[{"data":1,"prerenderedAt":222},["ShallowReactive",2],{"country-united-kingdom":3,"country-news-united-kingdom-1":7,"country-stories-united-kingdom-1":10,"country-publications-united-kingdom-1":12},{"name":4,"ids":5},"United Kingdom",[6],74,{"items":8,"total":9},[],0,{"items":11,"total":9},[],{"items":13,"total":221},[14],{"id":15,"status":16,"sort":17,"date_created":18,"date_updated":19,"nid":20,"slug":21,"title":22,"body":23,"citation":24,"language":17,"year":25,"publisher":26,"date_published":27,"external":28,"topic":17,"link_internal":29,"link_external":33,"featured":28,"topics":34,"languages":36,"type":38,"area":17,"programme":17,"websites":17,"summary":17,"pdf_text":17,"main_points":17,"short_version":40,"subtitle":17,"image":41,"countries":53,"tags":134,"pdf":165,"authors":205},2436,"published",null,"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,"Basel Institute on Governance","2026-05-28",false,[30],{"url":31,"caption":32},"\u002Fresources\u002Fpublications?type=Working%20Paper","View all Working Papers",[],[35],"Asset Recovery and Enforcement",[37],"English",[39],"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":42,"storage":43,"filename_disk":44,"filename_download":45,"title":46,"type":47,"created_on":48,"modified_on":48,"charset":17,"filesize":49,"width":50,"height":51,"duration":17,"embed":17,"description":17,"location":17,"tags":17,"metadata":52,"focal_point_x":17,"focal_point_y":17,"tus_id":17,"tus_data":17,"uploaded_on":48},"0b54d63b-364d-478e-b7a6-29c8a4f6333b","local","0b54d63b-364d-478e-b7a6-29c8a4f6333b.jpg","WP62_Corruption-sanctions_cover.jpg","Working Paper 62_Corruption 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