United Kingdom
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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
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)
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
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.