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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

8 items
Quick Guide 43: Corruption sanctions
Working Paper 62: Corruption sanctions: What governments need to know
Case Study 11: International cooperation in the Migori County corruption case
Case Study

Case Study 11: International cooperation in the Migori County corruption case

18 Nov 2025·Basel Institute on Governance, Ethics and Anti-Corruption Commission (Kenya) and International Anti-Corruption Coordination Centre

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.

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).

It 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.

While 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.

Back in action: How the UK is reviving unexplained wealth orders (The Academy Bulletin)
Article

Back in action: How the UK is reviving unexplained wealth orders (The Academy Bulletin)

3 Nov 2025·International Academy of Financial Crime Litigators

In an article published in the Fall 2025 issue of the Bulletin of the International Academy of Financial Crime Litigators, Andrew Dornbierer explores the revival of unexplained wealth orders (UWOs) in the United Kingdom.

Introduced in 2017 as a tool to combat the abuse of UK’s markets to launder criminal proceeds, the UWO mechanism suffered a severe setback in 2020. After only a handful of attempts to use it, a decision by the High Court effectively left it sprawled on the canvas.

In the last year or so, however, the mechanism has slowly started to prove itself. Most recently, the UK’s Serious Fraud Office – in its first use of the UK’s UWO mechanism – secured GBP 1.1 million from the sale of a property belonging to the ex-wife of a convicted fraudster.

This article offers a short history of UWOs in the UK. It examines how, after a turbulent start and subsequent amendments to the mechanism, UWOs are now back to being used by UK authorities to tackle illicit financial flows. If applied responsibly, proportionately and in harmony with established legal rights, unexplained wealth orders promise to be a powerful tool in the UK’s fight to recover criminal assets.

This is the fifth issue of The Academy’s Bulletin. It has been established to transmit the work of Academy Fellows, draw attention to matters of importance to the legal community and provide high-level analysis of cutting-edge issues in global financial crime investigations and litigation. The Basel Institute on Governance acts as Secretariat to the Academy.

Working Paper 55: Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms
Working Paper

Working Paper 55: Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms

17 Feb 2025·Basel Institute on Governance

The UK is a global leader in its efforts to target foreign bribery. It is one of the only countries worldwide to use negotiated settlements such as deferred prosecution agreements (DPAs) to resolve cases and extract penalties from corporations that commit corruption abroad. The UK has also laudably committed to using the proceeds of DPAs in foreign bribery cases to compensate the victims of corruption, particularly in countries that suffer its worst effects.

This paper explores why the UK’s policy of compensating the victims of foreign bribery is not achieving its intended results in practice, and proposes realistic suggestions for improvement to the extant DPA regime.

It examines the conceptual, practical and political difficulties inherent in this undertaking, shining a light on how victim compensation operates in the UK and analysing judicial decisions on this issue. Finally, the paper proposes reform recommendations to strengthen the DPA regime to ensure appropriate compensation is made in foreign bribery settlements.

About this report

The 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.

The paper is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. 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.

Suggested citation: Hickey, Sam. 2025. ‘Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms.’ Working Paper 55, Basel Institute on Governance. Available at: baselgovernance.org/publications/wp-55.

A version of this paper is also published by the Transnational Criminal Law Review.

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