566],5995,5996,5997,[568],1372,[],[],[],{"id":6,"name":4,"code":128,"latitude":129,"longitude":130},{"id":562,"news_id":574,"countries_id":585},{"id":529,"status":14,"user_created":63,"date_created":530,"user_updated":63,"date_updated":531,"title":532,"type":533,"body":534,"image":545,"date":535,"topic":575,"slug":537,"activity":576,"nid":541,"topics":577,"activities":578,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":579,"tags":580,"authors":581,"images":582,"translations":583,"content":584},[29],[539,540],[29],[539,540],[555,562],[564,565,566],[568],[],[],[],{"id":107,"name":108,"code":109,"latitude":110,"longitude":111},[587,600,613],{"id":564,"news_id":588,"tags_id":599},{"id":529,"status":14,"user_created":63,"date_created":530,"user_updated":63,"date_updated":531,"title":532,"type":533,"body":534,"image":545,"date":535,"topic":589,"slug":537,"activity":590,"nid":541,"topics":591,"activities":592,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":593,"tags":594,"authors":595,"images":596,"translations":597,"content":598},[29],[539,540],[29],[539,540],[555,562],[564,565,566],[568],[],[],[],{"id":148,"name":149},{"id":565,"news_id":601,"tags_id":612},{"id":529,"status":14,"user_created":63,"date_created":530,"user_updated":63,"date_updated":531,"title":532,"type":533,"body":534,"image":545,"date":535,"topic":602,"slug":537,"activity":603,"nid":541,"topics":604,"activities":605,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":606,"tags":607,"authors":608,"images":609,"translations":610,"content":611},[29],[539,540],[29],[539,540],[555,562],[564,565,566],[568],[],[],[],{"id":166,"name":167},{"id":566,"news_id":614,"tags_id":625},{"id":529,"status":14,"user_created":63,"date_created":530,"user_updated":63,"date_updated":531,"title":532,"type":533,"body":534,"image":545,"date":535,"topic":615,"slug":537,"activity":616,"nid":541,"topics":617,"activities":618,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":619,"tags":620,"authors":621,"images":622,"translations":623,"content":624},[29],[539,540],[29],[539,540],[555,562],[564,565,566],[568],[],[],[],{"id":184,"name":185},[627],{"id":568,"news_id":628,"authors_id":639},{"id":529,"status":14,"user_created":63,"date_created":530,"user_updated":63,"date_updated":531,"title":532,"type":533,"body":534,"image":545,"date":535,"topic":629,"slug":537,"activity":630,"nid":541,"topics":631,"activities":632,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":633,"tags":634,"authors":635,"images":636,"translations":637,"content":638},[29],[539,540],[29],[539,540],[555,562],[564,565,566],[568],[],[],[],{"id":640,"name":641,"position":15,"image":642},306,"Andrew Dornbierer","89aae58b-3e50-4375-9b9b-5b31370dab64",[],[],[],{"id":647,"status":14,"date_created":648,"date_updated":649,"title":650,"type":533,"body":651,"date":652,"topic":653,"slug":656,"activity":657,"nid":658,"topics":659,"activities":661,"programme":15,"area":15,"websites":15,"language":23,"image":662,"translation_of":15,"countries":668,"tags":759,"authors":760,"images":761,"translations":762,"content":763},10563,"2025-07-13T11:42:46.000Z","2026-05-29T22:22:37.000Z","Boosting business integrity in Asia: the power of public-private cooperation","_A joint blog by Vanessa Hans, Director, Private Sector, Basel Institute on Governance, and Elodie Beth, Senior Manager, Anti-corruption, Global Relations, Directorate for Financial and Enterprise Affairs, Organisation for Economic Co-operation and Development (OECD). The post is also published on the [OECD website](https:\u002F\u002Fwww.oecd.org\u002Fen\u002Fblogs\u002F2025\u002F06\u002Fboosting-business-integrity-in-asia-the-power-of-public-private-co-operation1.html)._\n\nClean, ethical business practices build trust, attract investors and create healthier markets. For the OECD, business integrity is key to levelling the global playing field and enhancing national competitiveness.\n\nAmid global regulatory uncertainty, countries like Indonesia and Thailand are stepping up. Both are taking meaningful steps to strengthen their anti-corruption frameworks as they move towards joining the OECD Anti-Bribery Convention – a critical milestone and prerequisite for future OECD membership.\n\nTheir actions reflect a broader shift: governments across Asia increasingly recognise that corruption undermines competitiveness, deters investment and jeopardises sustainable, long-term growth. A 2024 [regional study](https:\u002F\u002Flink.springer.com\u002Fchapter\u002F10.1007\u002F978-981-99-9303-1_3) confirms it: Asian countries that have improved their control of corruption are far more likely to attract foreign direct investment and foster long-term growth.\n\n### Regional co-operation and the role of Collective Action\n\nRecognising that no single actor can tackle corruption alone, public- and private-sector actors are joining forces at the regional level through the [Anti-Corruption Initiative for Asia and the Pacific](https:\u002F\u002Fwww.oecd.org\u002Fen\u002Fnetworks\u002Fanti-corruption-initiative-for-asia-and-the-pacific.html) (ACI), co-led by the OECD and Asian Development Bank.\n\nThe ACI, jointly supported by the OECD and the Asian Development Bank, launched a business integrity workstream in 2019, initiated by the Government of Viet Nam as the host country. Last year, the Government of Bhutan held business integrity seminars, and in 2025, Indonesia is expected to host the Regional ACI Conference.\n\nThese Collective Action efforts are underpinned by the OECD’s 2021 Anti-Bribery Recommendation, the first global standard to formally recognise the role of Collective Action and partnerships between the public and private sectors against foreign bribery.\n\n### Spotlight on innovation: Promising business integrity initiatives across the region\n\nFrom risk mapping to regulatory reform, here are standout examples of how countries are taking action through public-private initiatives:\n\n*   Australia: The [Bribery Prevention Network](https:\u002F\u002Fbriberyprevention.com\u002F) brings together business, civil society, academia and government to help small- and medium-sized enterprises prevent, detect and address bribery and corruption while promoting a culture of compliance.\n*   India: The [Maritime Anti-Corruption Network](https:\u002F\u002Fmacn.dk\u002Findia\u002F), a global initiative, set up a HelpDesk in India serving as a real-time resolution mechanism that bridges the gap between the shipping industry and local authorities. It collects anonymous reports by shipping companies of bribe solicitation in ports and uses this data to map out risk areas and tailor its strategies to engage with local government authorities.\n*   Hong Kong, China: The [Independent Commission Against Corruption](https:\u002F\u002Fcpas.icac.hk\u002FEN\u002FInfo\u002FNews_List?cate_id=26) is engaged in several sector-specific Collective Action initiatives, particularly in construction and banking. It collaborates with chambers of commerce and industry associations such as the Construction Industry Council.\n*   Thailand: In 2024, the Thai government amended its procurement law to recognise certification by the [Thai Collective Action Against Corruption](https:\u002F\u002Fwww.thai-cac.com\u002Fen\u002F) (CAC) initiative as proof of a company’s anti-corruption controls. This enables CAC-certified firms to qualify for public contracts above a certain threshold, incentivising private-sector compliance.\n\nThese experiences illustrate how government authorities are increasingly participating in Collective Action initiatives to enhance their awareness-raising efforts, gather better evidence and develop tailored solutions that reflect the realities of different sectors and companies, including small and medium-sized enterprises.\n\nBy engaging in such initiatives, government authorities can increase their overall outreach, lend greater legitimacy to private-sector anti-corruption efforts and effectively promote the adoption of business integrity policies.\n\n### Building a regional community of practice\n\nTo sustain momentum, the OECD and the Basel Institute on Governance have launched a regional community of practice.\n\nIn 2023, the [Asia-Pacific Collective Action Forum](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fevents\u002Fasia-pacific-anti-corruption-collective-action-forum-2023\u002F) was held in Manila, Philippines, bringing together 50+ practitioners from diverse stakeholder groups across the region. The Asia-Pacific Anti-Corruption Collective Action Award recognised the growing number of initiatives in the region and celebrated their achievements. The Thai CAC received the inaugural award.\n\nEncouraged by the Forum’s success, participants expressed strong interest in sustaining and deepening exchanges among practitioners. A follow-up Collective Action workshop was held in 2024 in Bangkok, in collaboration with the Thai CAC. The workshop further strengthened the emerging community of practice and provided a valuable platform for peer learning.\n\nThis regional community has created a meaningful space for peer learning and experience sharing. It has also contributed to greater alignment with international standards.\n\n### Looking ahead: co-operation as the path forward\n\nThese developments show that business integrity reforms are not only possible but already underway.\n\nIn 2025, the OECD will release a policy paper examining the link between business integrity frameworks and competitiveness. The paper underscores how public-private cooperation is not only advancing reform, but also makes countries more attractive to investment and resilient to shocks.\n\nAlthough still in their early stages, the emergence of Collective Action and partnerships between the public and private sectors in Asia offers a promising path forward to advance integrity. Sustained cooperation will be crucial to fully realising the potential of these initiatives.\n\n### Learn more and get engaged\n\n*   OECD work on [fighting foreign bribery](https:\u002F\u002Fwww.oecd.org\u002Fen\u002Ftopics\u002Ffighting-foreign-bribery.html)\n*   OECD and ADB [Anti-Corruption Initiative for Asia and the Pacific](https:\u002F\u002Feur02.safelinks.protection.outlook.com\u002F?url=https%3A%2F%2Fwww.oecd.org%2Fen%2Fnetworks%2Fanti-corruption-initiative-for-asia-and-the-pacific.html&data=05%7C02%7CAmelia.GODBER%40oecd.org%7C6fd37eac8a904a45c14a08ddb79ccb32%7Cac41c7d41f61460db0f4fc925a2b471c%7C0%7C0%7C638868606248663645%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=f3iuWN%2F79tnGhdt3SdwKbaUixtckXB6wTGm2vb%2BocG4%3D&reserved=0)\n*   [B20 Collective Action Hub](https:\u002F\u002Fcollective-action.com\u002F) by the Basel Institute on Governance\n*   [Working Paper 48: A collaborative approach to improve business integrity in ASEAN](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fpublications\u002F2316\u002F) by Lucie Binder, Vanessa Hans and Anna Stransky, Basel Institute on Governance\n*   [Working Paper 56: Anti-corruption Collective Action: A typology for a new era](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fpublications\u002F2397\u002F) by Scarlet Wannenwetsch, Basel Institute on Governance","2025-06-30",[654,655],"Collective Action","Private Sector","boosting-business-integrity-in-asia-the-power-of-public-private-cooperation-2825",[540],2825,[654,655,660],"Business Integrity Ethics and Compliance",[540],{"id":663,"storage":50,"filename_disk":664,"filename_download":547,"title":650,"type":548,"created_on":648,"modified_on":648,"charset":15,"filesize":665,"width":550,"height":666,"duration":15,"embed":15,"description":15,"location":15,"tags":15,"metadata":667,"focal_point_x":15,"focal_point_y":15,"tus_id":15,"tus_data":15,"uploaded_on":648},"c2ae4699-b971-41c8-bba9-47e7fadb6c5e","c2ae4699-b971-41c8-bba9-47e7fadb6c5e.webp",48588,600,{},[669,687,705,723,741],{"id":670,"news_id":671,"countries_id":686},7783,{"id":647,"status":14,"user_created":63,"date_created":648,"user_updated":64,"date_updated":649,"title":650,"type":533,"body":651,"image":663,"date":652,"topic":672,"slug":656,"activity":673,"nid":658,"topics":674,"activities":675,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":676,"tags":681,"authors":682,"images":683,"translations":684,"content":685},[654,655],[540],[654,655,660],[540],[670,677,678,679,680],7784,7785,7786,7787,[],[],[],[],[],{"id":6,"name":4,"code":128,"latitude":129,"longitude":130},{"id":677,"news_id":688,"countries_id":699},{"id":647,"status":14,"user_created":63,"date_created":648,"user_updated":64,"date_updated":649,"title":650,"type":533,"body":651,"image":663,"date":652,"topic":689,"slug":656,"activity":690,"nid":658,"topics":691,"activities":692,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":693,"tags":694,"authors":695,"images":696,"translations":697,"content":698},[654,655],[540],[654,655,660],[540],[670,677,678,679,680],[],[],[],[],[],{"id":700,"name":701,"code":702,"latitude":703,"longitude":704},46,"China","CN",35.86166,104.1954,{"id":678,"news_id":706,"countries_id":717},{"id":647,"status":14,"user_created":63,"date_created":648,"user_updated":64,"date_updated":649,"title":650,"type":533,"body":651,"image":663,"date":652,"topic":707,"slug":656,"activity":708,"nid":658,"topics":709,"activities":710,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":711,"tags":712,"authors":713,"images":714,"translations":715,"content":716},[654,655],[540],[654,655,660],[540],[670,677,678,679,680],[],[],[],[],[],{"id":718,"name":719,"code":720,"latitude":721,"longitude":722},103,"India","IN",20.59368,78.96288,{"id":679,"news_id":724,"countries_id":735},{"id":647,"status":14,"user_created":63,"date_created":648,"user_updated":64,"date_updated":649,"title":650,"type":533,"body":651,"image":663,"date":652,"topic":725,"slug":656,"activity":726,"nid":658,"topics":727,"activities":728,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":729,"tags":730,"authors":731,"images":732,"translations":733,"content":734},[654,655],[540],[654,655,660],[540],[670,677,678,679,680],[],[],[],[],[],{"id":736,"name":737,"code":738,"latitude":739,"longitude":740},174,"Philippines","PH",12.87972,121.77402,{"id":680,"news_id":742,"countries_id":753},{"id":647,"status":14,"user_created":63,"date_created":648,"user_updated":64,"date_updated":649,"title":650,"type":533,"body":651,"image":663,"date":652,"topic":743,"slug":656,"activity":744,"nid":658,"topics":745,"activities":746,"programme":15,"area":15,"websites":15,"translation_of":15,"language":23,"countries":747,"tags":748,"authors":749,"images":750,"translations":751,"content":752},[654,655],[540],[654,655,660],[540],[670,677,678,679,680],[],[],[],[],[],{"id":754,"name":755,"code":756,"latitude":757,"longitude":758},213,"Thailand","TH",15.87003,100.99254,[],[],[],[],[],{"id":765,"status":14,"date_created":766,"date_updated":767,"title":768,"type":533,"body":769,"date":770,"topic":771,"slug":772,"activity":773,"nid":774,"topics":775,"activities":776,"programme":15,"area":15,"websites":777,"language":15,"image":779,"translation_of":15,"countries":787,"tags":805,"authors":820,"images":837,"translations":838,"content":839},10461,"2024-08-07T10:01:39.000Z","2026-05-29T22:22:30.000Z","Australia is cracking down on foreign bribery","_A guest blog by Ryan Carter, a law student at Arizona State University who is undertaking a legal research internship at the Basel Institute on Governance._\n\nOn 8 September 2024, [significant amendments](https:\u002F\u002Fwww.prod.legislation.gov.au\u002FC2024A00005) to Australia’s foreign bribery laws will take effect. These changes follow long-standing concerns expressed by both the [OECD Working Group on Bribery](https:\u002F\u002Fone.oecd.org\u002Fdocument\u002FDAF\u002FWGB(2022)15\u002Fen\u002Fpdf) and [civil society](https:\u002F\u002Ftransparency.org.au\u002Freform-needed-to-stop-multinational-companies-bribing-their-way-into-foreign-markets\u002F) about the low level of enforcement in this area in Australia.\n\nThese concerns are not unjustified. Since Australia first introduced foreign bribery laws, [only four companies and fewer than a dozen individuals](https:\u002F\u002Fone.oecd.org\u002Fdocument\u002FDAF\u002FWGB(2022)15\u002Fen\u002Fpdf) have been sanctioned. Many other investigations failed to result in sanctions since they fell short of the current law’s rigid requirements. The authors of the forthcoming amendments argue that the reforms will address these criticisms by overcoming the limitations of the currently [“overly prescriptive and difficult to use”](https:\u002F\u002Fparlinfo.aph.gov.au\u002FparlInfo\u002Fsearch\u002Fdisplay\u002Fdisplay.w3p;query=Id%3A%22legislation%2Fems%2Fr7055_ems_f4929a53-6cf5-4ea3-95b7-3689e6c81df9%22) version of the law.\n\nSo, what changes do these amendments introduce? What issues do they address? And most importantly, what impact will they have?\n\n### The anticipated changes: expanding scope and reducing burden of proof\n\nIn a nutshell, [the amendments](https:\u002F\u002Fparlinfo.aph.gov.au\u002FparlInfo\u002Fsearch\u002Fdisplay\u002Fdisplay.w3p;query=Id%3A%22legislation%2Fems%2Fr7055_ems_f4929a53-6cf5-4ea3-95b7-3689e6c81df9%22) significantly expand the scope of the law. Amongst other things, they:\n\n*   broaden the foreign bribery offence to include the bribery of a political “candidate” (and not just current holders of public office);\n*   extend the offence to cover bribery payments made to gain “personal” advantages, rather than only payments made for “business” advantages;\n*   remove the requirement to demonstrate that an advantage obtained through bribery is “not legitimately due”, and replace it with a requirement to demonstrate that the bribing party had an intention of “improperly influencing” the official in question;\n*   remove the requirement to demonstrate that an official was influenced in the exercise of their official duties; and\n*   clarify that it is not necessary for the prosecution to prove that the bribing party sought to obtain a specific advantage.\n\n### A new corporate liability offence\n\nThe most important amendment is arguably the creation of a new, absolute liability offence targeting companies that “fail to prevent bribery of a foreign public official”. Under this [new provision](https:\u002F\u002Fwww.ato.gov.au\u002Flaw\u002Fview\u002Fdocument?docid=PAC\u002F20240005\u002FSch1-Cl8), a company may be found to have committed an offence when “an associate” of the company has committed bribery to obtain a “profit or gain” for that entity.\n\nThis is a dramatic change to the current law. The current version of the law requires prosecutors to prove that either the company’s board or high-level managers committed the relevant bribery acts, or that the company had a corporate culture that tolerated non-compliance, for the company itself to be found liable. The new offence will significantly lower the prosecution’s burden of proof, in effect making it possible to hold companies liable under a much wider set of circumstances (e.g. where the company’s executives have turned a blind eye to the corrupt acts of their employees).\n\nNotably, the amendments also provide companies with an avenue to rebut this offence if they can prove they had adequate procedures in place to prevent foreign bribery by their associates. In order to inform businesses about what constitutes “adequate procedures”, the Australian Minister of Justice now has a duty to publish guidance on the steps companies can take to prevent associates from bribing officials.\n\n### Anticipated effect: increased enforcement and stronger prevention\n\nThe authors of these amendments [claim](https:\u002F\u002Fparlinfo.aph.gov.au\u002FparlInfo\u002Fsearch\u002Fdisplay\u002Fdisplay.w3p;query=Id%3A%22legislation%2Fems%2Fr7055_ems_f4929a53-6cf5-4ea3-95b7-3689e6c81df9%22) that the changes will ensure the law keeps pace with evolving foreign bribery schemes, and will overcome the challenges of establishing corporate criminal liability in cases of wilful blindness. They also argue that the removal of some of the prescriptive conviction requirements of the foreign bribery offence and the broadening of its scope will allow prosecutors to pursue foreign bribery charges in more cases.\n\nThe amendments are largely modelled on similar reforms made in the United Kingdom in 2010, which [directly contributed](https:\u002F\u002Fparlinfo.aph.gov.au\u002FparlInfo\u002Fsearch\u002Fdisplay\u002Fdisplay.w3p;query=Id%3A%22legislation%2Fems%2Fr7055_ems_f4929a53-6cf5-4ea3-95b7-3689e6c81df9%22) to a substantial increase in enforcement actions. [According to the OECD](https:\u002F\u002Fwww.oecd.org\u002Fcontent\u002Fdam\u002Foecd\u002Fen\u002Ftopics\u002Fpolicy-sub-issues\u002Ffighting-foreign-bribery\u002Foecd-anti-bribery-convention-enforcement-data-2009-2021.pdf\u002F_jcr_content\u002Frenditions\u002Foriginal.\u002Foecd-anti-bribery-convention-enforcement-data-2009-2021.pdf), before 2010 the UK had sanctioned only one individual and one company for foreign bribery. By 2021, the UK had criminally sanctioned 25 individuals and 16 companies. Of those 16 companies, eight were specifically sanctioned for failure to prevent bribery offences.\n\nAs in the UK, Australia’s amendments and new failure to prevent foreign bribery offence will broaden the jurisdictional scope of law and lower the prosecution’s evidentiary burdens. Therefore, it is not unreasonable to suggest that they will result in a similar increase in enforcement actions.\n\n### Incentivising compliance\n\nIn addition, these amendments are likely to enhance prevention efforts by incentivising companies to implement their own procedures to prevent foreign bribery. The UK reforms on which they changes were modelled also resulted in an increase in corporate compliance programmes. According to the OECD, the failure to prevent bribery offence and its “adequate procedures” defence in particular prompted the adoption of [“well advanced” anti-corruption corporate compliance measures](https:\u002F\u002Fwww.oecd.org\u002Fen\u002Fpublications\u002Fimplementing-the-oecd-anti-bribery-convention-phase-4-report-united-kingdom_888c5655-en.html).\n\nThere is a strong argument that these amendments will encourage similar action in Australia, as companies that implement such programmes will effectively shield themselves from liability for failing to prevent foreign bribery committed by their associates.\n\n### A step forward\n\nIt is encouraging to see Australia adopting substantial reforms to enhance its enforcement of the OECD Anti-Bribery Convention. On paper, these amendments look as if they will enable the prosecution of foreign bribery in a broader range of circumstances. They should also encourage more Australian companies to implement effective anti-bribery programmes.\n\nIdeally, these changes will noticeably improve Australia’s foreign bribery enforcement, and placate the ongoing concerns that Australia is not doing enough to fulfil its obligations under the OECD Anti-Bribery Convention.","2024-08-07",[29],"australia-is-cracking-down-on-foreign-bribery-2661",[540],2661,[45],[540],[778],"Main page",{"id":780,"storage":50,"filename_disk":781,"filename_download":547,"title":768,"type":548,"created_on":782,"modified_on":782,"charset":15,"filesize":783,"width":784,"height":785,"duration":15,"embed":15,"description":15,"location":15,"tags":15,"metadata":786,"focal_point_x":15,"focal_point_y":15,"tus_id":15,"tus_data":15,"uploaded_on":782},"802fdb9d-71aa-4aa7-a028-b9b3bcb9ee0a","802fdb9d-71aa-4aa7-a028-b9b3bcb9ee0a.webp","2025-05-12T21:10:35.000Z",87884,1400,748,{},[788],{"id":789,"news_id":790,"countries_id":804},7115,{"id":765,"status":14,"user_created":63,"date_created":766,"user_updated":64,"date_updated":767,"title":768,"type":533,"body":769,"image":780,"date":770,"topic":791,"slug":772,"activity":792,"nid":774,"topics":793,"activities":794,"programme":15,"area":15,"websites":795,"translation_of":15,"language":15,"countries":796,"tags":797,"authors":799,"images":801,"translations":802,"content":803},[29],[540],[45],[540],[778],[789],[798],5690,[800],1106,[],[],[],{"id":6,"name":4,"code":128,"latitude":129,"longitude":130},[806],{"id":798,"news_id":807,"tags_id":819},{"id":765,"status":14,"user_created":63,"date_created":766,"user_updated":64,"date_updated":767,"title":768,"type":533,"body":769,"image":780,"date":770,"topic":808,"slug":772,"activity":809,"nid":774,"topics":810,"activities":811,"programme":15,"area":15,"websites":812,"translation_of":15,"language":15,"countries":813,"tags":814,"authors":815,"images":816,"translations":817,"content":818},[29],[540],[45],[540],[778],[789],[798],[800],[],[],[],{"id":184,"name":185},[821],{"id":800,"news_id":822,"authors_id":834},{"id":765,"status":14,"user_created":63,"date_created":766,"user_updated":64,"date_updated":767,"title":768,"type":533,"body":769,"image":780,"date":770,"topic":823,"slug":772,"activity":824,"nid":774,"topics":825,"activities":826,"programme":15,"area":15,"websites":827,"translation_of":15,"language":15,"countries":828,"tags":829,"authors":830,"images":831,"translations":832,"content":833},[29],[540],[45],[540],[778],[789],[798],[800],[],[],[],{"id":835,"name":836,"position":15,"image":15},538,"Ryan Carter",[],[],[],{"id":841,"status":14,"date_created":842,"date_updated":843,"title":844,"type":533,"body":845,"date":846,"topic":847,"slug":849,"activity":850,"nid":851,"topics":852,"activities":853,"programme":15,"area":15,"websites":854,"language":15,"image":855,"translation_of":15,"countries":865,"tags":883,"authors":900,"images":901,"translations":902,"content":903},10384,"2023-08-07T16:01:34.000Z","2025-08-31T23:14:40.000Z","The Crown Resorts anti-money laundering fine: a wake-up call for the gambling industry","_A blog by Zisheng Xing, a law student at the Arizona State University who is undertaking a legal research internship at the Basel Institute on Governance._\n\nA monumental anti-money laundering fine recently dropped in Australia, sending shockwaves throughout the gambling industry – a sector well-known for flying under the radar of anti-money laundering and counter financing of terrorism (AML\u002FCFT) regulations.\n\nOn 11 July 2023, the Federal Court of Australia ordered the Australian gambling giant Crown Resorts (“Crown”) to pay an AUD 450 million (USD 300 million) fine for repeatedly violating the _Anti-Money Laundering and Counter-Terrorism Financing Act 2006_ (“AML\u002FCFT Act”) between 2015–2022. \n\nThe fine resulted from an agreement between Crown and Australia’s financial intelligence unit, AUSTRAC. This significant penalty is one of the largest in the gambling industry and serves as a severe reminder to casinos to implement and maintain effective AML\u002FCFT systems.\n\n### How did Crown breach Australia’s AML\u002FCFT Act?\n\nThe Australian Federal Court [found](https:\u002F\u002Fwww.judgments.fedcourt.gov.au\u002Fjudgments\u002FJudgments\u002Ffca\u002Fsingle\u002F2023\u002F2023fca0782) that Crown’s Melbourne and Perth casinos:\n\n*   failed to implement transaction monitoring programmes that were “appropriate to the nature, size and complexity of their business”;\n*   lacked “appropriate procedures to ensure higher risk customers were subjected to extra scrutiny” in their “enhanced customer due diligence” programmes;\n*   failed to conduct “appropriate ongoing customer due diligence on a range of specific customers who presented higher money laundering risks”;\n*   failed to maintain effective “risk-based systems and controls in their AML\u002FCFT programs”;\n*   failed to appropriately identify, timely assess and respond to ML\u002FTF risks they faced; and\n*   failed to establish appropriate frameworks for management oversight.\n\nWhen assessing the propriety of the penalty, the Federal Court concluded that Crown’s violations were “systemic, longstanding and egregious” and that they permeated “every designated service” that the enterprise provided its customers.\n\n### Risks posed by junkets\n\nA key finding of proceedings was that Crown had shown “a fundamental lack of regard” for the risk posed by junket operators. Junket operators are third parties who enter into agreements with casinos to facilitate gambling for high rollers. Junket operations often involve heightened AML risk, on the basis that they enable transfers of large amounts of money between jurisdictions. These transfers are administered in such a way that the source and ownership of funds involved can be easily obscured.\n\nMany of Crown’s contraventions were based on their relationship with such operations – even when the risks they presented were obvious. For example, AUSTRAC stated that Crown continued a “business relationship with a major casino junket operator” while “aware of allegations the operator was connected to organised crime.\"\n\nAdditionally, AUSTRAC noted at least 75 “suspicious incidents” involving approximately AUD 23 million in cash found in a private gaming room to which Crown Melbourne had given a junket operator exclusive access.\n\n### Why is this decision significant for AML\u002FCFT?\n\nAs [outlined](https:\u002F\u002Fwww.austrac.gov.au\u002Fnews-and-media\u002Fmedia-release\u002Ffederal-court-makes-ruling-crown-matter) by AUSTRAC, “the casino industry by its very nature, faces serious risks of exploitation by criminals seeking to launder the profits of their illicit enterprises.”\n\nConsequently, it is crucial that enterprises involved in this industry strictly implement and maintain strong AML measures and comply with relevant state laws. The penalty imposed on Crown is a clear warning to the entire gambling industry that its AML\u002FCFT compliance systems must be strong enough to meet obligations and “protect the… community and their businesses from serious financial crime.”\n\nThe decision also shows the importance of significant civil or administrative sanctions to enforcing compliance. As highlighted in our [quick guide to money laundering through the gambling industry](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-28-money-laundering-through-gambling-industry), proportionate penalties such as these both deter future breaches and encourage casinos to invest in robust AML\u002FCFT programmes.\n\n### Learn more\n\n*   View our [quick guide](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2022-09\u002FQG28%20gambling.pdf) to money laundering through the gambling industry by Isys Lam and Andrew Dornbierer.\n*   For more on money laundering risk assessment more generally, see the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) – the Basel Institute’s flagship index of money laundering and terrorist financing risks around the world.","2023-08-07",[848],"Anti-Money Laundering","the-crown-resorts-anti-money-laundering-fine-a-wake-up-call-for-the-gambling-industry-2496",[22],2496,[848],[],[778],{"id":856,"storage":50,"filename_disk":857,"filename_download":858,"title":844,"type":548,"created_on":859,"modified_on":860,"charset":15,"filesize":861,"width":862,"height":863,"duration":15,"embed":15,"description":15,"location":15,"tags":15,"metadata":864,"focal_point_x":15,"focal_point_y":15,"tus_id":15,"tus_data":15,"uploaded_on":860},"4ba38771-e903-4845-9203-549526518d27","4ba38771-e903-4845-9203-549526518d27.webp","Alex Proimos from Sydney, Australia, via Wikimedia Commons.webp","2025-05-12T21:11:43.000Z","2026-05-06T07:35:09.000Z",238556,1600,1067,{},[866],{"id":867,"news_id":868,"countries_id":882},7170,{"id":841,"status":14,"user_created":63,"date_created":842,"user_updated":869,"date_updated":843,"title":844,"type":533,"body":845,"image":856,"date":846,"topic":870,"slug":849,"activity":871,"nid":851,"topics":872,"activities":873,"programme":15,"area":15,"websites":874,"translation_of":15,"language":15,"countries":875,"tags":876,"authors":878,"images":879,"translations":880,"content":881},"b0662e2a-864d-4888-a1b7-4342b7570b30",[848],[22],[848],[],[778],[867],[877],5706,[],[],[],[],{"id":6,"name":4,"code":128,"latitude":129,"longitude":130},[884],{"id":877,"news_id":885,"tags_id":897},{"id":841,"status":14,"user_created":63,"date_created":842,"user_updated":869,"date_updated":843,"title":844,"type":533,"body":845,"image":856,"date":846,"topic":886,"slug":849,"activity":887,"nid":851,"topics":888,"activities":889,"programme":15,"area":15,"websites":890,"translation_of":15,"language":15,"countries":891,"tags":892,"authors":893,"images":894,"translations":895,"content":896},[848],[22],[848],[],[778],[867],[877],[],[],[],[],{"id":898,"name":899},818,"Anti-money laundering",[],[],[],[],4,1780676674449]