Thailand
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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. Clean, 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. Amid 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. Their 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 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. Regional co-operation and the role of Collective Action Recognising 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 ACI , co-led by the OECD and Asian Development Bank. The 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. These 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. Spotlight on innovation: Promising business integrity initiatives across the region From risk mapping to regulatory reform, here are standout examples of how countries are taking action through public-private initiatives: Australia: The Bribery Prevention Network 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. India: The Maritime Anti-Corruption Network, 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. Hong Kong, China: The Independent Commission Against Corruption 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. Thailand: In 2024, the Thai government amended its procurement law to recognise certification by the Thai Collective Action Against Corruption 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. These 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. By 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. Building a regional community of practice To sustain momentum, the OECD and the Basel Institute on Governance have launched a regional community of practice. In 2023, the Asia-Pacific Collective Action Forum 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. Encouraged 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. This regional community has created a meaningful space for peer learning and experience sharing. It has also contributed to greater alignment with international standards. Looking ahead: co-operation as the path forward These developments show that business integrity reforms are not only possible but already underway. In 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. Although 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. Learn more and get engaged OECD work on fighting foreign bribery OECD and ADB Anti-Corruption Initiative for Asia and the Pacific B20 Collective Action Hub by the Basel Institute on Governance Working Paper 48: A collaborative approach to improve business integrity in ASEAN by Lucie Binder, Vanessa Hans and Anna Stransky, Basel Institute on Governance Working Paper 56: Anti-corruption Collective Action: A typology for a new era by Scarlet Wannenwetsch, Basel Institute on Governance
How do SMEs and business associations benefit from anti-corruption Collective Action?
An entrepreneur and vocal supporter of anti-corruption Collective Action, Norwegian-born Vibeke Lyssand Leirvag has two interesting perspectives: as a small business owner in Thailand and as Chairwoman of the Joint Foreign Chambers of Commerce. In this short interview on the sidelines of the Basel Institute’s International Collective Action Conference, Vibeke explained how engaging in a Collective Action initiative can help make the voice of business – whether an SME or a Chamber of Commerce – heard in matters of business integrity and fair competition. Video file “I'm from Norway originally, but I have been in Thailand for 35 years. I own a jewellery manufacturing company called Felicia Design, where we have 150 workers – I would consider that we are the M in SMEs. I'm also the chairwoman of the Joint Foreign Chambers of Commerce in Thailand, representing 36 chambers and around 9,000 companies, where 80 percent are SMEs. Value of Collective Action for SMEs I feel that Collective Action is extremely important for SMEs. First, it gives SMEs a voice. It gives them a platform and a network where they can communicate their challenges. And second, being in a collective network gives SMEs access to tools and opportunities. As an example, in Thailand, we have the Thai Coalition Against Corruption Thai CAC , which offers clinics that train staff on the ground. We also have an “OECD regulations toolkit”, which is very helpful to SMEs. To engage in Collective Action and work towards zero corruption requires finances. Very often SMEs will look at anti-corruption compliance as a cost. To me, it is not a cost. I think you invest in what is right. You invest in ethics and a good moral compass. And that will actually create opportunities. How business associations can benefit For the Joint Foreign Chambers of Commerce, Collective Action gives us a platform to have influence and to speak with the government. It gives us a platform to make sure that the policies that are put in place are actually functional. In other words, that these are policies that businesses can work with – both larger corporations and SMEs. So I think Collective Action is effective, and I think it's very important that we make sure government, civil society, private sector and academia work together.” Learn more See more Q&As with leading voices in promoting anti-corruption Collective Action, together with photos and videos, on the web page of our 2024 International Collective Action Conference. Learn more about Collective Action and how to engage on the B20 Collective Action Hub.
Why Thai SMEs are seeking anti-corruption certification through Collective Action
Multinational companies are no strangers to problems of corruption in their supply chains, which can bring significant legal, financial and reputational risks. Especially when entering new markets, many companies find it difficult to identify credible local partners and to assess their adherence to anti-corruption regulations. Anti-corruption Collective Action can be a means of bridging this gap and facilitating market access for both multinational companies and local suppliers or partners. Some Collective Action initiatives offer certification as a way to support their members in strengthening their anti-corruption credentials. One such initiative is the Thai CAC, a key player in the field of Collective Action in Thailand. The Thai CAC has made remarkable progress since its establishment in 2010, and through the Collective Action initiative, has certified over a thousand companies. With the support of Thailand’s key business associations, the certification process strengthens the private sector in its implementation of Thailand’s national strategic goal to counter corruption set by the National Anti-Corruption Commission. With the support of the Basel Institute’s Collective Action team, the Thai CAC is now seeking to engage small and medium-sized enterprises SMEs in its certification programmes. What benefits do SMEs see in engaging in Collective Action and achieving certification for their anti-corruption practices? Among the beneficiaries of the Thai CAC’s certification programme for SMEs is Felicia Design, a fine jewellery manufacturer. The company is led by Vibeke Lyssand Leirvag, Founder & Managing Director, and Domenica Piantedosi, General Manager. The following excerpts from their interview with the CAC demonstrate how their business has benefitted from the certification. “Corruption is a disease of societies just as cancer is of people.” According to Domenica Piantedosi, corruption in Thailand remains pervasive, which impacts all of society: “It undermines public trust and leads to wasting resources.” Ms. Piantedosi also highlighted mistrust in the private sector, which can impact international business operations. For Vibeke Lyssand Leirvag corruption is always a choice and engaging in it was never part of their companies’ values. Although most SMEs fear that they are too small to have a voice in the fight against corruption, Ms. Lyssand Leirvag is convinced that: If the majority has the will, a corruption system can be changed. She claims that refusal to engage needs to be followed by taking a stand against corruption, thus not implicitly allowing corrupt practices to happen. Anti-corruption certification for SMEs has benefits externally… One external advantage of Collective Action efforts like the Thai CAC certification programme lies in its capability to empower small-scale businesses and build trust in international markets. Especially Felicia Design, with most its clients based in Scandinavia, needs to “comply with foreign laws and/or stock-exchange regulations”. The CAC certification can help small businesses set up these policies and procedures, thus reducing the risk on both sides. Moreover, Vibeke Lyssand Leirvag and Domenica Piantedosi benefit from the use of the Thai CAC certification in their external communications. This not only conveys their respect for ethical business practices to their supply chain but also to their customers. Through certification, SMEs are empowered to actively prevent corruption and to take a visible stance against corrupt practices. This illustrates one way that Collective Action has the power to change society. Any company that feels this way should join CAC because together we can change the system. \ …\ Changes will take hold only when the majority applies these principles. …and internally: Engagement with the Thai CAC helps beneficiary companies to strengthen policies and internal controls tailored to the Thai context. This ensures management and employees are trained and take ownership of corruption prevention. The Thai CAC understands the constraints of SMEs and helps them formalise and effectively communicate internal policies and controls. Similarly, Felicia Design has profited from the CAC through strengthening its existing anti-corruption policies and training. Domenica Piantedosi states that: Joining CAC allowed us to reinforce the anti-corruption message to our staff \ through\ the \ tailored\ CAC training courses and \ ...\ helped our staff have a better understanding of the reasons behind some of our policies for example, the ‘no gifts policy’. Both management and staff benefit from this improvement of mutual understanding through more effective communication. Vibeke Lyssand Leirvag particularly stresses that it helped convey to their staff “that we practise what we preach.” What does the future hold? Supported by our Collective Action team with funding from the KBA-Notasys Integrity Fund, the Thai CAC is working to extend its certification scheme to engage more SMEs. The Thai CAC approach has already been replicated in Indonesia. This model has potential for duplication in other countries which would in turn positively impact SMEs looking at engaging in international supply chains. Learn more Read the original interview between the Thai CAC and Felicia Design here. Learn more about the benefits of local certification in this Working Paper. Read about the collaboration between the Thai CAC and the Basel Institute. Find out more about local certification initiatives in other regions on the B20 Collective Action Hub, a global resource centre for information and inspiration on anti-corruption Collective Action. Did you know the Basel Institute’s Collective Action team operates a free Mentoring Programme for new and established Collective Action initiatives? Visit our Helpdesk to have your personal question concerning anti-corruption Collective Action answered.
Renewed MoU signals fresh commitment to cooperate in fighting corruption in Thailand
The Thai National Anti-Corruption Commission NACC has renewed a long-standing Memorandum of Understanding MoU with the Basel Institute on Governance to jointly foster the prevention of and international collaboration in the fight against corruption. The President of the NACC, Pol. General Watcharapol Prasarnkrajkit, and Mrs Phyllis Atkinson, Head of Training at the Basel Institute’s International Centre for Asset Recovery ICAR , took part in a signing ceremony at the NACC premises in Bangkok on 8 July 2019. The ceremony was witnessed by the Swiss Ambassador, the Honourable Mr Ivo Siber, NACC Commissioners and its Secretary General. Deepening a strong and fruitful partnership The NACC President explained that the MoU, which has been in existence since 2011, has created a strong partnership that enhances the sharing of anti-corruption knowledge and expertise between the NACC, the Basel Institute and other stakeholders. The extension, he said, would further strengthen the relationship, as well as provide further opportunities for capacity building with regard to mutual legal assistance and investigations for asset tracing and recovery. The importance of financial investigation for anti-corruption The President reminded all present that tracing, identifying and recovering assets are important elements of the anti-corruption measures set out in the United Nations Convention against Corruption UNCAC and international standards. He also acknowledged that financial investigation is key to corruption enforcement and anti-money laundering measures. Financial investigation is a first step in providing evidence for effective prosecution in corruption cases, recovering assets and investigating unexplained or “unusual” wealth. He emphasised that the NACC recognises the importance of financial investigations and therefore encourages capacity-building amongst NACC investigators. This will allow them to remain abreast of new developments and to learn from international experts, including the ICAR training team. He hoped that the workshop following the signing to be conducted by Phyllis Atkinson would achieve its goal and that all NACC investigators would benefit greatly from the knowledge shared and implemented. Hands-on discussion of key components of financial investigations Following the signing ceremony, Phyllis Atkinson gave a presentation on "Key Components of Financial Investigations" to approximately 90 NACC officers. It focused on methods used to conceal the proceeds of crime and approaches to tracing and recovering such proceeds. The participants discussed the practical implementation of financial investigative techniques on the basis of an exercise aimed at determining the disparity between a suspect's legal and known income and his expenditure. They were introduced to the “Source and Application Analysis of Funds” method as a means of determining "unusual wealth" in terms of Thailand's 2018 Organic Law on Anti-Corruption. Feedback indicated that the participants "liked the presentation" and "want the session to be longer than half-day and more intensive as they gained knowledge for their work". We are always delighted to receive this type of feedback on our training courses and note that it is fully in keeping with the terms of the renewed MoU.
Three-day workshop in Basel on the role of good governance and anti-corruption in the context of national development for senior executives of Thailand
At the request of the National Anti-Corruption Commission NACC of Thailand, the Basel Institute carried out a three-day executive workshop on the role of good governance and anti-corruption in the context of national development for senior executives from various relevant public offices and related institutions of Thailand. The workshop took place from 9 to 11 September at the University of Basel and covered specific topics such as international trends and developments in anti-corruption, private sector corruption prevention and Collective Action, the role of good good governance and anti-corruption for development, trends and developments in preventing money laundering in Switzerland, as well as anti-corruption law enforcement and the recovery of stolen assets. The audience included some 60 senior Thai professionals from key public operators, including institutions such as the NACC itself, the Department of Public Works, the Office of the National Economic and Social Development Board, the Bank for Agriculture, the Office of Constitutional Court, the Audit Office and the Electricity Generating Authority of Thailand, to name just a few. Back in 2011 the Basel Institute and the NACC of Thailand signed an official Memorandum of Understanding with the intent to establish a strong partnership for the purpose of enhancing the sharing of anti-corruption knowledge and expertise between the two parties and other relevant stakeholders as appropriate. It is in line with this partnership arrangement that the Basel Institute regularly engages with the NACC to develop and implement joint activities intended to prevent and combat corruption as well as to promote anti-corruption research and training activities.
Publications
Case Study 14: Madagascar: a landmark conviction for money laundering linked to environmental crime
This Case Study demonstrates how international cooperation and the follow-the-money approach revealed a transnational criminal network trafficking endangered species and led to Madagascar’s first money laundering conviction related to wildlife trafficking.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
Photo: Studio Sifaka / khaosodenglish (used with permission).
The Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery. This case relates to the Basel Institute’s Green Corruption programme.
The development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.
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.
Working Paper 48: A collaborative approach to improve business integrity in ASEAN: Case studies of anticorruption Collective Action in the region
This working paper provides an overview and analysis of anti-corruption Collective Action case studies in the ASEAN region. It builds on the 2014 paper: Collective Action against Corruption: Business and Anti-Corruption Initiatives in ASEAN, which was published by the ASEAN CSR Network and the Asian Institute of Management.
This 2023 paper reviews the initiatives featured in the 2014 paper and highlights new initiatives that have emerged in the region since then. It covers:
- Indonesia: Indonesia Business Links
- Malaysia: Corporate Integrity System Malaysia
- Philippines: Integrity Initiative and project SHINE
- Thailand: Collective Action Against Corruption
- Thailand: Anti-Corruption Organization of Thailand
- Vietnam: Vietnam Chamber of Commerce & Industry and its Office for Business
The analysis identifies several success factors, while noting that Collective Action is a flexible approach that can and must be tailored to different contexts.
About this Working Paper
The authors would like to thank the Asian Institute of Management and the representatives of the initiatives featured in this paper for their time and contributions.
This paper is made possible through the support of the Siemens Integrity Initiative.
The publication is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. You may share or republish the Working Paper under a Creative Commons Attribution NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
Suggested citation: Binder, Lucie, Vanessa Hans, and Anna Stransky. 2023. ‘A collaborative approach to improve business integrity in ASEAN: Case studies of anti-corruption Collective Action in the region.’ Working Paper 48, Basel Institute on Governance. Available at: https://baselgovernance.org/publications/wp48.
Working Paper 38: Cryptocurrencies in Asia and beyond: law, regulation and enforcement
The crypto industry has exploded in recent years, and authorities in different countries have been reacting in very different ways. Some have banned cryptocurrencies, while others are embracing them to varying degrees. Some are working hard to align their anti-money laundering regulations with FATF standards, while others are turning a blind eye. A few countries have confiscated huge quantities of crypto assets linked to crime and money laundering. Others are at square one in terms of enforcement, risking becoming a hub for crypto crime and money laundering and posing a serious vulnerability in the world’s financial system.
This Working Paper draws on a detailed analysis of how selected countries are addressing legal, regulatory and enforcement issues around cryptocurrencies and other virtual assets. The analysis is focused on Asia, but set in the context of global trends in crypto law, regulation and enforcement. It explores critical questions that will shape policies around virtual assets at the corporate, national and international levels:
- What is working in terms of crypto regulation and enforcement?
- What are the implications of different policy choices on crypto assets – for the industry, for the countries themselves and for global financial integrity as a whole?
- What would the crypto wave possibly bring next?
The Paper also highlights broader developments needed to bring light and clarity to laws, policies and practices around the crypto industry, such as collaboration between both market players and governments.
Jurisdictions touched upon in this Working Paper alphabetically include Bhutan, Central African Republic, El Salvador, Hong Kong SAR, India, Indonesia, Japan, Kazakhstan, Malaysia, Myanmar, Russia, Singapore, South Korea, the Philippines, the People’s Republic of China, Thailand, Ukraine and Vietnam.
A list of key terms and abbreviations have been prepared in the Annex to this Working Paper for the readers’ easy reference.
About this Working Paper
This Working Paper is a collaboration between Dorothy Siron, Co-Managing Partner, Zhong Lun Law Firm LLP and Federico Paesano, Senior Financial Investigation Specialist, Basel Institute on Governance.
Dorothy Siron provided the bulk of the analysis and discussion, while Federico Paesano provided a selection of case studies and was co-author of the seven recommendations contained in section 4. The collaboration was facilitated by the International Academy of Financial Crime Litigators, an independent, non-partisan global centre that shapes and advances financial crime litigation practices for the future.
The publication is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. It is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
Suggested citation: Siron, Dorothy, and Federico Paesano. 2022. “Cryptocurrencies in Asia and beyond: law, regulation and enforcement.” Working Paper 38, Basel Institute on Governance. Available at: https://baselgovernance.org/publications/wp-38
Disclaimer: This Working Paper does not, and is not intended to, constitute and/or substitute legal or other professional advice. The content of this Working Paper is updated as of 4 May 2022 and is intended for general informational purposes only. No representations have been made as to its accuracy and completeness. You should seek independent legal or other professional advice before acting or relying on any of the information contained herein.
Thailand's Collective Action Coalition Against Corruption
This case focuses on a private sector initiative to fight deep-seated corruption in Thailand.
The Collective Action Coalition Against Corruption (CAC) was founded by a charismatic business scion in late 2010, but an untimely heart attack a few months later left CAC reeling. A new leader named Bandid Nijathaworn was suddenly responsible for delivering the rapid growth and good-faith commitments that his predecessor had envisioned.
At the center of this case, Dr. Bandid and his team considered raising standards, reorienting recruitment, and more, but they had to move quickly for the Collective Action Coalition to live up to its promise.