[{"data":1,"prerenderedAt":288},["ShallowReactive",2],{"news-2025-annual-report-and-foreword-by-peter-maurer-2829":3,"news-2025-annual-report-and-foreword-by-peter-maurer-2829-similar":57,"i-heroicons:arrow-left-20-solid":283},[4],{"id":5,"status":6,"date_created":7,"date_updated":8,"title":9,"type":10,"body":11,"date":12,"topic":13,"slug":15,"activity":16,"nid":17,"topics":18,"activities":19,"programme":20,"area":20,"websites":20,"language":21,"image":22,"translation_of":20,"countries":32,"tags":33,"authors":34,"images":54,"translations":55,"content":56},10560,"published","2025-07-13T11:42:44.000Z","2025-08-31T23:09:21.000Z","2025 Annual Report and foreword by Peter Maurer","Blog","2024 was a challenging year for the Basel Institute on Governance, marked by the tragic passing of our Managing Director Gretta Fenner in April. But we have continued building on her legacy and, in early 2025, welcomed our new Executive Director Betsy Andersen to lead us into the future.\n\nIn his foreword to our [2024 Annual Report](https:\u002F\u002Fbaselgovernance.org\u002Far2024), the Basel Institute's President Peter Maurer reflects on how our teams have worked with partners and allies to achieve tangible progress against corruption with the ultimate goal of a more peaceful, just and sustainable world:\n\n> 2024 was profoundly overshadowed by the sudden and tragic loss of our Managing Director, Gretta Fenner, who led the Basel Institute for nearly two decades. Under her dedicated and inspirational leadership, the Institute has become what it still exemplifies today: a distinguished, hands-on centre of expertise committed to advancing the global fight against corruption and striving to create a more peaceful, secure and sustainable world.\n> \n> After Gretta’s passing, I temporarily stepped in to guide the organisation and the team during a transition period whilst a new leadership was sought. This unexpected task gave me an even deeper understanding and appreciation of the Basel Institute’s distinctively multi-disciplinary, adaptable and impactful approach – a method that is essential for tackling corruption in today’s complex and shifting political landscapes. It also confirmed the Institute’s resilience in an increasingly volatile and fragmented world.\n> \n> The Institute’s strength lies first and foremost in our skilled global team and in our ability to provide independent, expert support to stakeholders across multiple sectors and regions. We also benefit from the unwavering and generous commitment of our donors and a broad network of partners, from the local grass roots to the international community.\n> \n> In 2024 these factors were especially visible in the context of our engagement in Ukraine. Despite enormous challenges, Ukraine’s government and society have kept anti-corruption efforts in focus and on track. We are proud to support them: from helping prevent corruption in infrastructure, transport and forestry, to strengthening private-sector integrity in reconstruction projects, to assisting with transnational asset recovery. This kind of holistic engagement is both challenging and vital for Ukraine’s security, as well as Europe’s.\n> \n> Across more than 30 country programmes and projects, 2024 brought significant successes. In these pages you’ll read about, for example:\n> \n> *   How we contributed to the confiscation or return of over CHF 50 million in precedent-setting asset recovery cases, and new breakthroughs in targeting the financial aspects of environmental crimes.\n> *   Steps towards preventing corruption in timber value chains, identifying red flags for corruption at EU borders and in public procurement processes, and shining a light on sexual corruption risks faced by students.\n> *   Our compliance assistance to safeguard investments in critical infrastructure projects and how we foster high-level support for anti-corruption Collective Action to strengthen business integrity.\n> *   In Peru, how citizens are seeing real results from better public finance management: infrastructure delivered on time and vital services like vaccines and schoolbooks reaching those who need them.\n> \n> Each success, and many others not mentioned here, brings us closer to a better governed and safer world.\n> \n> Empowering people is at the heart of everything we do. Our eLearning courses now reach over 53,000 learners worldwide. More than 800 anti-corruption and conservation practitioners collaborate in one of several communities of practice. And new postgraduate programmes with the University of Basel will help build the next generation of anti-corruption and asset recovery leaders.\n> \n> Anti-corruption work has always faced resistance, from entrenched interests to institutional backsliding. At the Basel Institute, we are well prepared to defend values of integrity, transparency and accountability.\n> \n> But in the face of increasing headwinds in the geopolitical environment, we can only continue to succeed by building coalitions, breaking silos and collectively innovating to address corruption’s harmful role in major global challenges – challenges like the energy transition, healthcare and security, as well as poverty and organised crime.\n> \n> This is the charge that our new Executive Director, Elizabeth “Betsy” Andersen now leads. Appointed by the Board in late 2024 following a rigorous selection process, Betsy brings deep legal expertise, strategic vision, run-with-it motivation and a wealth of leadership experience in the non‑profit sector.\n> \n> On behalf of the Board, I warmly welcome her, convinced that her steady hand will help us guide the Institute as we chart and navigate the future.\n\nView the [2024 Annual Report of the Basel Institute on Governance](https:\u002F\u002Fbaselgovernance.org\u002Far2024).","2025-07-09",[14],"","2025-annual-report-and-foreword-by-peter-maurer-2829",[14],2829,[],[],null,"English",{"id":23,"storage":24,"filename_disk":25,"filename_download":26,"title":9,"type":27,"created_on":7,"modified_on":7,"charset":20,"filesize":28,"width":29,"height":30,"duration":20,"embed":20,"description":20,"location":20,"tags":20,"metadata":31,"focal_point_x":20,"focal_point_y":20,"tus_id":20,"tus_data":20,"uploaded_on":7},"86cec7af-39d3-4c47-9cd8-5b004def85c4","local","86cec7af-39d3-4c47-9cd8-5b004def85c4.webp","tmp.webp","image\u002Fwebp",6676,800,533,{},[],[],[35],{"id":36,"news_id":37,"authors_id":50},1343,{"id":5,"status":6,"user_created":38,"date_created":7,"user_updated":39,"date_updated":8,"title":9,"type":10,"body":11,"image":23,"date":12,"topic":40,"slug":15,"activity":41,"nid":17,"topics":42,"activities":43,"programme":20,"area":20,"websites":20,"translation_of":20,"language":21,"countries":44,"tags":45,"authors":46,"images":47,"translations":48,"content":49},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","b0662e2a-864d-4888-a1b7-4342b7570b30",[14],[14],[],[],[],[],[36],[],[],[],{"id":51,"name":52,"position":20,"image":53},558,"Dr Peter Maurer","77976774-7119-48eb-9813-0979e38abf71",[],[],[],[58,86,106,132,164,187,211,240,260],{"id":59,"body":60,"status":6,"type":61,"date":62,"slug":63,"title":64,"image":65,"countries":66,"topic":69,"activity":72,"tags":74,"nid":75,"topics":76,"activities":77,"authors":78,"images":79,"websites":20,"area":20,"programme":20,"language":21,"translations":80,"translation_of":20,"user_created":38,"date_created":81,"user_updated":82,"date_updated":83,"content":84,"link":85},10574,"We are delighted to announce a new grant that will enable the Basel Institute on Governance to continue and expand its support to Ukraine on integrity and accountability.\n\nThrough the Government of Norway's [Nansen Support Programme for Ukraine](https:\u002F\u002Fwww.norad.no\u002Fen\u002Fthematic-areas\u002Fhumanitarian-assistance-and-comprehensive-response-and-the-nansen-programme-for-ukraine\u002Fthe-nansen-support-programme-for-ukraine\u002Fthe-nansen-support-programme-for-ukraine\u002Fhow-norad-fights-corruption-in-ukraine\u002F), the Basel Institute will work from 2025 to 2028 to promote transparency and accountability in three strategically vital sectors:\n\n*   Natural resources: Tackling corruption risks in forestry and the critical minerals sector, building on our long-standing work to combat [corruption in Ukraine’s forestry industry](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fdeepdive1-ukraine) and the expertise of our wider [Green Corruption programme](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption).\n*   Energy: Supporting transparency and accountability in energy-related enterprises. In the first year, this will begin with our collaboration with the Gas Transmission System Operator of Ukraine (Gas TSO), a vital state-owned enterprise with which we recently [signed a Memorandum of Understanding](https:\u002F\u002Fwww.facebook.com\u002Fgas.tso.ua\u002Fphotos\u002F%D0%BE%D0%BF%D0%B5%D1%80%D0%B0%D1%82%D0%BE%D1%80-%D0%B3%D1%82%D1%81-%D1%83%D0%BA%D1%80%D0%B0%D1%97%D0%BD%D0%B8-%D1%80%D0%BE%D0%B7%D0%BF%D0%BE%D1%87%D0%B0%D0%B2-%D1%81%D0%BF%D1%96%D0%B2%D0%BF%D1%80%D0%B0%D1%86%D1%8E-%D0%B7-%D0%B1%D0%B0%D0%B7%D0%B5%D0%BB%D1%8C%D1%81%D1%8C%D0%BA%D0%B8%D0%BC-%D1%96%D0%BD%D1%81%D1%82%D0%B8%D1%82%D1%83%D1%82%D0%BE%D0%BC-%D1%83%D0%BF%D1%80%D0%B0%D0%B2%D0%BB%D1%96%D0%BD%D0%BD%D1%8F-%D0%BE%D0%BF%D0%B5%D1%80\u002F1414177947376981\u002F) to establish a comprehensive anti-corruption compliance system.\n*   Defence industries: Strengthening compliance and integrity systems in defence manufacturers as they produce vital materiel for Ukraine’s defence and integrate with Europe’s broader security architecture. This builds on our ongoing partnership with [Ukraine Defense Industries](https:\u002F\u002Fukroboronprom.com.ua\u002Fen\u002Fupravlinnya-ta-komplajens\u002Fat-uop-i-bazelskii-institut-upravlinnya-proveli-persu-zustric-v-ramkax-spivpraci-shhodo-posilennya-vnutrisnix-komplajens-spromoznosteiopk) (UkrOboronProm or UOP).\n\n### Strengthening integrity where it matters most\n\nThis programme is significant because natural resources, energy and defence are at the heart of Ukraine’s resilience and recovery. They are essential for the country’s security, economic stability and EU integration – yet also among the most vulnerable to corruption.\n\nWeak governance in these sectors risks undermining resilience, slowing reconstruction and eroding donor confidence.\n\nThe Government of Norway [recognises](https:\u002F\u002Fwww.norad.no\u002Fen\u002Fthematic-areas\u002Fhumanitarian-assistance-and-comprehensive-response-and-the-nansen-programme-for-ukraine\u002Fthe-nansen-support-programme-for-ukraine\u002Fthe-nansen-support-programme-for-ukraine\u002Fhow-norad-fights-corruption-in-ukraine\u002F) that “combating corruption and building strong institutions are central” to achieving the goals of its comprehensive Nansen Support Programme, which aims to “help secure a safe, free and independent Ukraine, strengthen vital state functions and reduce human suffering”. Like the Basel Institute, our partners in Norway acknowledge Ukraine’s progress in tackling corruption and the strong commitment of Ukrainian civil society and the public to building robust anti-corruption institutions.\n\n### Sustaining Ukraine’s path to resilience\n\nJorun Nossum, Director of Norad’s Department for the Nansen Support Programme, said:\n\n> We are very pleased to be able to continue our partnership with Basel Institute on Governance in working to prevent corruption in sectors central to Ukraine’s resistance and reforms.\n\nJuhani Grossmann, who leads the Basel Institute’s work in Ukraine and the opening of our new office in Kyiv, commented:\n\n> The support of Norway allows us to boost our integrity-building partnerships in Ukraine for the long term at a time when reliability is especially crucial. The three priority areas have been carefully selected to reflect both Ukraine's immediate needs and the desire for a sustainable recovery.\n> \n> Our natural resource partnerships will seek to ensure Ukraine’s people derive the maximum benefit from its environment and natural resources. Our energy partnerships will help build trustworthy energy partners as Ukraine integrates into European energy markets. Our defence partnerships are designed to enable Ukraine’s manufacturers to reap the full benefits for Ukraine’s security from their technical prowess.\n> \n> Enhanced and more compliant corporate structures will unlock Ukraine’s full potential to contribute to Europe’s emerging security infrastructure.\n\n### A decade of partnership with Ukraine\n\nAs featured in the [Basel Institute’s Annual Report 2024](https:\u002F\u002Fbaselgovernance.org\u002Far2024), we have been engaged in Ukraine for over a decade, supporting both corruption prevention and enforcement.\n\nOn the prevention side, our work since 2013 has included Collective Action and compliance initiatives in government permitting and corporate governance. We have also advised on the establishment of the Business Ombudsman, provided guidance to the Ukrainian Road Authority and supported independent commissions tasked with recruiting leaders of Ukraine’s anti-corruption institutions.\n\nFollowing the full-scale invasion in 2022, we significantly expanded our anti-corruption support, recognising it as both a contribution to Ukraine’s long-term European integration and to its short-term wartime resilience.\n\nWith significant funding from Switzerland and contributions from the European Bank for Reconstruction and Development and NEFCO, we have helped Ukrainian authorities and state-owned enterprises ensure the integrity of the wartime economy and reconstruction efforts. Priority areas have included restoration, transport and natural resources.","News","2025-10-20","strengthening-integrity-in-ukraines-natural-resources-energy-and-defence-sectors-with-norways-support-2857","Strengthening integrity in Ukraine’s natural resources, energy and defence sectors with Norway’s support","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc22c8770-c1ad-4fd3-8af1-7174cdbe6b0b?width=1000&height=650&format=webp&quality=80",[67,68],7797,7798,[70,71],"Green Corruption","Private Sector",[73],"Partnerships",[],2857,[70,71],[73],[],[],[],"2025-10-20T16:01:43.000Z","dfef11db-1bc6-47e9-a61d-93443995484b","2026-05-08T21:11:16.000Z",[],"\u002Fresources\u002Fnews\u002Fstrengthening-integrity-in-ukraines-natural-resources-energy-and-defence-sectors-with-norways-support-2857",{"id":87,"body":88,"status":6,"type":61,"date":89,"slug":90,"title":91,"image":92,"countries":93,"topic":94,"activity":95,"tags":96,"nid":97,"topics":98,"activities":99,"authors":100,"images":101,"websites":20,"area":20,"programme":20,"language":21,"translations":102,"translation_of":20,"user_created":38,"date_created":103,"user_updated":20,"date_updated":20,"content":104,"link":105},10623,"This feature appears in the 2025 Basel AML Index Public Edition report. [Download the full report and related resources](https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads).\n\n### Key takeaways \n\nA risk-based approach has long been at the core of efforts to mitigate risks of financial crimes like money laundering and terrorist financing. But application of the approach has been uneven, often focusing too heavily on high-risk areas while paying too little attention to where risks are lower. \n\nGlobal AML\u002FCFT standards now place stronger emphasis on applying the risk-based approach _proportionately_, encouraging the use of simplified measures in lower-risk situations. \n\nMany financial institutions and authorities find it difficult to assess or provide guidance on what constitutes lower risks in specific contexts. This limits the use of simplified measures and adds to compliance burdens. \n\nThe Basel AML Index’s updated risk classification offers a more nuanced, data-driven way to identify lower-risk jurisdictions and to support the application of a proportionate risk-based approach. \n\n### Proportionality: why clarity on lower-risk jurisdictions matters\n\nThe [risk-based approach](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html) has become the backbone of efforts to prevent money laundering, terrorist financing and related financial crimes. Its logic is straightforward: understand the different levels of risk, then apply stronger or lighter controls as appropriate. \n\nYet in many jurisdictions as well as in the private sector, the risk-based approach is not used as effectively as intended. Most attention is placed on identifying _high-risk_ clients, products or jurisdictions – for example, through the FATF’s black and grey lists, international sanctions regimes or high-risk lists. By contrast, there has been much less discussion about what should count as _lower risk_. \n\nThis gap matters because lower-risk situations are where simplified measures should be used by financial institutions. If they are not, resources are not used efficiently and people or organisations can be unjustifiably [excluded from accessing financial services](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002Fguidance-financial-inclusion-aml-tf-measures.html). Yet financial institutions often hesitate to use simplified measures out of fear that they may not be accepted by supervisors, which may not have clearly articulated their own risk tolerance.\n\nThe FATF, which sets global AML\u002FCFT standards, has recognised this imbalance and the unintended consequences. [Updates to its Recommendations](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Fupdate-standards-promote-financial-conclusion-feb-2025.html) this year encourage jurisdictions not only to _consider_ allowing simplified measures for lower-risk situations but to actually _allow and encourage_ them. \n\nThe FATF has also shifted to using the word _proportionate_ instead of _commensurate_ to describe how controls should be applied. While this may sound like semantics, it does signal a stronger expectation that AML\u002FCFT measures should not be uniform or mechanistic, but carefully calibrated in a way that ensures effectiveness and reduces compliance burdens. \n\n### The missing piece: what exactly is “lower risk”? \n\nEven with this shift, many authorities and financial institutions find it difficult to decide what genuinely counts as lower risk. According to our review of several recent national risk assessments from different regions, and from discussions with public and private-sector experts, several factors contribute to this uncertainty: \n\n*   Lack of clear definitions. The [FATF distinguishes](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html) between _low risk_ or (where isolated exemptions from AML\u002FCFT measures may be possible) and _lower risk_ (where simplified measures may be appropriate). Most national risk assessments do not draw this distinction. \n*   Different approaches. Some jurisdictions use structured risk scales in their national risk assessments. [Malaysia’s](https:\u002F\u002Famlcft.bnm.gov.my\u002Fpublications) national risk assessment, for example, uses a four-band model: high, medium-high, medium and low. Others, such as that of the [U.S.](https:\u002F\u002Fhome.treasury.gov\u002Fnews\u002Fpress-releases\u002Fjy2080), describe risks in narrative form without assigning categories. \n*   Unhelpful shortcuts. Jurisdiction risk models sometimes rely mainly on sanctions lists or lists of offshore centres, which offer a limited picture of financial crime risk. \n\n### Why clearer lower-risk categories support better outcomes \n\nWhen lower-risk jurisdictions and other situations are clearly identified, the benefits are significant: \n\n*   Better resource allocation and reduced compliance burdens. Staff and systems can be better directed towards higher-risk areas instead of being spread thinly. \n*   Improved quality of suspicious activity reports. Financial intelligence units often complain of defensive reporting, i.e. reporting entities submitting large numbers of suspicious activity reports mainly to protect themselves from possible criticism, rather than because the activity is genuinely suspicious. Specifically allowing simplified measures in lower-risk situations would help to reduce this. \n*   Less de-risking. When risk is assessed more accurately, financial institutions are less likely to withdraw services from whole countries or sectors based on broad assumptions. \n*   Public authorities can also distinguish between jurisdictions or regions requiring intense scrutiny in terms of cross-border financial crime risks and those where less close attention is justified. \n\nTo achieve these outcomes, financial institutions need a clear internal framework and risk assessment methodologies, as well as reliable data sources, on which to base their decisions.\n\n### How the Basel AML Index’s updated classification helps \n\nThe [Expert Edition](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) of the Basel AML Index has long provided an independent, data-driven assessment of money laundering and related financial crime risks across jurisdictions. \n\nPreviously it used three fixed risk bands: low, medium and high. This straightforward approach offers stability and simplicity, but may no longer capture the granularity needed by financial institutions and policymakers, especially where the rating drives due diligence or monitoring processes. \n\nFollowing our annual expert review meeting (see page 12), the Expert Edition will now use Jenks natural breaks, a statistical method that groups jurisdictions according to natural patterns in the data rather than fixed cut-off points. This results in the following categories: \n\n*   Lower risk: \u003C 4.70 \n*   Medium risk: 4.70–6.08 \n*   Higher risk: > 6.08 \n\nThe categories have also been renamed “lower”, “medium” and “higher” to emphasise that risk is relative. This new approach produces a clearer spread across categories and helps users see which jurisdictions fall meaningfully below the global risk pattern. \n\nThe purpose is not to label any jurisdiction as “safe” or “unsafe” but to offer a practical tool that supports geographic risk assessments and the application of proportionate measures. The Index’s underlying data remain available to subscribers. Users can then consider specific indicators relevant to their company’s risk appetite.","2025-12-05","streamlining-the-risk-based-approach-to-anti-money-laundering-compliance-2895","Streamlining the risk-based approach to anti-money laundering compliance","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd17b33b4-0aa3-4940-a5f9-1951e0e60f43?width=1000&height=650&format=webp&quality=80",[],[14],[14],[],2895,[],[],[],[],[],"2026-06-04T21:13:52.000Z",[],"\u002Fresources\u002Fnews\u002Fstreamlining-the-risk-based-approach-to-anti-money-laundering-compliance-2895",{"id":107,"body":108,"status":6,"type":10,"date":109,"slug":110,"title":91,"image":111,"countries":112,"topic":20,"activity":20,"tags":113,"nid":20,"topics":114,"activities":116,"authors":118,"images":120,"websites":121,"area":122,"programme":124,"language":21,"translations":126,"translation_of":20,"user_created":127,"date_created":128,"user_updated":127,"date_updated":129,"content":130,"link":131},10589,"This feature appears in the 2025 Basel AML Index Public Edition report. \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads\">Download the full report and related resources\u003C\u002Fa>.\n\n\u003Cblockquote>\n\u003Ch3>Key takeaways \u003C\u002Fh3>\n\n\u003Cul>\n\t\u003Cli>\u003Cstrong>A risk-based approach has long been at the core of efforts to mitigate risks of financial crimes \u003C\u002Fstrong>like money laundering and terrorist financing. But application of the approach has been uneven, often focusing too heavily on high-risk areas while paying too little attention to where risks are lower. \u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>Global AML\u002FCFT standards now place stronger emphasis on applying the risk-based approach \u003C\u002Fstrong>\u003Cstrong>\u003Cem>proportionately\u003C\u002Fem>\u003C\u002Fstrong>, encouraging the use of simplified measures in lower-risk situations. \u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>Many financial institutions and authorities find it difficult to assess or provide guidance on what constitutes lower risks \u003C\u002Fstrong>in specific contexts. This limits the use of simplified measures and adds to compliance burdens. \u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>The Basel AML Index’s updated risk classification offers a more nuanced, data-driven way \u003C\u002Fstrong>to identify lower-risk jurisdictions and to support the application of a proportionate risk-based approach. \u003C\u002Fli>\n\u003C\u002Ful>\n\u003C\u002Fblockquote>\n\n\n### Proportionality: why clarity on lower-risk jurisdictions matters\n\nThe \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html\">risk-based approach\u003C\u002Fa> has become the backbone of efforts to prevent money laundering, terrorist financing and related financial crimes. Its logic is straightforward: understand the different levels of risk, then apply stronger or lighter controls as appropriate.\n\nYet in many jurisdictions as well as in the private sector, the risk-based approach is not used as effectively as intended. Most attention is placed on identifying \u003Cem>high-risk \u003C\u002Fem>clients, products or jurisdictions – for example, through the FATF’s black and grey lists, international sanctions regimes or high-risk lists. By contrast, there has been much less discussion about what should count as \u003Cem>lower risk\u003C\u002Fem>.\n\nThis gap matters because lower-risk situations are where simplified measures should be used by financial institutions. If they are not, resources are not used efficiently and people or organisations can be unjustifiably \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002Fguidance-financial-inclusion-aml-tf-measures.html\">excluded from accessing financial services\u003C\u002Fa>. Yet financial institutions often hesitate to use simplified measures out of fear that they may not be accepted by supervisors, which may not have clearly articulated their own risk tolerance.\n\nThe FATF, which sets global AML\u002FCFT standards, has recognised this imbalance and the unintended consequences. \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Fupdate-standards-promote-financial-conclusion-feb-2025.html\">Updates to its Recommendations\u003C\u002Fa> this year encourage jurisdictions not only to \u003Cem>consider \u003C\u002Fem>allowing simplified measures for lower-risk situations but to actually \u003Cem>allow and encourage \u003C\u002Fem>them.\n\nThe FATF has also shifted to using the word \u003Cem>proportionate \u003C\u002Fem>instead of \u003Cem>commensurate \u003C\u002Fem>to describe how controls should be applied. While this may sound like semantics, it does signal a stronger expectation that AML\u002FCFT measures should not be uniform or mechanistic, but carefully calibrated in a way that ensures effectiveness and reduces compliance burdens.\n\n### The missing piece: what exactly is “lower risk”?\n\nEven with this shift, many authorities and financial institutions find it difficult to decide what genuinely counts as lower risk. According to our review of several recent national risk assessments from different regions, and from discussions with public and private-sector experts, several factors contribute to this uncertainty:\n\n- \u003Cstrong>Lack of clear definitions\u003C\u002Fstrong>. The \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html\">FATF distinguishes\u003C\u002Fa> between \u003Cem>low risk \u003C\u002Fem>or (where isolated exemptions from AML\u002FCFT measures may be possible) and \u003Cem>lower risk \u003C\u002Fem>(where simplified measures may be appropriate). Most national risk assessments do not draw this distinction.\n- \u003Cstrong>Different approaches\u003C\u002Fstrong>. Some jurisdictions use structured risk scales in their national risk assessments. \u003Ca href=\"https:\u002F\u002Famlcft.bnm.gov.my\u002Fpublications\">Malaysia’s\u003C\u002Fa> national risk assessment, for example, uses a four-band model: high, medium-high, medium and low. Others, such as that of the \u003Ca href=\"https:\u002F\u002Fhome.treasury.gov\u002Fnews\u002Fpress-releases\u002Fjy2080\">U.S.\u003C\u002Fa>, describe risks in narrative form without assigning categories. \n- \u003Cstrong>Unhelpful shortcuts\u003C\u002Fstrong>. Jurisdiction risk models sometimes rely mainly on sanctions lists or lists of offshore centres, which offer a limited picture of financial crime risk.\n\n### Why clearer lower-risk categories support better outcomes\n\nWhen lower-risk jurisdictions and other situations are clearly identified, the benefits are significant:\n\n- \u003Cstrong>Better resource allocation and reduced compliance burdens\u003C\u002Fstrong>. Staff and systems can be better directed towards higher-risk areas instead of being spread thinly.\n- \u003Cstrong>Improved quality of suspicious activity reports\u003C\u002Fstrong>. Financial intelligence units often complain of defensive reporting, i.e. reporting entities submitting large numbers of suspicious activity reports mainly to protect themselves from possible criticism, rather than because the activity is genuinely suspicious. Specifically allowing simplified measures in lower-risk situations would help to reduce this.\n- \u003Cstrong>Less de-risking\u003C\u002Fstrong>. When risk is assessed more accurately, financial institutions are less likely to withdraw services from whole countries or sectors based on broad assumptions.\n- \u003Cstrong>Public authorities \u003C\u002Fstrong>can also distinguish between jurisdictions or regions requiring intense scrutiny in terms of cross-border financial crime risks and those where less close attention is justified.\n\nTo achieve these outcomes, financial institutions need a clear internal framework and risk assessment methodologies, as well as reliable data sources, on which to base their decisions.\n\n### How the Basel AML Index’s updated classification helps\n\nThe \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition\">Expert Edition\u003C\u002Fa> of the Basel AML Index has long provided an independent, data-driven assessment of money laundering and related financial crime risks across jurisdictions.\n\nPreviously it used three fixed risk bands: low, medium and high. This straightforward approach offers stability and simplicity, but may no longer capture the granularity needed by financial institutions and policymakers, especially where the rating drives due diligence or monitoring processes.\n\nFollowing our annual expert review meeting (see page 12), the Expert Edition will now use \u003Cstrong>Jenks natural breaks\u003C\u002Fstrong>, a statistical method that groups jurisdictions according to natural patterns in the data rather than fixed cut-off points. This results in the following categories:\n\n- \u003Cstrong>Lower risk\u003C\u002Fstrong>: < 4.70\n- \u003Cstrong>Medium ris\u003C\u002Fstrong>k: 4.70–6.08\n- \u003Cstrong>Higher risk\u003C\u002Fstrong>: > 6.08\n\n![](https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F9b974fd1-47e9-49f8-9d2c-9f2ec25bd99c)\n\nThe categories have also been renamed “lower”, “medium” and “higher” to emphasise that risk is relative. This new approach produces a clearer spread across categories and helps users see which jurisdictions fall meaningfully below the global risk pattern.\n\nThe purpose is not to label any jurisdiction as “safe” or “unsafe” but to offer a practical tool that supports geographic risk assessments and the application of proportionate measures. The Index’s underlying data remain available to subscribers. Users can then consider specific indicators relevant to their company’s risk appetite.\n","2025-12-08","streamlining-the-risk-based-approach-to-anti-money-laundering-compliance","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd0c794ab-f975-4521-9333-579c5d947048?width=1000&height=650&format=webp&quality=80",[],[],[115],"Anti-Money Laundering",[117],"Basel AML Index",[119],1364,[],[117],[123],"Asset Recovery & Enforcement",[125],"International Centre for Asset Recovery",[],"545a204d-e41b-4882-afda-481ecf3fd971","2025-12-05T11:16:34.000Z","2025-12-08T07:09:33.000Z",[],"\u002Fresources\u002Fnews\u002Fstreamlining-the-risk-based-approach-to-anti-money-laundering-compliance",{"id":133,"body":134,"status":6,"type":10,"date":135,"slug":136,"title":137,"image":138,"countries":139,"topic":140,"activity":142,"tags":144,"nid":149,"topics":150,"activities":152,"authors":153,"images":155,"websites":156,"area":20,"programme":20,"language":20,"translations":158,"translation_of":20,"user_created":38,"date_created":159,"user_updated":160,"date_updated":161,"content":162,"link":163},10532,"_This article is adapted from the_ [_2024 Basel AML Index public report_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024)_._\n\nFinancial crime has far-reaching impacts on people’s lives. Yet often the only time it draws serious attention in the media is when a country is added to the [FATF’s grey list](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fcountries\u002Fblack-and-grey-lists.html). This designation of “jurisdictions under increased monitoring” frequently sparks debate and concern, and is clouded by misconceptions. This section looks at five common myths that we come across in our work to support partner countries seeking to avoid or leave the grey list.\n\n### Myth 1: The grey list = high-risk countries\n\nA common misconception about the FATF grey list is that it represents (the only) countries and jurisdictions that pose high risks for money laundering, terrorist financing and proliferation financing.\n\nIn fact, in the FATF’s own words, the grey list is the public list of jurisdictions that are “actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.” It is the FATF’s black list that specifically identifies high-risk countries and calls for enhanced due diligence and\u002For countermeasures when dealing with these.\n\nThe distinction is important because not all grey-listed countries pose the same level or type of risk. Many are on a rapid path to improvement. Not all will require enhanced due diligence. And some countries that are not and never have been on the grey list may still present significant risks.\n\nInclusion on the grey list is based on the FATF's [International Co-operation Review Group](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FHigh-risk-and-other-monitored-jurisdictions\u002FMore-on-high-risk-and-non-cooperative-jurisdictions.html) (ICRG) process and on the criteria summarised under Myth 2, rather than merely on its own criteria for identifying a higher-risk country (see box below).\n\nA complicating factor for financial institutions seeking to identify clear criteria for applying enhanced due diligence is the use of both the black and grey lists by the EU and UK for their own lists of high-risk third countries.\n\n> What is a higher-risk country?\n> \n> The Interpretative Note to the FATF’s [Recommendation 10](https:\u002F\u002Fcfatf-gafic.org\u002Fdocuments\u002Ffatf-40r\u002F376-fatf-recommendation-10-customer-due-diligence) on customer due diligence sets out guidelines on country or geographic risk factors that might trigger the application of enhanced due diligence according to a risk-based approach. The criteria (note 15b) refer to countries that are “identified by credible sources” as having inadequate AML\u002FCFT systems, high levels of corruption and crime or high levels of terrorist activity and financing, or that are subject to sanctions or similar measures. It does not specifically refer to either the grey list or the black list, though this may be one factor that organisations take into account.\n> \n> Similarly, [Recommendation 19](https:\u002F\u002Fwww.cfatf-gafic.org\u002Fdocuments\u002Ffatf-40r\u002F385-fatf-recommendation-19-higher-risk-countries) on higher-risk countries and its Interpretative Note require enhanced due diligence by financial institutions to be applied only to countries “for which this is called for by the FATF”, indicating the black list of jurisdictions subject to a call for action.\n\n### Myth 2: Grey listing is a surprise\n\nEach time the FATF holds a plenary session, commentators appear to “bet” which countries will be added or removed. This leads some to believe that grey listing comes as a surprise – even to a country’s authorities.\n\nIn fact, grey listing is based mainly on a country’s poor performance in its mutual evaluation report, specifically in one of four criteria:\n\n*   Fifteen or more non-compliant or partially compliant ratings for technical compliance in any Recommendation.\n*   A non-compliant or partially compliant rating for three or more of the following Recommendations: R.3 (money laundering offences), R.5 (terrorist financing offences), R.6 (targeted financial sanctions related to terrorist financing), R.10 (customer due diligence), R.11 (record keeping) and R.20 (reporting of suspicious transactions).\n*   A low or moderate level of effectiveness for nine or more of the 11 Immediate Outcomes, with a minimum of 2 low ratings.\n*   A low level of effectiveness for six or more of the 11 Immediate Outcomes.\n\nThe authorities typically have a year or more to work on their specific weaknesses without being publicly listed, under the FATF’s International Co-operation process.\n\nThe FATF also prioritises countries and jurisdictions with significant financial centres. For the fifth round of evaluations, the threshold has been increased from USD 5 billion to USD 10 billion, measured in [broad money terms](https:\u002F\u002Fwww.oecd.org\u002Fen\u002Fdata\u002Findicators\u002Fbroad-money-m3.html).\n\nSo grey listing is rarely a surprise to the authorities. It is however less easy for third parties like financial institutions and foreign donors to predict whether a jurisdiction will end up on the grey list.\n\nOur [Expert Edition Plus](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) now offers subscribers an assessment of the risks that a particular country will end up on the grey list. This makes it possible to better anticipate this and prepare accordingly – including, we would recommend, by using the Basel AML Index to assess the broad range of factors contributing to a higher level of money laundering risk.\n\n### Myth 3: Grey listing has only negative impacts\n\nBeing added to the FATF grey list can trigger severe economic consequences for countries, especially low-income countries dependent on foreign investment and assistance. Investors and financial institutions may reduce their business in the country. A 2021 [IMF paper](https:\u002F\u002Fpapers.ssrn.com\u002Fsol3\u002Fpapers.cfm?abstract_id=4026331) found that capital inflows decline on average by 7.6 percent of GDP following grey listing, for example.\n\nFinancial institutions may also “de-risk” completely – cutting off all business to avoid the extra compliance and risk management costs. Individuals and businesses may have challenges accessing financial services as a result, leading to lower financial inclusion. Other [unintended consequences](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12) may include an increase in the use of less regulated channels to move money.\n\nNegative economic consequences are not inevitable, however, especially for more developed economies. [Croatia’s economy and its financial sector](https:\u002F\u002Fwww.imf.org\u002Fen\u002FPublications\u002FCR\u002FIssues\u002F2024\u002F07\u002F26\u002FRepublic-of-Croatia-2024-Article-IV-Consultation-Press-Release-and-Staff-Report-552561), for example, both appear to be relatively unscathed by its placement on the grey list in 2023. S&P Global even [upgraded](https:\u002F\u002Fdisclosure.spglobal.com\u002Fratings\u002Fen\u002Fregulatory\u002Farticle\u002F-\u002Fview\u002Ftype\u002FHTML\u002Fid\u002F3250133) its long-term sovereign credit rating from BBB+ to A- in September 2023.\n\nWould it have done even better if it hadn’t been grey listed? It is hard to know – but in some cases perhaps being grey listed could even help a country’s performance in the long run, by motivating it to conduct necessary reforms quickly. For example, Iceland and Malta both managed to leave the grey list after just a year, having speedily fulfilled the requirements of their action plans.\n\nFor countries receiving development aid, grey listing can bring the benefit of increased targeted assistance to implement reforms and eventually exit the grey list. However, since authorities are typically aware of the risk of grey listing in advance (see Myth 2), it would be more effective if this assistance were provided earlier to help prevent the country from being listed in the first place.\n\n### Myth 4: The grey-listing system is inherently unfair\n\nCritics of the grey-listing system point out that it unfairly penalises low-income jurisdictions with less capacity for AML\u002FCFT but also lower significance due to their small financial centres.\n\nIt is true that low-income countries are disproportionately represented on the grey list, but this is changing. More than half of grey-listed countries at the time of writing are in [Sub-Saharan Africa](https:\u002F\u002Findex.baselgovernance.org\u002Fapi\u002Fassets\u002Ff2c74bc1-2760-4bea-a118-aaa96b9cdf09), for example. Yet the addition of European countries in 2023 and 2024 – Bulgaria, Croatia and Monaco – shows that the geography is shifting.\n\nThe following figure shows the percentage of jurisdictions in each region on the grey list as of October 2024:\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2025-02\u002FGraphic%20regional%20percentage%20FATF%20grey%20list.png)\n\n[New prioritisation criteria](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfgeneral\u002FFATF-grey-listing-criteria.html) announced in October 2024 in effect apply a risk-based approach to grey listing. High-income countries and jurisdictions with financial centres over USD 10 billion will be prioritised. Least developed countries as defined by the UN will not be prioritised except in rare cases of high risk, in which case they will have a longer time period to work on their deficiencies before being grey listed.\n\nAs these changes take effect, we should see the grey-listing geography shift towards higher-income countries that are deeply integrated in financial markets.\n\nAnd there are some simple things that a country can do to avoid grey listing – namely, prepare well for the mutual evaluation process, which is always announced well in advance. Quite basic actions can help, like preparing an up-to-date [national risk assessment](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-26-national-money-laundering-and-terrorist-financing-risk-assessments) (and specific sectoral assessments where relevant), gathering statistical data and developing strategies to mitigate identified risks.\n\nThe Basel AML Index methodology does not penalise countries for being on the grey list, since the deficiencies that led to them being grey listed are already apparent in the mutual evaluation report data. In 2023, we also [updated our methodology](https:\u002F\u002Findex.baselgovernance.org\u002Fnews\u002Fbasel-aml-index-2023-reflecting-the-progress-of-grey-listed-jurisdictions-2513) to better capture improvements in the effectiveness of jurisdictions that exit the grey list, even if the FATF does not release new effectiveness data.\n\n### Myth 5: Leaving the grey list is the end of the story\n\nGrey listing is just one period in a country’s anti-money laundering journey. Being delisted is naturally a cause for celebration and hope, but it’s not the end of the story. Many jurisdictions have been grey listed more than once, including Cambodia, Nicaragua, Panama and Pakistan.\n\nFATF standards continue to evolve and to strengthen, so jurisdictions need to constantly improve in order to keep up.\n\nA prominent example highlighted in several Basel AML Index reports over the years is Recommendation 15 on virtual assets. After it was updated in 2018, almost all subsequently assessed jurisdictions [achieved lower levels of compliance](https:\u002F\u002Findex.baselgovernance.org\u002Fnews\u002Fvirtual-currencies-are-we-missing-a-trick-insights-from-the-basel-aml-index-2023-2541) than previously. We can expect a similar effect with the [updated Recommendations 4 and 38](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Ffatf-seeks-change-landscape-international-asset-recovery-what-means-latin-america) on asset recovery, where there are still some countries that do not meet basic criteria such as having a non-conviction based forfeiture law or enforcing international judgements based on these laws.\n\nThe FATF’s fifth round of evaluations will [emphasise effectiveness](https:\u002F\u002Fwww.fatf-gafi.org\u002Fcontent\u002Ffatf-gafi\u002Fen\u002Fpublications\u002FMutualevaluations\u002FFatf-methodology.html) over technical compliance. Countries will need to put in more effort to improve their effectiveness ratings, which are, on average, less than half as strong as their ratings for technical compliance.\n\nAs financial systems continue to evolve, criminals will find ever more ingenious ways to steal, launder and hide money or to use it for illicit purposes such as the financing of terrorism and weapons of mass destruction. Avoiding or graduating from the grey list is one step along a never-ending journey to a resilient system that successfully wards of money laundering and related threats while not limiting financial inclusion and innovation.\n\n### Learn more\n\n*   Read the [13th annual Public Edition report of the Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024).\n*   Explore the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F).","2025-02-06","fatf-grey-list-truth-and-myths-2760","FATF grey list: truth and myths","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F2397c564-394a-4f1e-8448-ec230a14810c?width=1000&height=650&format=webp&quality=80",[],[115,141],"Asset Recovery",[143],"Insights",[145],{"tags_id":146},{"id":147,"name":148},818,"Anti-money laundering",2760,[115,151],"Asset Recovery and Enforcement",[143],[154],1090,[],[157],"Main page",[],"2025-02-06T11:01:49.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-29T22:22:34.000Z",[],"\u002Fresources\u002Fnews\u002Ffatf-grey-list-truth-and-myths-2760",{"id":165,"body":166,"status":6,"type":10,"date":167,"slug":168,"title":169,"image":170,"countries":171,"topic":172,"activity":173,"tags":174,"nid":175,"topics":176,"activities":177,"authors":178,"images":181,"websites":20,"area":20,"programme":20,"language":21,"translations":182,"translation_of":20,"user_created":38,"date_created":183,"user_updated":160,"date_updated":184,"content":185,"link":186},10584,"As cryptoassets and other blockchain-based tokens enter the mainstream, alarm bells are ringing about the risks of their misuse. The technology is neutral in itself, but like any mechanism to transfer value, it can and does facilitate a wide range of crimes.\n\nAnd it’s not just scams, hacks and ransomware attacks. Cryptoassets are now seen in practically all crime types, from drug trafficking and terrorist financing to sanctions evasion, and increasingly as a tool for laundering the proceeds of those crimes.\n\nWhen it comes to the links between crypto and _corruption_, research and closed case examples are still scant. But since both are important enablers of crime, it’s vital to better understand how they intersect.\n\nThis blog outlines some basic areas of concern. Despite the gaps in data and analysis, one thing is clear. While the technologies are fairly new, the corrupt practices are not: they are simply manifesting in different ways.\n\n> _Crypto and corruption: what we mean_\n> \n> _In this blog we take a broad view of both crypto and corruption. By “crypto”, we mean cryptoassets such as Bitcoin (BTC) and Ether (ETH) as well as stablecoins tied to fiat currencies such as Tether (USDT) and USD Coin (USDC); plus other digital tokens that run on public, decentralised blockchains. The scope also includes the companies, industries and services built around crypto, as well as the systems for their regulation and supervision and for law enforcement. “Corruption” refers not just to bribery, but to any abuse of entrusted power for undue benefit – whether financial or political, whether personal or for a collective entity._\n\n### 1 Crypto for bribery\n\nIs crypto a brilliant way to pay bribes and kickbacks? Transfers are pseudonymous after all – linked to long wallet addresses like _1Lbcfr2sAHTG9CgdQo3HTMTkV7LK4ZnX75_ rather than names. Transfers can be made directly between individuals, through decentralised platforms or peer-to-peer transactions, which avoids awkward questions about who is who and where the money comes from.\n\nCrypto holdings are easier to keep private, so might not be included in the asset declarations of politically exposed persons keen not to reveal all of their hidden wealth. And it’s fast and easy: you can transfer crypto to any person, anywhere in the world at the touch of a button. That makes it superficially more attractive than an international bank transfer, and less hassle and personal risk than travelling to another continent carrying suitcases stuffed with cash.\n\nSome clearly think crypto is great for bribes:\n\n*   In 2024, a Ukrainian Member of Parliament was [sentenced to eight years in prison](https:\u002F\u002Fhacc-decided.ti-ukraine.org\u002Fen\u002Fnews\u002Fnardepa-odarcenka-zasudili-do-8-rokiv-vyaznici) for offering a bribe of EUR 46,000 in bitcoin to secure funding for reconstruction projects.\n*   Crypto payments were allegedly made to a former senior official at the China Securities Regulatory Commission in return for [abuses of power](https:\u002F\u002Fwww.ccn.com\u002Fnews\u002Fcrypto\u002Fyao-qian-china-cbdc-crypto-corruption\u002F) in making appointments and securing loans – alongside expensive liquor and invitations to banquets.\n*   In June 2025, two employees of the state-owned China Construction Bank were charged in Hong Kong with bribery and other offences: they allegedly accepted around USD 470,000 in crypto in exchange for [authenticating false documents](https:\u002F\u002Fwww.artemis.bm\u002Fnews\u002Fchina-construction-bank-manager-accused-of-accepting-bribes-from-vesttoo-employee\u002F) for the now-bankrupt Israeli firm Vesttoo.\n\nYet the use of crypto for bribery has a unique vulnerability: transactions on public blockchains are permanent and publicly visible. If investigators can verifiably link an address to a suspect, the evidence of the bribery remains accessible forever.\n\nSadly, it’s pretty hard to identify bribes or kickbacks being paid unless you already know there’s a bribery scheme or you know the addresses of suspected accomplices. That might explain why major crypto bribery cases haven’t surfaced (yet!).\n\n### 2 Laundering proceeds of corruption using crypto\n\nWhat about laundering the proceeds of corruption? For those with a lot of dirty money to launder, crypto adds a new dimension to the playbook.\n\nSure, keep the shell companies and offshore bank accounts, the trusts and real estate and gambling schemes, the hawala networks. Now you can add to the mix by converting corrupt proceeds into crypto, converting these to other coins, hopping across blockchains and using privacy-enhancing technologies to throw investigators off track.\n\nAs adoption of tokenised assets grows – digital representations of financial or real-world assets – we can expect corrupt actors to buy not only villas in Tuscany and ski apartments in Switzerland, but tokens representing these. And while you can’t ski on a digital token, it is likely attractive to money launderers to be able to trade in a broad range of investments while keeping the beneficial owner hidden.\n\nAre corrupt actors using crypto to launder their funds? There’s little direct evidence, but it does seem likely. Corrupt individuals have long relied on professional money laundering services, often provided by lawyers and accountants. [Europol](https:\u002F\u002Fwww.europol.europa.eu\u002Fpublications-events\u002Fmain-reports\u002Fsocta-report) warns that these professionals,\n\n> “increasingly with specialised knowledge in digital asset trading, have developed parallel, underground financial systems that operate outside the regulatory frameworks governing legal financial institutions”.\n\nAnd we do see that law enforcement is starting to take down organised groups that specialise in laundering illicit funds, including through crypto.\n\nAn [Australian takedown](https:\u002F\u002Fwww.ato.gov.au\u002Fmedia-centre\u002Falleged-qld-money-laundering-organisation-dismantled) of an organised money laundering operation in June 2025, for example points to millions of tainted Australian dollars laundered through crypto exchanges as well as bank accounts, couriers, a car dealership and a sales company. Some outfits specialise in a specific clientele: in the Europol-coordinated [Operation Karasu](https:\u002F\u002Fwww.europol.europa.eu\u002Fmedia-press\u002Fnewsroom\u002Fnews\u002F17-providers-of-criminal-banking-services-arrested) in 2025, authorities arrested 17 suspects alleged to be providing money laundering services to Chinese- and Arabic-speaking clients using hawala banking, cash transactions and crypto.\n\nThe largest blockbuster takedown to date is the [October 2025 indictment of the Chairman of Prince Group](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Fchairman-prince-group-indicted-operating-cambodian-forced-labor-scam-compounds-engaged), a Cambodia-based multinational business enterprise, and the filing of a forfeiture action for more than 127,000 bitcoin – approximately USD 15 billion at the time of seizure. The press release described the use of professional money laundering operations and pointed to highly sophisticated techniques, such as “spraying” stolen cryptoassets across multiple addresses to obscure the trail of the funds.\n\nCommenting on the indictment, the head of the U.S. Drug Enforcement Administration highlighted the role of corruption in such schemes. He explained how: \n\n> complex criminal schemes \\[such as this\\] exploit global financial systems and emerging technologies to conceal illicit proceeds. These networks operate at the intersection of drug trafficking, corruption, and financial crime, threatening the stability of institutions and communities, alike.\n\n### 3 Corrupt law enforcement in crypto cases\n\nSay you’re a law enforcement officer – a public servant. You’re one of the few in your agency with the technical skills to trace and seize cryptoassets suspected of being involved in crime.\n\nYou see an opportunity to supplement your salary by stealing crypto during an investigation or taking payments from criminals to leave their holdings in peace. Nobody will know – surely?\n\n*   That’s what two US agents from the [Drug Enforcement Administration](https:\u002F\u002Fwww.justice.gov\u002Farchives\u002Fopa\u002Fpr\u002Fformer-dea-agent-sentenced-extortion-money-laundering-and-obstruction-related-silk-road) and [Secret Service](http:\u002F\u002Fwww.justice.gov\u002Farchives\u002Fopa\u002Fpr\u002Fformer-secret-service-agent-sentenced-scheme-related-silk-road-investigation) thought, when they abused their power as law enforcement officers and their access to government-controlled wallets to steal tens of millions of USD in bitcoin linked to the takedown of the illicit Silk Road online marketplace.\n*   In Russia, a former investigator was found guilty in 2023 of [accepting bitcoin bribes](https:\u002F\u002Fcointelegraph.com\u002Fnews\u002Frussia-seizes-10-million-bitcoin-from-official-biggest-bribery) equivalent to tens of millions of US dollars from an organised crime group in order not to confiscate their bitcoin holdings – estimated at USD 138 million at the time.\n*   In Iran, senior intelligence officers of the Revolutionary Guard are alleged to have gained around USD 21 million during the takedown of the Cryptoland exchange: following the CEO’s arrest, they [stole and sold his tokens](https:\u002F\u002Fwww.iranintl.com\u002Fen\u002F202503309549) before the arrest was made public and the tokens’ value collapsed. \n\nIt’s not uncommon for law enforcement officers to go rogue, or for bribes to be paid to influence law enforcement actions or judicial proceedings. So authorities don’t just need to build capacity to go after crypto-related crime. They also need to look out for crypto-related corruption risks among their own ranks, including entities such as asset management offices that have custody over seized and confiscated cryptoassets.\n\n### 4 When the crypto industry meets politics\n\nCrypto is a fast-evolving industry that demonstrates genuinely exciting financial and technological innovation. It’s no wonder that politicians all over the world are getting interested.\n\nCorrupt behaviour by politicians involving the crypto industry is still a realm of speculation, as data on real-world cases is sparse. But red flags for corruption are a common feature of all fast-growing, profitable industries with highly technical aspects, like mining and defence. So, it is sensible to look out for common risks, which span from licencing schemes to the shaping of cryptoasset regulations or the resources put into enforcement.\n\nWhen it comes to public trust in government, even suspicions of crypto-related wrongdoing matter. Examples range from a [political financing scandal in Colombia](https:\u002F\u002Fwww.theblock.co\u002Fpost\u002F293857\u002Fcolombian-president-crypto-donation-campaign-2022-daily-cop) to [graft accusations in Venezuela](https:\u002F\u002Fwww.barrons.com\u002Fnews\u002Fvenezuela-kills-off-petro-cryptocurrency-1e2b0317) and to allegations of [crypto-related irregularity affecting the US President](https:\u002F\u002Fwww.economist.com\u002Fleaders\u002F2025\u002F05\u002F15\u002Fcrypto-has-become-the-ultimate-swamp-asset) and his family.\n\nAnd in the Czech Republic, when the Justice Ministry [accepted a bitcoin donation](https:\u002F\u002Fwww.occrp.org\u002Fen\u002Fnews\u002Fbitcoin-scandal-triggers-czech-government-crisis) worth around USD 46 million from a convicted criminal, the ensuing scandal triggered a public investigation and the resignation of the Justice Minister; some feared it might even topple the government.\n\n### 5 Corruption fuelling organised crime and state capture\n\nThe link between crypto and corruption with possibly the most damaging social impact is its role in enabling criminal gangs to carry out cybercrime and launder money with impunity.\n\nAs detailed in a 2025 UNODC report on [corruption and cybercrime](https:\u002F\u002Fwww.unodc.org\u002Froseap\u002Fuploads\u002Fdocuments\u002FPublications\u002F2025\u002F2025.10.21_The_Nexus_Between_Cybercrime_and_Corruption.pdf), corruption both creates the “permissive environment” that allow cybercrime operations to flourish and “enables many daily operations of cybercriminal networks.”\n\nIn [Southeast Asia](https:\u002F\u002Fwww.unodc.org\u002Froseap\u002Fen\u002F2025\u002F04\u002Fcyberfraud-inflection-point-mekong\u002Fstory.html), for example, a separate UNODC report depicts how industrial-scale scam centres run by organised crime groups generate huge amounts of illegal revenue – mostly in crypto. Despite often being plainly identified in public reports, they remain operational and engage in human trafficking to obtain unwilling workers. The report emphasises “high rates of corruption which criminal actors can leverage” to continue their scam operations unmolested.\n\nUNODC warns that the revenue generated by scam centres, coupled with the ability to easily launder the stolen crypto, is increasing the power and influence of organised crime groups as well as their financial liquidity. And that gives them even more ability to corrupt and capture politicians and states.\n\nThat may already be happening, according to a November 2025 _Economist_ report on [allegations of political collusion](https:\u002F\u002Fwww.economist.com\u002Fasia\u002F2025\u002F11\u002F20\u002Fthe-politicians-protecting-huge-criminal-networks) in scam operations in Cambodia, the Philippines and Thailand. These have led to the resignation of a deputy finance minister, the jailing of a mayor and a warning from Thailand's deputy leader of the opposition that without action against politicians colluding in scam operations,\n\n> “we’ll wake up to find the country run by crooks in suits\".\n\n### What to do?\n\nCrypto represents an exciting transformation in financial systems. The industry and its underlying technology could improve privacy, efficiency and access to financial markets. This may benefit many people poorly served by today’s centralised systems.\n\nBut without a clear understanding of crypto-related risks and proper safeguards, the industry could create more opportunities for corruption and related financial crimes such as money laundering, terrorist financing and sanctions evasion. Crypto-fuelled corruption could weaken trust in governments and be leveraged to undermine the stability and security of nation states.\n\nAt the Basel Institute, we’re keen to explore better how the worlds of crypto and corruption intersect and how best to mitigate both systemic and day-to-day risks. We’re also committed to building the capacity of anti-corruption and asset recovery practitioners to “follow the money” across blockchains and to connect these to wider financial and criminal investigations.\n\nBeyond training for [individuals](https:\u002F\u002Fbaselgovernance.org\u002Fcrypto-aml-training) and [public agencies](https:\u002F\u002Fbaselgovernance.org\u002FICAR-training), we also bring together people from across sectors and geographies at our annual [Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002F9crc) together with Europol and UNODC. Look out for more on this topic in the coming months!","2025-11-27","crypto-the-ultimate-enabler-of-corruption-2882","Crypto: the ultimate enabler of corruption?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd41fd31d-6c56-48e0-96cc-2be74f18b731?width=1000&height=650&format=webp&quality=80",[],[141],[143],[],2882,[151],[143],[179,180],1360,1361,[],[],"2025-11-27T17:01:44.000Z","2026-05-29T22:22:38.000Z",[],"\u002Fresources\u002Fnews\u002Fcrypto-the-ultimate-enabler-of-corruption-2882",{"id":188,"body":189,"status":6,"type":10,"date":190,"slug":191,"title":192,"image":193,"countries":194,"topic":195,"activity":196,"tags":198,"nid":199,"topics":200,"activities":201,"authors":202,"images":204,"websites":205,"area":20,"programme":20,"language":20,"translations":206,"translation_of":20,"user_created":38,"date_created":207,"user_updated":160,"date_updated":208,"content":209,"link":210},10486,"Is financial crime really a security threat, as an increasing number of countries and experts now say? If so, in what sense? And what implications might that have for our efforts to fight it?\n\nThe issues around framing financial crime as a threat to national and international security were a key topic on the agenda of the first international Summit of the [Global Coalition to Fight Financial Crime](https:\u002F\u002Fwww.gcffc.org\u002F) (GCFFC) in Stockholm, Sweden, on 10–11 September 2024.\n\nUnder the theme [Accelerating Cooperation](https:\u002F\u002Fwww.gcffc.org\u002Fannual-summit-in-stockholm-sweden-10-11-september-2024-conference-materials\u002F), the event drew 140 financial crime fighters from a broad range of backgrounds, including law enforcement, financial intelligence units (FIUs), civil society, tech companies and banks.\n\nHans-Peter Bauer, Senior Advisor on AML\u002FCFT and former Board Member of the Basel Institute on Governance, chaired a panel on Financial Crime as a Security Threat together with:\n\n*   David Lewis, Managing Director and Global Head of Anti-Money Laundering Advisory at Kroll and former Executive Secretary of the FATF;\n*   Marcus Pleyer, Deputy Director General of the German Finance Ministry and former Chair of the Financial Action Task Force (FATF);\n*   Ian Tennant, Director of the Global Initiative against Transnational Organized Crime; and\n*   Ilze Znotina, Chair of GCFFC Europe Chapter and former Head of the FIU of Latvia.\n\nThe panel discussed whether financial crime could and should be considered a serious threat to national and international security – and what the implications might be for political action against financial crime and the resources dedicated to it.\n\n### Financial crime causes immense harm\n\nThe discussion highlighted how financial crimes inflict terrible harm on individuals, societies and the global community. The damage goes well beyond the financial aspect.\n\nCrimes like corruption and fraud are not victimless, even if the victims are sometimes hard to identify. Financially motivated crimes like the trafficking of drugs, humans and weapons cause immense harm to individuals and threaten the stability and security of whole societies. The same is true for environmental crimes like the illegal trade in wildlife and timber, which are now finally being recognised as a form of financial crime.\n\nAnd as Markus Pleyer emphasised in a follow-up [social media post](https:\u002F\u002Fwww.linkedin.com\u002Fposts\u002Fmarcus-pleyer-4658bb1b6_financial-crime-as-a-national-security-threat-activity-7240741506330882048-pzi_), financial crime feeds terrorist activity and aggression, fuelling conflict. Even in relatively peaceful areas of the world, he said:\n\n> Criminals can use their dirty money to exert economic or even political influence destabilising social order and subverting our state and economic structures.\n\nDespite the wide scope of meaning of the term “security”, the big picture is clear. It is vital to look not only at the monetary aspects of financial crime, but to consider the whole chain of actors involved in the crimes and the resulting impacts on peace, stability and social cohesion.\n\n### High profits for criminals, low rates of enforcement\n\nThe sheer scale of the impacts of financial crime is well illustrated in the GFCCC’s [information wall](https:\u002F\u002Fwww.gcffc.org\u002Finformation-wall\u002F), whose latest version shows estimates of criminal activity and resulting illicit funds across a wide spectrum of crime typologies.\n\nYet detection and conviction rates for financial crime offences remain stubbornly low across the world. Estimates of the amount of illicit financial flows intercepted and recovered hover around 1 percent, as the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F)’s latest public report shows.\n\nThis gap led the panel – and many in the audience – to agree that a profound reform of the current system and approach to fighting financial crime is required.\n\n### Political implications\n\nOne political implication of recognising financial crime as a security threat is organisational. For example, Germany included the fight against financial crime into its [national security strategy](https:\u002F\u002Fwww.nationalesicherheitsstrategie.de\u002FNational-Security-Strategy-EN.pdf) in 2023. Among its measures will be the setup of a new [Federal Financial Crime Authority](https:\u002F\u002Fwww.bundesfinanzministerium.de\u002FContent\u002FEN\u002FStandardartikel\u002FTopics\u002FPriority-Issues\u002FFinancial-Crime\u002Ffight-against-financial-crime.html) with powers and competences that go beyond those of a typical FIU.\n\nOther implications might be new structures to facilitate public-private information sharing on financial crime cases. Legal reforms may be needed to allow this, as well as to facilitate private-private exchange of such information.\n\nThe rollout of beneficial ownership registers might see a boost if government leaders understand the critical need for accurate information on the owners of companies and assets to be available to the competent authorities and others with a legitimate interest.\n\nAnother positive outcome of recognising financial crime as a security threat would be a much-needed increase in resources for law enforcement and the judiciary, including to follow up on cases where financial institutions report suspicious activity.\n\n### Fighting financial crime is not an end in itself\n\nThe conference topics showed a clear recognition that tackling financial crime is critical to tackling some of the world’s greatest challenges.\n\nIn addition to the panel on financial crime as a security threat, the participants explored modern slavery and human trafficking, trade-based financial crime, dealing with mercenaries and private military, information sharing through public-private partnerships, balancing data privacy concerns, and how to improve the effectiveness of anti-money laundering supervision.\n\nThe energy and dynamism in the room also demonstrated the value of bringing together leading voices from across the world to discuss critical emerging issues and find consensus where possible.\n\nWe are proud to have been a member of the Global Coalition since its establishment and to have taken part in this first global conference. Congratulations to the organisers, particularly John Cusack and Che Sidanius. There was much interest in making this an annual event – so we look forward to being present again at Stockholm 2025!","2024-09-16","framing-financial-crime-as-a-security-threat-2687","Framing financial crime as a security threat","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F998e60c1-df73-4b7c-a031-a976e9dfe17e?width=1000&height=650&format=webp&quality=80",[],[115,141],[197,143,73],"Events",[],2687,[115,151],[197,143,73],[203],1103,[],[157],[],"2024-09-16T16:01:41.000Z","2026-05-29T22:22:32.000Z",[],"\u002Fresources\u002Fnews\u002Fframing-financial-crime-as-a-security-threat-2687",{"id":212,"body":213,"status":6,"type":10,"date":214,"slug":215,"title":216,"image":217,"countries":218,"topic":219,"activity":220,"tags":223,"nid":229,"topics":230,"activities":231,"authors":232,"images":234,"websites":20,"area":20,"programme":20,"language":21,"translations":235,"translation_of":20,"user_created":38,"date_created":236,"user_updated":160,"date_updated":237,"content":238,"link":239},10587,"_This article is adapted from the_ [_2024 Basel AML Index public report_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024)_._\n\nPrivate companies and governments invest significant resources in efforts to combat money laundering and related financial crimes. Financial institutions alone spent an [estimated USD 206 billion globally](https:\u002F\u002Frisk.lexisnexis.com\u002Fglobal\u002Fen\u002Finsights-resources\u002Fresearch\u002Ftrue-cost-of-financial-crime-compliance-study-global-report) on anti-money laundering (AML) compliance in 2023 – and that figure is rising. Yet illicit assets continue to flow through and outside of regulated financial systems. Confiscation rates are still very low, with a long way to go before asset recovery becomes an effective deterrence to financially motivated crimes.\n\nThis is a disaster for countries deprived of [desperately needed funds for development](https:\u002F\u002Functad.org\u002Fsystem\u002Ffiles\u002Fofficial-document\u002Faldcafrica2020_en.pdf), while also negatively impacting on [economies](https:\u002F\u002Fwww.imf.org\u002Fen\u002FBlogs\u002FArticles\u002F2023\u002F12\u002F07\u002Ffinancial-crimes-hurt-economies-and-must-be-better-understood-and-curbed), [security](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fframing-financial-crime-security-threat) and the health of our [planet](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-50).\n\nIt is right to question whether we are on the path to success, and indeed what we mean by success in the fight against money laundering and related financial crimes. This article looks at what data we have and what else we should consider in answering this question.\n\n### 1 Are we making progress in terms of international standards?\n\nA very basic question is whether countries and regions are at least in line with minimum international standards for AML set by the FATF.\n\nWhile it is important to [question](https:\u002F\u002Fwww.rusi.org\u002Fexplore-our-research\u002Fpublications\u002Fcommentary\u002Fwhats-point-financial-action-task-force-standards) FATF data and standards, and to identify [abuses](https:\u002F\u002Fwww.rusi.org\u002Fexplore-our-research\u002Fprojects\u002Fcharting-authoritarian-abuses-fatf-standards) and [unintended consequences](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002FUnintended-consequences-project.html), ultimately they are the foundation of a harmonised global framework aimed at reducing opportunities for criminals to hide and launder illicit funds.\n\n#### _Technical compliance: fewer black holes on the map_\n\nFirst, the good news. Technical compliance with the FATF’s 40 Recommendations has, on average, increased by 12 percentage points globally since the start of the fourth round of evaluations in 2013. Much of that improvement comes from lower-performing countries catching up with the others. This indicates that more countries are at least meeting basic standards of an AML legal and institutional infrastructure. There are fewer black holes on the map.\n\nTo reach the 12 percentage point figure, we analysed data on 113 countries and jurisdictions that had both mutual evaluation reports (MERs) and subsequent follow-up reports (FURs) from the FATF.\n\nThe greatest progress has taken place in the area of preventive measures and targeted financial sanctions. The following table indicates the highest level of progress in technical compliance with FATF Recommendations across all 113 jurisdictions assessed with MERs and FURs:\n\nRecommendation\n\nAverage technical compliance\n\nR.7: Targeted financial sanctions – proliferation of weapons of mass destruction\n\n57% (up from 31%)\n\nR.19: Higher-risk countries\n\n74% (up from 51%)\n\nR.12: Politically exposed persons\n\n73% (up from 51%)\n\nR.16: Wire transfers\n\n71% (up from 50%)\n\nR.22: DNFBPs – Customer due diligence\n\n59% (up from 40%)\n\nR.6: Targeted financial sanctions – terrorism and terrorist financing\n\n62% (up from 43%)\n\nIt is good to see progress in R.22 on designated non-financial businesses and professions (DNFBPs), since this has traditionally been an area of low performance globally and a frequently criticised weakness in AML systems.\n\nThe progress brings hope that more countries have now imposed stricter customer due diligence requirements for gambling businesses, improved record-keeping standards on customer information and transactions, increased the coverage of customer due diligence requirements to relevant professionals such as property developers and precious metal dealers, and increased the responsibilities and obligations for legal professionals.\n\nWhile improvements in most Recommendations may show real progress across countries, the dynamics in R.16 on wire transfers are complicated by the increase in new payment systems and methods that are not captured by this Recommendation.\n\nIn early 2024, the FATF conducted [public consultations](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002FR16-public-consultation-Feb24.html) on possible amendments to R.16 to reflect this evolution in payment systems and to increase the transparency of cross-border payments. It may be that stricter requirements under R.16 will lead to a rapid deterioration in compliance in the next period.\n\n#### _Regional picture: closing the gap_\n\nIn general, countries and regions with low scores in technical compliance with the FATF Recommendations are catching up, including as a result of being [grey listed](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Ffatf-grey-list-truth-and-myths). The top 20 countries and jurisdictions in terms of progress are mostly in Sub-Saharan Africa and Latin America and the Caribbean, followed by East Asia and Pacific, regions with low average performance previously.\n\nThe following table shows countries with the highest level of progress in technical compliance with FATF Recommendations, out of all those assessed with MERs and FURs. Countries with an asterisk (\\*) are those that are or have been on the FATF grey list.\n\nProgress between mutual evaluation report and latest follow-up report\n\nCountries and jurisdictions (progress in percentage points)\n\n40–52 percentage points\n\nMauritius\\* (52), Botswana\\* (50), Vanuatu\\* (49), Mauritania (48), Uganda\\* (40)\n\n25–39 percentage points\n\nPakistan\\* (33), Iceland\\* (33), Saint Lucia (29), Bahamas\\* (28), Sri Lanka\\* (27), Zimbabwe\\* (26)\n\n20–25 percentage points\n\nMongolia\\* (24), Kenya\\* (24), Norway (24), Costa Rica (23), Morocco\\* (23), Fiji (22), Jamaica\\* (22), Bhutan (21), Trinidad and Tobago\\* (21), Tunisia\\* (20)\n\nThese leaps in performance are not the norm, however: more than half of the assessed countries made progress of less than 10 percentage points.\n\n#### _Effectiveness is falling_\n\nMore challenging, and more depressing, is to assess changes in effectiveness according to the FATF’s 11 Immediate Outcomes (IOs). FATF follow-up reports do not currently reassess countries against these effectiveness criteria. At the global level, however, we can see that effectiveness is decreasing. And that decrease is happening from an already very low base.\n\nWe analysed the difference in global effectiveness scores as the FATF increased its coverage of fourth-round evaluation reports from 115 countries and jurisdictions in 2021 to 178 in 2024.\n\nAverage effectiveness dropped from 30 percent in 2021 to 28 percent in 2023 and remained at that low level in 2024. That means newly assessed countries have similarly low levels of effectiveness as those assessed in earlier years.\n\nWhat’s falling the most? The following table displays the IOs with the lowest effectiveness scores on average across all jurisdictions assessed with mutual evaluation reports. All of them dropped still further between 2021 and 2024:\n\nImmediate Outcome (paraphrased)\n\nAverage effectiveness\n\nIO7: Money laundering investigations, prosecutions and effective, proportionate and dissuasive sanctions\n\n20% (down from 21% in 2021)\n\nIO5: Legal persons and arrangements prevented from misuse for money laundering and terrorist financing (ML\u002FTF); beneficial ownership information available to competent authorities\n\n21% (down from 22%)\n\nIO4: Financial institutions and DNFBPs apply AML\u002FCFT preventive measures commensurate with their risks and report suspicious transactions\n\n22% (down from 24%)\n\nIO11: Prevention of financing of proliferation of weapons of mass destruction\n\n22% (down from 24%)\n\nIO3: Appropriate supervision according to a risk-based approach\n\n23% (down from 26%)\n\nIO10: Prevention of terrorist financing \u002F abuse of non-profit sector\n\n24% (down from 27%)\n\nEven in the IOs with the highest average performance globally across all jurisdictions assessed with MERs, we see decreasing effectiveness as more countries are assessed:\n\nImmediate Outcome (paraphrased)\n\nAverage effectiveness\n\nIO2: International cooperation on information, financial intelligence and evidence against criminals and assets\n\n44% (down from 49% in 2021)\n\nIO1: Risks understood and domestic coordination to combat ML\u002FTF and proliferation financing\n\n36% (down from 38%)\n\nIO6: Financial intelligence and other information used investigations\n\n34% (down from 37%)\n\nIO9: Terrorist financing investigations, prosecutions and effective, proportionate and dissuasive sanctions\n\n33% (down from 37%)\n\nIO8: Proceeds and instrumentalities of crime confiscated\n\n27% (down from 29%)\n\nIO8 on proceeds and instrumentalities of crime confiscated dropped despite hopes for a rise, as [asset recovery was an FATF priority](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Fasset-recovery.html) in 2022–2023.\n\nThe big picture? Overall, countries’ AML frameworks are gradually becoming more technical compliant with the global standards but less effective in practice.\n\n### Effectiveness along the asset recovery chain\n\nData from the Basel AML Index Expert Edition Plus, which includes the full FATF dataset, can help to identify weak links in what we call the asset recovery “chain” – all the steps from preventing and detecting illicit financial flows through to their confiscation and restitution.\n\nApplying this concept to FATF data on effectiveness can give us a simplified picture of what might be weak links in the chain. The following figure shows FATF average effectiveness ratings applied to key links in the asset recovery “chain”:\n\n> The concept of the asset recovery chain is at the heart of the support provided by our International Centre for Asset Recovery (ICAR) to partner countries, including Basel AML Index-based technical assistance in strengthening understanding of and resilience to money laundering risks.\n\n### 2 What other data and metrics can we use to better measure success in practice?\n\nFATF data is the best that is available for comparing money laundering vulnerabilities in different countries and jurisdictions, as the same assessment methodology is applied globally.\n\nYet alone it is clearly not enough to give an accurate picture of success. Critics point out that many countries with high performance in both technical compliance and effectiveness are favoured destinations for those seeking to stash, spend and launder money.\n\nThis is why the Basel AML Index methodology takes into account a variety of indicators beyond the quality of a country’s AML framework as assessed by the FATF. They make it easier to evaluate financial crime risk exposure more widely as well as the functioning of the system as a whole. They also make it possible to see where data is missing or could be misleading.\n\nMany of these metrics are useful in evaluating whether systems are working in practice not only to address illicit financial flows as an end in itself but considering wider implications for people and societies.\n\nThe following figure offers some illustrative examples. See the [methodology](https:\u002F\u002Findex.baselgovernance.org\u002Fmethodology) online for more information and subscribe to the Expert Edition (free for most users outside the private sector) to view and filter the full data.\n\n### 3 Clearer goals, better evidence\n\nIt may seem obvious to readers, but it still needs to be stressed: the fight against financial crime is not a narrow technical issue but a multi-dimensional challenge that is interlinked with many aspects of our lives at both the national and global level. A single metric alone will never be sufficient to measure success.\n\nMeasuring success depends on defining the ultimate objective. The FATF’s purpose has always been to “protect financial systems and the broader economy”. This may be a useful intermediate goal. But we support rising calls to position the fight against money laundering and related financial crimes as ultimately key to achieving a more peaceful, just and sustainable world.\n\nAchieving this ambition requires a nuanced understanding of the broader factors driving money laundering risk and their far-reaching consequences, as illustrated above. It also demands robust evidence of the effectiveness and tangible benefits of AML measures, to counter scepticism and bolster the case for sustained investment in these efforts\n\nCrucially, building an effective AML system is not merely a technical task for a single government department or a compliance team. It is a collective mission that requires collaboration across sectors, industries and borders. Only through a shared commitment and clear vision of our end goal can we create a world where financial systems are resilient to exploitation for criminal purposes and where AML measures support broader societal goals.\n\n### Learn more\n\n*   Read the [13th annual Public Edition report of the Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024).\n*   Explore the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F).","2025-02-20","anti-money-laundering-what-is-success-2768","Anti-money laundering: what is success?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F947bee1f-add9-40fb-9346-e20626e7c915?width=1000&height=650&format=webp&quality=80",[],[115,141],[117,221,222,143],"Research","Reports",[224,227],{"tags_id":225},{"id":226,"name":117},1346,{"tags_id":228},{"id":147,"name":148},2768,[115,151],[117,221,222,143],[233],1362,[],[],"2025-12-04T11:01:47.000Z","2026-05-29T22:22:39.000Z",[],"\u002Fresources\u002Fnews\u002Fanti-money-laundering-what-is-success-2768",{"id":241,"body":242,"status":6,"type":61,"date":243,"slug":244,"title":245,"image":246,"countries":247,"topic":248,"activity":249,"tags":250,"nid":251,"topics":252,"activities":253,"authors":254,"images":255,"websites":20,"area":20,"programme":20,"language":21,"translations":256,"translation_of":20,"user_created":38,"date_created":257,"user_updated":160,"date_updated":184,"content":258,"link":259},10577,"The 14th edition of the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) Public Edition – set to be released on 8 December 2025 – will categorise jurisdictions’ financial crime risks using a more nuanced risk-level system.\n\nExperts at this year’s annual review meeting agreed that the change will help Basel AML Index users to better identify lower-risk jurisdictions for money laundering and related financial crimes. The aim is a smarter application of the risk-based approach to anti-money laundering systems, leading to more efficient use of resources and less burdensome application of regulations.\n\n### Mitigating financial crime threats\n\nThe “[risk-based approach](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002FFatfguidanceontherisk-basedapproachtocombatingmoneylaunderingandterroristfinancing-highlevelprinciplesandprocedures.html)” has long been a core element of anti-money laundering and counter-financing of terrorism (AML\u002FCFT) systems.\n\nAs a concept, it makes sense: first gain a thorough understanding of the risks, then apply proportionate mitigation measures.\n\nThe goal is to focus resources and attention on the aspects that pose the highest threat. The concept applies both to private entities subject to AML\u002FCFT reporting requirements, such as financial institutions, and to jurisdictions developing and implementing AML\u002FCFT regulations and supervisory frameworks.\n\n### Poor application = poor results\n\nWhile the risk-based approach is well established, its application in practice still raises questions and triggers valid criticisms and sometimes [unintended consequences](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002FUnintended-consequences-project.html).\n\nPoor implementation or misapplication in the private sector, for example, can lead to over-compliance and a “tick-box” mentality. This increases compliance costs and friction for clients while doing little to improve the effectiveness of mitigation measures.\n\nA superficial assessment of risk may also cause financial institutions to “de-risk” by cutting off certain groups of clients or even entire countries. For example, a humanitarian organisation operating in a higher-risk jurisdiction may struggle to access financial services. In extreme cases, [indiscriminate de-risking](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12) can have even more drastic, long-term unintended consequences for financial systems.\n\nFor supervisory and other public authorities, poor application of a risk-based approach can result in burdensome over-regulation, heavy-handed supervision and misleading guidance. A common criticism is that authorities apply _rule_\\-based rather than _risk_\\-based procedures – blindly following a uniform set of rules for all reporting entities, instead of focusing on what truly matters in preventing or detecting money laundering, terrorist financing or other financial crimes.\n\nIn response to this, recent developments in the Financial Action Task Force (FATF) Recommendations – which set global standards for AML\u002FCFT systems – emphasise the importance of [proportionality](https:\u002F\u002Fwww.fatf-gafi.org\u002Fcontent\u002Fdam\u002Ffatf-gafi\u002Fguidance\u002FGuidance-Financial-Inclusion%20-Anti-Money-Laundering-Terrorist-Financing-Measures.pdf.coredownload.pdf) in applying a risk-based approach. A more nuanced understanding of lower-risk jurisdictions, products or clients is encouraged.\n\n### Basel AML Index risk levels considered at expert review meeting\n\nThe [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) has long been a leading independent tool for assessing geographical risks of money laundering and related financial crimes. The subscription-based [Expert Edition](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) allows users to assess risk levels for 203 jurisdictions across 17 indicators. (Subscription is free for most users outside the private sector.)\n\nDue to the tool’s importance in assessing jurisdictions’ risk scores, we hold an annual expert review meeting to consider the [Basel AML Index methodology](https:\u002F\u002Findex.baselgovernance.org\u002Fmethodology) and ensure it remains accurate, transparent and reflective of evolving financial crime risks.\n\nExperts in AML\u002FCFT and risk assessment methodologies from the public and private sectors, international and non-profit organisations, and academia discussed possible refinements to the current risk levels during the two-part review meeting on 15 and 16 September 2025.\n\nUntil now, the Basel AML Index has categorised jurisdictions’ risk levels for Expert Edition subscribers as follows:\n\n*   0–3.3 = low risk\n*   3.4–6.6 = medium risk\n*   6.7–10 = high risk\n\nThis straightforward approach, used not only by the Basel AML Index but also by many other risk-ranking tools, offers stability and simplicity. However, it may no longer capture the granularity needed by financial institutions and policymakers.\n\nCurrently, around 84 percent of jurisdictions fall into the medium-risk category, while only 2.6 percent are considered low risk. Another concern is that these uniform thresholds do not fully reflect the actual distribution of data.\n\n### Alternative approaches\n\nSeveral statistical methods were considered during the annual review meeting to achieve a more data-driven classification:\n\n*   Standard-deviation-based scoring tailors risk bands to the data’s distribution but assumes a roughly normal shape. This is not fully applicable given the Basel AML Index’s slight positive skew (skew = 0.35).\n*   K-means clustering also groups similar values but requires equal variance between clusters. This is an assumption not fully compatible with the Index’s weighted structure.\n*   Jenks natural breaks classification identifies “natural” groupings within the data, minimising internal variance and maximising differences between clusters. This method adapts flexibly to the actual distribution of jurisdiction scores.\n\nGiven the characteristics of the data distribution, it was decided to adopt the Jenks natural breaks classification.\n\nJurisdictions in the Basel AML Index classified according to the current equal distribution of risk levels (left) vs the Jenks natural breaks classification (right).\n\n### What to expect\n\nFrom the next Public Edition release of the Basel AML Index on 8 December 2025, the Jenks natural breaks classification will be used to highlight risk levels within the three-tier system of the Basel AML Index.\n\nTo emphasise that a jurisdiction’s risk is relative to others, experts also agreed to rename the categories “lower” and “higher” instead of “low” and “high”. The final risk-level categories are therefore:\n\n*   Lower risk: Less than 4.70 (65 jurisdictions with current data)\n*   Medium risk: 4.70–6.08 (84 jurisdictions)\n*   Higher risk: More than 6.08 (54 jurisdictions)\n\nThese breaks will remain fixed for the next year. The levels may be reassessed if there are significant changes in data distribution.\n\n### Care needed\n\nThe new risk-level classification provides a more nuanced picture of AML\u002FCFT risks worldwide. However, any categorisation inevitably simplifies complexities, especially for jurisdictions near category thresholds.\n\nThe Basel AML Index applies these risk levels for information purposes only. Detailed data are provided in Excel format for Expert Edition users, who can apply their own categorisations or filter for specific indicators.\n\nWe encourage all users – and anyone involved in assessing financial crime risks – to adopt more nuanced ways to identify lower-risk jurisdictions, clients or products, and to refine their application of the risk-based approach.\n\n### Additional updates: increased coverage\n\nDue to increased availability of FATF data, the next Public Edition of the Basel AML Index will be able to cover more than a dozen additional jurisdictions compared to the 164 included currently. The broader coverage strengthens the Index’s analytical base while maintaining its commitment to data quality and methodological consistency.\n\nIn addition, our [Expert Edition Plus subscription](https:\u002F\u002Findex.baselgovernance.org\u002Ffeatures-expertplus) – our most comprehensive subscription category, which includes detailed calculative and written analyses of FATF data – will soon cover three further jurisdictions recently assessed by the FATF: Curaçao, Sint Maarten (Kingdom of the Netherlands) and the Holy See (Vatican City).\n\n### Learn more\n\n*   Check out the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) and its [Expert Edition and Expert Edition Plus subscriptions](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition). Subscription is free for most users outside the public sector – simply sign up and verify your eligibility to view and download detailed data on risk indicators for 203 jurisdictions.\n*   Sign up for the [2025 Basel AML Index online launch event](https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F2855) on 9 December.","2025-11-03","identifying-lower-and-higher-risk-jurisdictions-for-money-laundering-basel-aml-index-re-thinks-risk-levels-2860","Identifying lower and higher risk jurisdictions for money laundering: Basel AML Index re-thinks risk levels","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc666fac1-9c17-4430-8a4b-4b72f6954f39?width=1000&height=650&format=webp&quality=80",[],[115,141],[117],[],2860,[115,151],[117],[],[],[],"2025-11-03T17:01:40.000Z",[],"\u002Fresources\u002Fnews\u002Fidentifying-lower-and-higher-risk-jurisdictions-for-money-laundering-basel-aml-index-re-thinks-risk-levels-2860",{"id":261,"body":262,"status":6,"type":61,"date":263,"slug":264,"title":265,"image":266,"countries":267,"topic":268,"activity":270,"tags":271,"nid":272,"topics":273,"activities":274,"authors":275,"images":276,"websites":277,"area":20,"programme":20,"language":20,"translations":278,"translation_of":20,"user_created":38,"date_created":279,"user_updated":39,"date_updated":280,"content":281,"link":282},10527,"Nominations are now open for the [International Anti-Corruption Collective Action Awards 2025](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fawards\u002F).\n\nWith the Collective Action Awards, we celebrate outstanding achievements by multi-stakeholder initiatives in tackling corruption and raising standards of business integrity – and hopefully inspire the development of new Collective Action initiatives.\n\nOrganisations and initiatives can submit their nomination for one of two award categories:\n\n*   Outstanding Achievement in Collective Action 2025 – acknowledging significant contributions towards fairer market conditions and the prevention of corruption through engagement in Collective Action.\n*   Collective Action Inspirational Newcomer 2025 – showcase accomplishments of initiatives that have been active in the field of anti-corruption Collective Action for less than two years.\n\nNomination are open until 2 March 2025.\n\n[Last year’s winners](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fannouncing-winners-2024-anti-corruption-collective-action-awards) were the Agribusiness Anti-Corruption Collective Action in Brazil and the Transparency 100% Movement of the UN Global Compact Network Brazil. The awards were presented at the [5th International Collective Action Conference](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fevents\u002Ficac-2024\u002F) in Basel, Switzerland, in June 2024.\n\nThe anti-corruption Collective Action Awards are non-monetary and will only be granted to organisations, not individuals. Following a jury selection and public vote, the winners of the third international awards edition will be announced on our website and social media in May 2025.\n\n### Learn more\n\n*   For more information on the eligibility criteria, the selection process and the public vote, see our [award methodology](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2025-01\u002F2025%20Award%20Methodology.pdf).\n*   Learn more on the [B20 Collective Action Hub](https:\u002F\u002Fcollective-action.com\u002F), the Basel Institute's platform for knowledge and engagement on anti-corruption Collective Action.","2025-01-22","international-collective-action-awards-2025-nominations-open-now-2748","International Collective Action Awards 2025: nominations open now","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F990d164b-9f0a-4ca2-b73e-a938a2eab0f5?width=1000&height=650&format=webp&quality=80",[],[269,71],"Collective Action",[197],[],2748,[269,71],[197],[],[],[157,269],[],"2025-01-22T17:01:46.000Z","2025-08-31T23:14:40.000Z",[],"\u002Fresources\u002Fnews\u002Finternational-collective-action-awards-2025-nominations-open-now-2748",{"left":284,"top":284,"width":285,"height":285,"rotate":284,"vFlip":286,"hFlip":286,"body":287},0,20,false,"\u003Cpath fill=\"currentColor\" fill-rule=\"evenodd\" d=\"M17 10a.75.75 0 0 1-.75.75H5.612l4.158 3.96a.75.75 0 1 1-1.04 1.08l-5.5-5.25a.75.75 0 0 1 0-1.08l5.5-5.25a.75.75 0 1 1 1.04 1.08L5.612 9.25H16.25A.75.75 0 0 1 17 10\" clip-rule=\"evenodd\"\u002F>",1780676511295]