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Holding the corrupt to account: the promise and potential of corruption sanctions
3 June 2026

Holding the corrupt to account: the promise and potential of corruption sanctions

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. Here we share the foreword to his paper by the Basel Institute's Andrew Dornbierer, Head of Policy and Research, International Centre for Asset Recovery. Foreword 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. 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. 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. 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. 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. 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. 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. 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. Learn more Read Dr Anton Moiseienko’s Working Paper “Corruption sanctions: What governments need to know” for a deeper analysis of the topic and key policy recommendations. Get a brief introduction to corruption sanctions from our related Quick Guide. Register for our public webinar "Corruption sanctions – reaching those beyond the law" on 18 June 2026, marking the launch of Dr Moiseienko's Working Paper.

Publications

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Quick Guide 43: Corruption sanctions
Working Paper 62: Corruption sanctions: What governments need to know
Working Paper

Working Paper 62: Corruption sanctions: What governments need to know

28 May 2026·Basel Institute on Governance

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.

This 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.

Download the Working Paper here

Advantages and limitations of corruption sanctions

Corruption 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:

  • they can be applied regardless of any geographical link between the sanctioning state and the alleged corruption, based on relatively low evidentiary thresholds; and
  • 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.

However, 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.

Recommendations

Drawing 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.

The paper is aimed primarily at policymakers but will also be of interest to anti-corruption activists, private-sector financial crime specialists and academics.

About this paper

This 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 International Licence.

This 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.

The 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.

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