[{"data":1,"prerenderedAt":333},["ShallowReactive",2],{"news-annual-report-2021-defeating-corruption-for-peace-prosperity-equality-and-dignity-2227":3,"news-annual-report-2021-defeating-corruption-for-peace-prosperity-equality-and-dignity-2227-similar":79,"i-heroicons:arrow-left-20-solid":328},[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":18,"topics":19,"activities":20,"programme":21,"area":21,"websites":22,"language":21,"image":24,"translation_of":21,"countries":35,"tags":36,"authors":37,"images":76,"translations":77,"content":78},10279,"published","2022-06-08T13:18:57.000Z","2025-08-31T23:14:40.000Z","Annual Report 2021: Defeating corruption for peace, prosperity, equality and dignity","Blog","Foreword to our [Annual Report 2021](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2022-05\u002FAnnual%20Report%202021.pdf).\n\nWhen the year 2021 ended, we were cautiously breathing a sigh of relief. It seemed that the pandemic was starting to get under control in a growing number of countries, and that we could turn our full attention again to the other pandemic, corruption.\n\nLittle did we know that not even two months would pass until the world would be stunned by another earthquake. One that would fundamentally shake our belief in principles which are so central to our work, and indeed everyone’s life.\n\nOf course this is not the first time that international law and convention is trampled on, or that global governance seems to have lost its meaning. But wars are not something you compare or rank in levels of horror. War is always wrong.\n\nOur first and foremost hope is that the military aggression in Ukraine ceases, that the killing and destruction stops, and that Ukrainian territorial integrity is preserved. The impact of the war is of course felt worst in Ukraine, but also across the entire world. And as is so often the case, the most vulnerable societies suffer the most, be it from global food and energy insecurity, from redirected development aid, or from the impacts on geopolitical stability.\n\nImportantly, we cannot and should not ignore what this war is teaching us about corruption. It has never been more obvious that corruption is a fundamental threat to our societies, to national and international security, and to every citizen.\n\nCorruption is not “just” an illegal means to do business or beef up a public servant’s salary. Corruption is a strategic weapon, used to buy geopolitical influence, to capture entire economies and to subjugate people. This corruption is often very subtle, employed strategically over a prolonged period of time. The links between money and effect are often so convoluted and remote that they are hard to see or prove.\n\nIf so many people had to die, had to flee, had to lose everything they ever owned, in Ukraine and in the many other corruption-driven wars, at least let us make sure that the world finally wakes up to this reality and starts acting for good. No more wilful blindness or tacit complicity; no more impunity in exchange for trade or political loyalty; and no more dominance of national interests over global goods.\n\nAt the Basel Institute, we are more committed than ever to do our part in what must be a global war – the only war that is ever justified – against corruption. We count on you, our donors, our partners, to work with us and pass the message on: that defeating corruption is fundamental to achieving a world of peace, prosperity, equality and dignity.\n\n[Read the Annual Report 2021](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2022-05\u002FAnnual%20Report%202021.pdf)","2022-05-30",[14],"","annual-report-2021-defeating-corruption-for-peace-prosperity-equality-and-dignity-2227",[17],"Insights",2227,[],[17],null,[23],"Main page",{"id":25,"storage":26,"filename_disk":27,"filename_download":28,"title":9,"type":29,"created_on":30,"modified_on":30,"charset":21,"filesize":31,"width":32,"height":33,"duration":21,"embed":21,"description":21,"location":21,"tags":21,"metadata":34,"focal_point_x":21,"focal_point_y":21,"tus_id":21,"tus_data":21,"uploaded_on":30},"8c8c9688-490d-4d9f-9bfc-7b926d87b830","local","8c8c9688-490d-4d9f-9bfc-7b926d87b830.webp","tmp.webp","image\u002Fwebp","2025-05-12T21:16:40.000Z",98952,1400,1050,{},[],[],[38,59],{"id":39,"news_id":40,"authors_id":55},1165,{"id":5,"status":6,"user_created":41,"date_created":7,"user_updated":42,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":43,"slug":15,"activity":44,"nid":18,"topics":45,"activities":46,"programme":21,"area":21,"websites":47,"translation_of":21,"language":21,"countries":48,"tags":49,"authors":50,"images":52,"translations":53,"content":54},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","b0662e2a-864d-4888-a1b7-4342b7570b30",[14],[17],[],[17],[23],[],[],[39,51],1166,[],[],[],{"id":56,"name":57,"position":21,"image":58},297,"Gretta Fenner","06f7143f-fe9b-45df-87a0-8c2e8f721109",{"id":51,"news_id":60,"authors_id":72},{"id":5,"status":6,"user_created":41,"date_created":7,"user_updated":42,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":61,"slug":15,"activity":62,"nid":18,"topics":63,"activities":64,"programme":21,"area":21,"websites":65,"translation_of":21,"language":21,"countries":66,"tags":67,"authors":68,"images":69,"translations":70,"content":71},[14],[17],[],[17],[23],[],[],[39,51],[],[],[],{"id":73,"name":74,"position":21,"image":75},302,"Mark Pieth","2f4f2174-a03c-4bd1-9cbc-848efef795c6",[],[],[],[80,114,148,177,200,226,251,276,298],{"id":81,"body":82,"status":6,"type":83,"date":84,"slug":85,"title":86,"image":87,"countries":88,"topic":89,"activity":91,"tags":95,"nid":104,"topics":105,"activities":106,"authors":107,"images":108,"websites":109,"area":21,"programme":21,"language":21,"translations":110,"translation_of":21,"user_created":41,"date_created":111,"user_updated":42,"date_updated":8,"content":112,"link":113},9600,"The fifth event in the [Corrupting the Environment](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption\u002Fcorrupting-environment) webinar series explored the latest trends in the online sale of environmental goods, including live animals and wildlife products. What is happening, where, how much and who is doing it? And what are we missing in our efforts to detect and prevent it?\n\nCo-hosted on 21 May by the OECD and Basel Institute on Governance, the event featured speakers from the Europol, Global Initiative Against Transnational Organized Crime (GITOC) and Basel Institute’s International Centre for Asset Recovery. Scroll down for links to the full video and audio recording, or read the following short summary.\n\n### Why is it still easy to buy illegal wildlife online?\n\nAmong the many activities that have shifted more online due to the pandemic is illegal wildlife trade.\n\nThis is hardly surprising. Illicit trade tends to go along with trends in legitimate trade, and various [studies](https:\u002F\u002Functad.org\u002Fnews\u002Fglobal-e-commerce-jumps-267-trillion-covid-19-boosts-online-sales) already point to growth in online retail sales of all types of consumer goods.\n\nIt is concerning, though. This is not only because the internet makes it easy to buy and sell endangered products across borders and to evade domestic legislation. It is also because of the internet's role in socialisation and norm formation. Seeing endangered species being auctioned openly on Facebook while you catch up with friends or browse news makes this crime seem normal and acceptable.\n\nThis is not new, just a worrying acceleration. The online sale of wildlife products and other environmental goods, live and dead, was already rampant across social media, classified ads sites, B2B wholesaler websites and catalogue sites. Why isn’t being detected and taken down, and the criminals caught?\n\n### How policy priorities and regulations (would) support enforcement efforts\n\nOne barrier to effective action against the online sale of environmental goods is under-resourcing of law enforcement. With stretched funds, it is hard for police to raise illegal wildlife trade up their priority lists. This is particularly acute in many developing countries that are the sources of these illegal goods.\n\nThe problem of low prioritisation is changing in some areas, for example in the decision to include [environmental crime as one of the 10 EMPACT priorities](https:\u002F\u002Fwww.europol.europa.eu\u002Fcrime-areas-and-trends\u002Fcrime-areas\u002Fenvironmental-crime), Europol’s priority crime areas, under the 2018-2021 EU policy cycle. A second challenge is weak regulation of the cyber sphere. There is some excellent work underway through voluntary initiatives and partnerships with tech companies such as the [Coalition to End Wildlife Trafficking Online](https:\u002F\u002Fwww.endwildlifetraffickingonline.org\u002F). But the limitations of voluntary action by NGOs and the private sector are highlighted by the persistent and continued sale of endangered wildlife online.\n\nFor example, many platforms including Facebook have imposed clear bans on all trade in live animals and seem to be getting better at deleting content that is reported by NGOs and citizen activists. But it is hard to analyse these results without transparent data on the posts deleted and their content, which is not available. Plus, one can still easily find people auctioning live wild animals and whole pieces of ivory or rhino horn openly to their followers. In some cases, social media adverts feature illegal wildlife, ie the social media firms are not only facilitating but also directly profiting off IWT.\n\nTech companies would need to invest significantly in tools to more effectively stop both the trade and related socialisation, as well as to systematically store and provide usable information on illegal wildlife sales to law enforcement. The fragmentation of the social media and online sales platforms by language adds to the complication.\n\nWithout clear regulation that applies to all relevant online platforms internationally, it is hard to imagine any single company making that type of investment. (Though we would like to be proven wrong!)\n\n### Drilling down from the tip of the iceberg\n\nIn truth, we are only just scratching the surface of the illegal sale in environmental goods, even of products that are bought and sold openly on the public web.\n\nData on the scale and scope on online sales of illegal wildlife trade are still dangerously patchy. By combining techniques for machine learning and social media analysis, [GITOC research](https:\u002F\u002Fglobalinitiative.net\u002Fanalysis\u002Fin-search-of-cyber-enabled-disruption\u002F) reveals that the largest markets for some products may be totally off the radars even of conservation and law enforcement specialists. Adverts appear on a multitude of platforms, often attached to personal phone numbers and in clear violation of the platform's policies. [Europol's work on wildlife and other environmental crimes](https:\u002F\u002Fwww.europol.europa.eu\u002Fcrime-areas-and-trends\u002Fcrime-areas\u002Fenvironmental-crime) supports this finding – that a lot of illegal activity hides in plain sight on the open web. In European priority areas (reptiles, glass eels and birds) a major issue is the intermingling of legal and illegal supply chains, which make it easy to \"launder\" illegal species into legal markets and trade them openly online. Though the international law enforcement response is at an early stage, secure communication channels and partnerships like the [EU Wildlife Cybercrime Project](https:\u002F\u002Fcites.org\u002Fsites\u002Fdefault\u002Ffiles\u002FEU%20WWF%20PROJECT%20-%20Wildlife%20Cybercrime%20project%20factsheet.pdf) and [EnviCrimeNet](http:\u002F\u002Fwww.envicrimenet.eu\u002F) are starting to bear fruit. There are also valuable efforts to build capacity for cyber investigations among law enforcement and to include cyber and financial investigation specialists in environmental crime teams, an approach strongly advocated by the Basel Institute.\n\n### Shining a light into the dark web\n\nThe data gets even patchier as you enter the dark web. A 2018 GITOC report on [Illicit Wildlife Markets and the Dark Web](https:\u002F\u002Fglobalinitiative.net\u002Fwp-content\u002Fuploads\u002F2018\u002F11\u002FTGIATOC-DarkWebReport-Web.pdf) predicted that online sales of wildlife products would rise on the dark web, where the perpetrators are more professional and probably linked to other criminal activities like illegal drugs and arms sales.\n\nAlthough the dark web helps to protect the buyer and seller's anonymity to some extent, the tide is turning. Law enforcement operations to seize and close down dark web markets now often involve the authorities continuing to run the site for a short period. This is providing valuable intelligence on sellers, buyers and operational methods – intelligence which will increase as it is shared and compared across jurisdictions and sectors.\n\n### Following the (virtual) money\n\nCryptocurrencies are mostly used for illegal transactions on the dark web, again in an attempt to conceal the identities of the buyer and seller.\n\nUnfortunately for criminals, cryptocurrencies are not as anonymous as many people think. In many cases, blockchain analysis makes it possible to trace transactions, deanonymise them and even geolocate them. The international response to emerging financial crime threats relating to cryptocurrencies is also strengthening fast, as indicated by the [latest annual Global Conference on Criminal Finances and Cryptocurrencies](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fglobal-conference-criminal-finances-and-cryptocurrencies-closes-7-key-recommendations-fighting) co-organised by Europol, INTERPOL and the Basel Institute on Governance.\n\nRegulations are helping to shine light here. If criminals want to cash out their illegal funds, they have to do this through cryptocurrency exchanges, which now [fall under the scope of the Financial Action Task Force standards](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Fvirtualassets\u002Fdocuments\u002Fvirtual-assets-fatf-standards.html?hf=10&b=0&s=desc(fatf_releasedate)) on anti-money laundering and are therefore obliged to monitor transactions and conduct customer due diligence.\n\nThe implication? We could do a lot to improve detection of illegal wildlife trade online by combining two sets of red flags that are currently kept separately.\n\n*   Red flags that trigger regular suspicious transaction reports (STRs) by financial institutions including cryptocurrency exchanges.\n*   Red flags on environmental or wildlife crimes such as the customer’s background, location, profession and activity patterns, many of which are identified by initiatives such as the [United for Wildlife](https:\u002F\u002Funitedforwildlife.org\u002F) Taskforces.\n\nIf good communication channels exist between financial institutions and law enforcement, this could help detect suspicious transactions and money laundering activities by environmental criminals that result in investigations on the ground.\n\nImportantly, even small pieces of information about a single seizure, transaction or customer have triggered large cases in the past. Europol and INTERPOL play a key role in ensuring this information is channelled to the relevant authorities in compliance with legal frameworks and in a form that can be actioned. Financial institutions and other companies wishing to share information can reach out to the [EU Wildlife Cybercrime Project](https:\u002F\u002Fcites.org\u002Fsites\u002Fdefault\u002Ffiles\u002FEU%20WWF%20PROJECT%20-%20Wildlife%20Cybercrime%20project%20factsheet.pdf) or the National Units of Europol or INTERPOL.\n\n### Building specialist skills and special relationships\n\nBuilding capacity for cryptocurrency analysis among law enforcement is a clear urgency. Another low-hanging fruit is capacity for forensic analysis of digital devices seized in wildlife crime investigations, which often contain a wealth of data on transactions, operations and platforms. A third is building and maintaining the channels and relationships that are necessary for effective information exchange.\n\nAlthough these all hit against the barriers of unequal resources and competing priorities in different countries, specialists in cybercrime, cryptocurrencies and (virtual) financial investigation have a clear place in the fight against illegal online sales of environmental goods. Their role will only grow as both legal and illegal trade continue to intermingle and shift online.\n\n### With thanks to our panel\n\n*   José Antonio Alfaro Moreno, Team Leader, European Serious and Organised Crime Centre (ESOCC), Europol\n*   Simone Haysom, Senior Analyst, Global Initiative Against Transnational Organized Crime \n*   Federico Paesano, Senior Financial Investigation Specialist, Basel Institute on Governance\n*   Juhani Grossmann, Team Leader - Green Corruption programme, Basel Institute on Governance (moderator)\n\n### More\n\n*   Watch the full webinar on [YouTube](https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=n1bvzcNHFPs). \n*   Learn more about the OECD-Basel Institute [Corrupting the environment series](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption\u002Fcorrupting-environment) and register now for our next event on the [illegal waste trade](https:\u002F\u002Fbaselgovernance.zoom.us\u002Fwebinar\u002Fregister\u002FWN_oDxx3ijMRL6KTDWShsCNaA) on 16 June.\n*   The intermingling of legal and illegal supply chains is an underlying theme in the Basel Institute’s four-part series on Wildlife crime – understanding risks, avenues for action. See in particular the resources on [Illegal wildlife trade and financial crime](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=77), [Illegality in the exotic pet trade](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=80) and [Forest crime and the illegal timber trade](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=83).\n*   Federico Paesano leads an open-registration course on [Cryptocurrencies and Anti-Money Laundering](https:\u002F\u002Fbaselgovernance.org\u002Fcourses-and-events\u002Fcryptocurrencies-and-anti-money-laundering-training). Delivered virtually over four 3-hour sessions, the course aims to help practitioners from a wide range of law enforcement, financial and business sectors prevent, detect and investigate the use of cryptocurrencies for illicit activities.","News","2021-05-31","social-media-dark-web-and-cryptocurrencies-curbing-the-illegal-online-sale-of-wildlife-and-environmental-goods-2024","Social media, dark web and cryptocurrencies: curbing the illegal online sale of wildlife and environmental goods","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F445286ad-f5c0-41b5-b762-7a0a8c1c7002?width=1000&height=650&format=webp&quality=80",[],[90],"Green Corruption",[92,93,94],"Events","Research","Presentations",[96,100],{"tags_id":97},{"id":98,"name":99},1303,"Environment",{"tags_id":101},{"id":102,"name":103},854,"Virtual assets",2024,[90],[92,93,94],[],[],[23],[],"2022-05-26T22:53:05.000Z",[],"\u002Fresources\u002Fnews\u002Fsocial-media-dark-web-and-cryptocurrencies-curbing-the-illegal-online-sale-of-wildlife-and-environmental-goods-2024",{"id":115,"body":116,"status":6,"type":83,"date":117,"slug":118,"title":119,"image":120,"countries":121,"topic":122,"activity":125,"tags":128,"nid":135,"topics":136,"activities":138,"authors":139,"images":140,"websites":141,"area":21,"programme":21,"language":21,"translations":142,"translation_of":21,"user_created":41,"date_created":143,"user_updated":144,"date_updated":145,"content":146,"link":147},9567,"Released today, the 10th annual edition of the Basel AML Index raises grave questions about whether jurisdictions are serious about tackling their money laundering and terrorist financing (ML\u002FTF) risks, and what is holding them back.\n\nThe Basel AML Index is an independent annual ranking that assesses ML\u002FTF threats around the world and the capacity of jurisdictions’ anti-money laundering and counter financing of terrorism (AML\u002FCFT) measures to address their specific risks.\n\nThe average global money laundering risk score increased from 5.22 to 5.3 out of 10, as assessed across all 110 jurisdictions in the 2021 Public Edition of the Basel AML Index.\n\nEven among jurisdictions whose risk scores improved this year, none managed to improve by even one point out of 10. Half of improvements were 0.3 of a point or less.\n\nWhat is holding jurisdictions back from effectively tackling their ML\u002FTF risks and avoiding being the weak spot in regional and international financial systems? This year’s [Basel AML Index report](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-09\u002FBasel_AML_Index_2021_10th%20Edition.pdf) looks at four areas of AML\u002FCFT policy that urgently need more attention.\n\n### 1 – A strong response to threats from virtual assets\n\nThe use of virtual assets such as cryptocurrencies is exploding – for legitimate as well as illicit purposes. This year’s Basel AML Index report analyses data from the Financial Action Task Force (FATF) on how jurisdictions are responding to ML\u002FTF threats related to virtual assets.\n\nThe answer: not well at all. Most jurisdictions assessed or re-assessed in the last year have worsened their scores for technical compliance with FATF Recommendation 15 on virtual assets and virtual asset service providers. Average compliance levels have dropped by 10 percentage points globally.\n\n[Read the report to find out why](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-09\u002FBasel_AML_Index_2021_10th%20Edition.pdf).\n\n### 2 – Effective prevention, not just enforcement\n\nPrevious editions of the Basel AML Index have lamented that many jurisdictions have AML\u002FCFT systems that are mostly compliant with FATF technical recommendations but are ineffective in practice.\n\n[This year’s report](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-09\u002FBasel_AML_Index_2021_10th%20Edition.pdf) looks at the distinction between compliance with technical recommendations vs effective implementation. Does the problem prevail for both prevention _and_ enforcement?\n\nThe analysis reveals that:\n\n*   once again, jurisdictions score rather badly for effective implementation across the board;\n*   the discrepancy between technical compliance and effective implementation is even worse in relation to prevention.\n\nThese findings should ring an alarm bell for policy makers. Jurisdictions should invest more resources in the prevention of ML\u002FTF, without reducing resources for enforcement.\n\n### 3 - Beneficial ownership transparency\n\nBeneficial ownership transparency is directly related to the effectiveness of a jurisdiction’s AML systems and the essential role of these systems in preventing, detecting, prosecuting and sanctioning financial crimes.\n\nThe [Basel AML Index report](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-09\u002FBasel_AML_Index_2021_10th%20Edition.pdf) analyses the implementation of beneficial ownership registers around the world. It shows how slow and ineffective implementation of beneficial ownership transparency measures continues to provide safe havens for dirty money.\n\nThis is damaging for individual jurisdictions, but more importantly undermines all global efforts to combat money laundering.\n\n### 4 – Addressing ML\u002FTF vulnerabilities beyond the financial sector\n\nThe final issue highlighted by the Basel AML Index data analysis is the generally weak application of AML\u002FCFT preventive measures by lawyers, accountants, real estate agents and other designated non-financial businesses and professions non-financial entities (DNFBPs).\n\nThis means that there is a significant risk that such businesses and professions remain open to abuse by criminals and corrupt individuals wishing to launder their money. Moreover, there is increasing concern among regulators that:\n\n*   some DNFBPs are advising and assisting criminal clients with hiding and laundering illicit funds;\n*   as some high-profile cases have shown, accountants are used as intermediaries to avoid scrutiny.\n\nAt a minimum, more supervision over DNFBPs is urgently needed. Certain jurisdictions should also tighten their regulatory framework – and ensure that it is effectively enforced – over selected groups of DNFBPs in line with their risk exposure.\n\n### Regional deep dives\n\nFor a second year, the report offers profiles of money laundering risks in different regions. Our regional infographics show how jurisdictions score in relation to each other – and in too many cases let their neighbours down. \n\nPolicymakers should analyse their respective jurisdictions’ risks and make plans for serious reform. No jurisdiction is doing well. We call on all jurisdictions to step up their game.\n\n### See the report and website\n\n*   For a full results, analysis and interactive comparison tables, plus the opportunity to demo or subscribe to the Expert Edition, see our _new_ Basel AML Index website: [index.baselgovernance.org](https:\u002F\u002Findex.baselgovernance.org\u002F)\n*   [Download the press release](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-09\u002FBasel%20AML%20Index%202021%20press%20release%2013Sep2021.pdf)\n*   [Download the 2021 report (PDF)](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-09\u002FBasel_AML_Index_2021_10th%20Edition.pdf)","2021-09-13","basel-aml-index-2021-4-things-holding-back-the-global-fight-against-money-laundering-2087","Basel AML Index 2021: 4 things holding back the global fight against money laundering","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F21c506b0-bf87-4550-82b1-bed5abd4ea12?width=1000&height=650&format=webp&quality=80",[],[123,124],"Anti-Money Laundering","Asset Recovery",[126,127],"Basel AML Index","Media releases",[129,131],{"tags_id":130},{"id":102,"name":103},{"tags_id":132},{"id":133,"name":134},818,"Anti-money laundering",2087,[123,137],"Asset Recovery and Enforcement",[126,127],[],[],[23,126],[],"2022-05-26T22:52:36.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-29T22:21:43.000Z",[],"\u002Fresources\u002Fnews\u002Fbasel-aml-index-2021-4-things-holding-back-the-global-fight-against-money-laundering-2087",{"id":149,"body":150,"status":6,"type":10,"date":151,"slug":152,"title":153,"image":154,"countries":155,"topic":156,"activity":157,"tags":159,"nid":165,"topics":166,"activities":167,"authors":168,"images":170,"websites":21,"area":21,"programme":21,"language":171,"translations":172,"translation_of":21,"user_created":41,"date_created":173,"user_updated":144,"date_updated":174,"content":175,"link":176},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",[],[123,124],[126,93,158,17],"Reports",[160,163],{"tags_id":161},{"id":162,"name":126},1346,{"tags_id":164},{"id":133,"name":134},2768,[123,137],[126,93,158,17],[169],1362,[],"English",[],"2025-12-04T11:01:47.000Z","2026-05-29T22:22:39.000Z",[],"\u002Fresources\u002Fnews\u002Fanti-money-laundering-what-is-success-2768",{"id":178,"body":179,"status":6,"type":83,"date":180,"slug":181,"title":182,"image":183,"countries":184,"topic":186,"activity":188,"tags":189,"nid":190,"topics":191,"activities":192,"authors":193,"images":194,"websites":195,"area":21,"programme":21,"language":21,"translations":196,"translation_of":21,"user_created":41,"date_created":197,"user_updated":42,"date_updated":8,"content":198,"link":199},10331,"Peru has taken an important step towards improving integrity in its public administration and the ability of public-sector entities to deliver services to citizens.\n\nThe Government’s Secretariat for Public Integrity has published a new [Guide to Managing Risks that Affect Public Integrity](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fguia-para-la-gestion-de-riesgos-que-afectan-la-integridad-publica), with the technical support of the Swiss SECO-funded [Strengthening Subnational Public Finance Management Programme](https:\u002F\u002Fwww.gfpsubnacional.pe\u002F) implemented by the Basel Institute on Governance.\n\nIn a [press release](https:\u002F\u002Fwww.gob.pe\u002Finstitucion\u002Fpcm\u002Fnoticias\u002F686880-ejecutivo-publica-guia-para-gestionar-riesgos-de-corrupcion-en-la-administracion-publica) following the Guide’s formal adoption by the Presidency of the Council of Ministers, Prime Minister Alberto Otárola stressed that this action reflects the government's firm commitment to advancing the fight against corruption using a preventive approach.\n\nIts publication, Prime Minister Otárola said, aligns with the policies of President Dina Boluarte and commitments made at the last session of the High Level Anti-Corruption Commission, during the presentation of [Peru's Anti-Corruption Agenda](https:\u002F\u002Fwww.gob.pe\u002Finstitucion\u002Fcan\u002Finformes-publicaciones\u002F3810790-agenda-anticorrupcion-medidas-a-corto-y-mediano-plazo-a-impulsar-durante-el-gobierno-de-transicion).\n\n### What it covers\n\nThe guide seeks to help Peru’s public institutions reduce the risk of corruption and other misconduct, especially in critical areas such as service provision, public procurement and human resources.\n\nIt provides detailed guidance on the underlying framework and fundamental aspects of integrity risk management plus the four phases: identification, evaluation, mitigation and monitoring\u002Fcontinuous improvement.\n\nBased on international best practices and tailored to Peru’s context, the Guide will strengthen the risk management component of the national Integrity Model that public-sector entities in the country are progressively adopting.\n\n### Another achievement of _Programa GFP_\n\nSince 2015, a dedicated group of [Public Finance Management](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-finance-peru) experts has been assisting subnational governments in 11 regions and municipalities in Peru to improve their management of public finances.\n\n_Programa GFP_, funded by the Swiss State Secretariat for Economic Affairs (SECO) and [extended](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fsubnational-public-finance-management-programme-peru-hits-ground-running-second-phase) by the Peruvian and Swiss governments in 2019, has made significant achievements in the last seven years.\n\nAmong other things, an innovative [training concept](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fperus-innovation-week-showcases-training-concept-our-public-finance-management-team) enabled thousands of public officials to continue building capacity even during the worst of the Covid-19 pandemic. As described in this [excerpt](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2023-01\u002FPFM%20Peru_annual%20report%20excerpt.pdf) from the Basel Institute’s 2021 Annual Report, technical support by the Programme’s mentors and advisors has enabled the collection of significantly more tax revenue and improved efficiency of essential services such as vaccine rollouts, the provision of school books and waste management.\n\nLearn more about the risk management guide and programme on the [Programa GFP website](https:\u002F\u002Fwww.gfpsubnacional.pe\u002F2023\u002F01\u002F09\u002Fejecutivo-publica-guia-para-gestionar-riesgos-de-corrupcion-en-la-administracion-publica\u002F) (in Spanish).","2023-01-19","peruvian-government-publishes-integrity-risk-management-guidelines-with-support-from-the-basel-institutes-public-finance-management-programme-2342","Peruvian Government publishes integrity risk management guidelines with support from the Basel Institute’s Public Finance Management programme","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F50a661d0-e004-4711-a83e-afa956d710d5?width=1000&height=650&format=webp&quality=80",[185],7205,[187],"Public Finance Management",[14],[],2342,[187],[],[],[],[23],[],"2023-01-19T17:01:26.000Z",[],"\u002Fresources\u002Fnews\u002Fperuvian-government-publishes-integrity-risk-management-guidelines-with-support-from-the-basel-institutes-public-finance-management-programme-2342",{"id":201,"body":202,"status":6,"type":10,"date":203,"slug":204,"title":205,"image":206,"countries":207,"topic":208,"activity":211,"tags":213,"nid":214,"topics":215,"activities":216,"authors":217,"images":218,"websites":219,"area":21,"programme":21,"language":21,"translations":220,"translation_of":21,"user_created":41,"date_created":221,"user_updated":222,"date_updated":223,"content":224,"link":225},9540,"_A guest blog by Bernard O’Donnell, Head of Fraud Investigations at the [European Investment Bank](https:\u002F\u002Fwww.eib.org\u002Fen\u002Fabout\u002Faccountability\u002Fanti-fraud\u002Findex.htm) (EIB), and Sabine Zindera, Vice President, Legal and Compliance at Siemens AG and head of the [Siemens Integrity Initiative](http:\u002F\u002Fwww.siemens.com\u002Fintegrity-initiative)._\n\nWhen companies are sanctioned for wrongdoing, is there a way to turn the punitive sanction into a positive force – not only for those wronged, but for wider business integrity around the world?\n\nThere is. Exhibit number 1 is a settlement agreement signed in 2013 between the EIB and Siemens AG that addresses alleged past violations of the EIB Anti-Fraud Policy (see the [EIB](https:\u002F\u002Fwww.eib.org\u002Fen\u002Fpress\u002Fnews\u002Feib-and-siemens-settlement-agreement.htm) and [Siemens](https:\u002F\u002Fnew.siemens.com\u002Fglobal\u002Fen\u002Fcompany\u002Fsustainability\u002Fcompliance\u002Fcollective-action\u002Feib-and-siemens-settlement-agreement.html) press releases).\n\nAs part of the settlement, Siemens committed to provide funds totalling EUR 13.64 million to organisations that support projects or other initiatives that promote good governance and the fight against corruption.\n\nIt was agreed that the money would be disbursed under the umbrella of the [Siemens Integrity Initiative](http:\u002F\u002Fwww.siemens.com\u002Fintegrity-initiative), a USD 100 million funding mechanism established following a separate agreement that Siemens had reached with the [World Bank](https:\u002F\u002Fwww.worldbank.org\u002Fen\u002Fnews\u002Fpress-release\u002F2009\u002F07\u002F02\u002Fsiemens-pay-million-fight-fraud-corruption-part-world-bank-group-settlement) in 2009.\n\nNearly a decade on, the EIB has seen the very positive progress that Siemens has made in not only taking appropriate action to remediate past cases of corruption, but also in funding a host of impactful integrity projects around the world. The company is clearly taking an active role in improving the broader situation and has pushed the anti-corruption agenda forward on a local and global level, notably by fostering [Collective Action against corruption](https:\u002F\u002Fbaselgovernance.org\u002Fcollective-action).\n\n### Supporting the rise of Collective Action for fair and sustainable business\n\n“Collective Action” in general refers to action taken together by a group of like-minded and\u002For interested parties to try to achieve a common objective. In this case, Siemens committed to fostering the use of Collective Action to promote greater integrity, to level the playing field and to mitigate business risks.\n\nBack then, Collective Action was an innovative idea. Now, it is rapidly becoming part of [mainstream anti-corruption compliance](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-03\u002Fmainstreaming_collective_action_-_executive_summary.pdf) practice, as companies, governments and civil society representatives see the benefits of working together to overcome hurdles to clean business.\n\nIn total, the Siemens Integrity Initiative has supported 85 projects in over 50 countries across the three Funding Rounds and so-called Golden Stretch Round, and increased its committed funding to nearly USD 120 million. All projects are detailed in the Initiative’s [annual reports](https:\u002F\u002Fbaselgovernance.org\u002Fpublications?topic=All&type=All&country=All&language=All&title=Siemens&external=2), which tell a powerful story about the growing maturity and reach of Collective Action.\n\nCommenting on the Golden Stretch round, of which the Basel Institute is one of the eight organisations [selected for additional funding](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fsiemens-integrity-initiative-funds-basel-institute-golden-stretch-promoting-anti-corruption), Sabine Zindera said:\n\n> In selecting the projects to be supported, we placed particular emphasis on how the sustainability of their activities and results can be ensured beyond 2024, and on how our partners will inspire, support and engage local non-governmental organisations and the public and private sectors through their longstanding networks and institutional standing. We are pleased to again support diverse projects in order to promote fair competition and fight corruption with a portfolio balanced by region and topic.\n\nThe EIB sees the value of Collective Action to combat corruption and agrees that the results are now clear: the projects have been positive for both EIB and Siemens in terms of resolving the past issues relating to the settlement. Globally, they have also had a significant impact in terms of governance and cleaner business.\n\n### Settlements that make sense\n\nSiemens was the first company to set up such a fund as part of a settlement with a multilateral development bank (MDB). Since then, [EIB has signed similar settlement agreements](https:\u002F\u002Fwww.eib.org\u002Fen\u002Fabout\u002Faccountability\u002Fanti-fraud\u002Fexclusion\u002Findex.htm) with companies including Volkswagen and, more recently, JSC Nenskra Hydro and Hyundai Engineering & Construction Co.\n\nAlthough such settlement agreements are not always appropriate, in some cases there may be suitable possibilities to include a sanction that requires the company to make additional efforts and commitments that are not purely monetary.\n\n### Proactive coordination to combat private-sector corruption\n\nThis constructive approach to settlements chimes with the proactive coordination that exists between MDBs in relation to corruption and fraud.\n\nThe six MDBs, including the World Bank and EIB, all share common definitions of fraud and corruption thanks to the 2006 [Uniform Framework for Preventing and Combating Fraud and Corruption](http:\u002F\u002Fwww.iadb.org\u002Fdocument.cfm?id=37018601). The Framework also introduced [guidelines and principles to conduct investigations](https:\u002F\u002Fwww.eib.org\u002Fen\u002Fabout\u002Fdocuments\u002Fifi-anti-corruption-task-force-uniform-framework.htm).\n\nThe MDBs also have [consistent policies on sanctioning](https:\u002F\u002Fidbdocs.iadb.org\u002Fwsdocs\u002Fgetdocument.aspx?docnum=EZSHARE-1138756496-328) those found to have engaged in such wrongdoing, including the [Cross-Debarment Agreement](http:\u002F\u002Fwww.iadb.org\u002Fdocument.cfm?id=35154738) signed in 2010 by the MDBs with the exception of EIB. This enables participating MDBs to mutually recognise certain sanctions imposed by any of the signatory institutions against firms and individuals found to have engaged in prohibited practices.\n\n### The bottom line\n\nThe mid-term review of the Siemens Integrity Initiative (see page 90 onwards in the [2017 Annual Report](http:\u002F\u002Fwww.siemens.com\u002Fintegrity-initiative\u002FReport2017)) concluded that there is “strong evidence” that the Siemens Integrity Initiative-funded Collective Action projects have “achieved their intended short-term results” and made “significant contributions to change within their respective contexts”.\n\nIt is “the passionate and committed work of Integrity Partners and the Siemens Munich Project Office that has helped promote, enhance the visibility of, and contribute to learning on Collective Action, including demonstrating to the private sector that there is a business case for investing in Collective Action”, it continued. In so doing, said the report, “the Integrity Initiative has made valuable contributions to the global fight against corruption”.\n\nThe story is not over yet, and we are all looking forward to seeing the fruits of anti-corruption Collective Action blossom and mature over the coming years. Visit the [B20 Collective Action Hub](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub), developed and maintained by the Basel Institute on Governance, for more on Collective Action and ways to get involved.\n\n### _About the authors_\n\n_Bernard O’Donnell is Head of Fraud Investigations at the European Investment Bank (EIB). In his current position, Bernie oversees investigations into allegations of fraud, corruption and other prohibited conduct affecting EIB Group financed projects and activities in collaboration with national law enforcement and prosecution offices, along with the investigation offices of other international financial Institutions and the European Public Prosecutor’s Office and OLAF._\n\n_Sabine Zindera is Vice President, Legal and Compliance at Siemens AG and head of the Siemens Integrity Initiative. In this role she leads Siemens´ global Collective Action activities, helping to build alliances against corruption to foster clean business and to support fair market conditions. As part of this, she also manages Siemens' relationships with international and non-governmental organisations around the world._","2021-12-06","siemens-and-the-european-investment-bank-fostering-integrity-through-collective-action-and-constructive-settlements-2133","Siemens and the European Investment Bank: Fostering integrity through Collective Action and constructive settlements","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F47ec9765-2a36-4eba-bbc1-252dc4ea4da8?width=1000&height=650&format=webp&quality=80",[],[209,210],"Collective Action","Private Sector",[17,212],"Partnerships",[],2133,[209,210],[17,212],[],[],[23,209],[],"2022-05-26T22:52:12.000Z","dfef11db-1bc6-47e9-a61d-93443995484b","2026-05-08T21:11:00.000Z",[],"\u002Fresources\u002Fnews\u002Fsiemens-and-the-european-investment-bank-fostering-integrity-through-collective-action-and-constructive-settlements-2133",{"id":227,"body":228,"status":6,"type":10,"date":229,"slug":230,"title":231,"image":232,"countries":233,"topic":234,"activity":235,"tags":236,"nid":239,"topics":240,"activities":241,"authors":242,"images":244,"websites":245,"area":21,"programme":21,"language":21,"translations":246,"translation_of":21,"user_created":41,"date_created":247,"user_updated":144,"date_updated":248,"content":249,"link":250},9565,"_The Basel AML Index 10th Edition explore four aspects hindering the global fight against money laundering and terrorist financing (ML\u002FTF). The first element crunched Financial Action Task Force (FATF) data on how jurisdictions are responding to money laundering threats related to virtual assets. The answer: not well at all. Excerpt from the full report:_\n\nThe use of virtual assets such as cryptocurrencies is exploding – for legitimate as well as illicit purposes.\n\nIn January 2021, there were an [estimated 106 million cryptocurrency users](https:\u002F\u002Fassets.ctfassets.net\u002Fhfgyig42jimx\u002F5u8QqK4lqjEgL506mOx4m3\u002Fd44d8e204aecfc75a839e2a9d505f5d1\u002FCrypto.com_Data_Report_-_On-chain_Market_Sizing.pdf) globally. Data on how any of these may be using cryptocurrencies for criminal purposes, including to launder stolen money, is however scarce. According to a [2021 report by blockchain analysis firm Chainalysis](https:\u002F\u002Fgo.chainalysis.com\u002F2021-Crypto-Crime-Report.html), of the estimated USD 21.4 billion in cryptocurrency transactions in 2019, criminal activity represented around 2.1 percent (USD 450 million).\n\nCryptocurrencies have unique characteristics, many of which are very positive, including for example the potential to improve financial inclusion. Yet their borderless nature and existence outside the formal financial system also make them a tempting option for criminals to conceal proceeds of corruption and other crimes, evade tax or fund terrorism.\n\n### Mitigating ML \u002F TF threats from virtual assets – FATF Recommendation 15\n\nIn 2018, in an effort to motivate jurisdictions to take action to prevent virtual assets becoming a threat to global financial stability, the FATF revised its Recommendation 15 on virtual assets and virtual asset service providers (VASPs). Finalised amendments, an Interpretive Note and accompanying [Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Ffatfrecommendations\u002Fdocuments\u002Fguidance-rba-virtual-assets.html) followed in 2019.\n\nIn essence, the revised Recommendation requires among other things:\n\n*   Jurisdiction must apply a risk-based approach to AML \u002F CFT risks associated with virtual assets.\n*   VASPs should be licensed\u002Fregistered, and subject to adequate regulation and supervision.\n*   VASPS must conduct customer due diligence on one-off transactions over USD\u002F EUR 1,000, and submit suspicious activity reports where needed.\n*   VASPs should obtain information about the originator and beneficiary of transfers and make it available to competent authorities (the so-called \"travel rule\").\n\nThe FATF [defines](https:\u002F\u002Fwww.fatf-gafi.org\u002Fglossary\u002Fu-z\u002F) the term “virtual asset” as any “digital representation of value that can be digitally traded, or transferred, and can be used for payment or investment purposes”. This does not include digital representations of fiat currencies or other financial assets included elsewhere in its Recommendations.\n\nVASPs include natural or legal persons that offer services such as exchanging between virtual assets and fiat currencies, exchanging between different forms of virtual assets, transferring virtual assets, safekeeping or administering virtual assets, or providing other financial services relating to virtual assets.\n\n### How are jurisdictions doing at mitigating their risks of money laundering using virtual assets?\n\nIn July 2020 and July 2021, the FATF issued the [first](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Ffatfrecommendations\u002Fdocuments\u002F12-month-review-virtual-assets-vasps.html) and [second](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Ffatfrecommendations\u002Fdocuments\u002Fsecond-12-month-review-virtual-assets-vasps.html) reports on the results of 12-month reviews on the revised standard.\n\nIt is still early days, as the final version of the revised Recommendation 15 was only issued in June 2019. However, initial signs are not encouraging.\n\n*   Of the 27 jurisdictions assessed or reassessed for technical compliance with the new R.15 from June 2020 to June 2021, 19 downgraded their scores. Five jurisdictions retained the same scores and only three managed to improve.\n*   The average compliance score for R.15 across all jurisdictions assessed with the latest (fourth-round) FATF methodology decreased from 70% to 60%.\n*   Of the 10 jurisdictions assessed with Mutual Evaluation Reports, none was rated as being compliant. Two jurisdictions were non-compliant (score of 0), 5 were partially compliant (score of 1 out of 3) and 3 were largely compliant (score of 2 out of 3).\n\n### Is there a risk of “regulator shopping” in the virtual assets sector?\n\nYes. The consequences of individual failings by jurisdictions in implementing effective AML \u002F CFT requirements on VASPs could be serious.\n\nThe reason is simple and visible in regular money laundering schemes too: criminals wishing to abuse virtual assets for illicit purposes can simply switch from jurisdictions with a strong regulatory framework to one in which regulations are weak and not enforced. This risk is exacerbated by the hyper-global nature of virtual assets.\n\nA lack of coordinated and concerted global action may therefore result in some jurisdictions becoming safe havens for illicit activity using virtual assets.\n\nThis challenge has been recognised by the European Commission’s June 2021 package of proposals to tackle ML \u002F TF, which includes an ambitious plan to harmonise AML \u002F CFT legislation in relation to VASPs across all EU jurisdictions. This is a positive move, but without similar efforts among other jurisdictions and regional bodies, it is likely that the illicit activity will simply move to locations with fewer or no controls.\n\n### What are the biggest issues to fix, and how can jurisdictions with upcoming FATF assessments obtain a better evaluation?\n\nThe FATF’s second review of trends with regard to the implementation of the revised R.15 indicated progress in certain areas, including with respect to transposing the new requirements into domestic legislation, submitting suspicious activity reports and establishing supervisory regimes.\n\nSignificant gaps however remain, in particular in the following areas:\n\n*   Weak implementation of the “travel rule”, meaning that information on the originators and beneficiaries of cryptocurrency transactions is not being obtained or made available to competent authorities.\n*   Sluggish action by jurisdictions in implementing AML \u002F CFT obligations in the virtual assets sector, with infrequent examinations or sanctioning.\n*   Generally, a lack of knowledge and expertise among supervisory\u002Fregulatory bodies in the field of virtual assets, reducing their ability to oversee and guide VASPs.\n\n### What data is available to assess ML \u002F TF risks relating to virtual assets?\n\nThe new and fast-evolving nature of the virtual assets sector means that reliable data relevant to evaluating money laundering risks is not widely available.\n\nRegular market data on virtual assets, such as the use of cryptocurrencies and the location of cryptocurrency mining centres, are largely collected and analysed by blockchain analytic companies such as Chainalysis, CipherTrace, Coinfirm, Elliptic, Merkle Science, Scorechain, TRM Labs.2\n\nHowever, the differences in methodologies, analytical techniques and tools, along with the proprietary nature of the data, mean that comparability is difficult. The data also tend to focus on a select few cryptocurrencies only and are therefore not sufficiently comprehensive for this purpose.\n\nA prerequisite for evaluating risks of ML \u002F TF relating to virtual assets is understanding geographical trends in their use and regulation.\n\n*   Chainalysis issued a helpful [analysis of such geographic trends](https:\u002F\u002Fgo.chainalysis.com\u002Frs\u002F503-FAP-074\u002Fimages\u002F2020-Geography-of-Crypto.pdf) in September 2020, although it does not provide data on the risk of misuse of cryptocurrencies.\n*   Statistica published a list of [jurisdictions with the highest cryptocurrency use per capita](https:\u002F\u002Fwww.statista.com\u002Fchart\u002F18345\u002Fcrypto-currency-adoption\u002F) in March 2021. There is however no evidence as yet that a lack of regulation or intensive usage of virtual currencies in a population correlates with an increased risk of ML \u002F TF using virtual assets.\n\nWe therefore suggest that the FATF assessment of jurisdictions’ compliance with R.15 remains the most reliable source of data on ML \u002F TF risks relating to virtual assets. It also has the virtue of enabling comparisons across jurisdictions and measurement of progress over time.\n\n### Learn more\n\n*   See the [Basel AML Index 2021 press release](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fbasel-aml-index-2021-4-things-holding-back-global-fight-against-money-laundering).\n*   Visit our brand new Basel AML Index website at: [index.baselgovernance.org](https:\u002F\u002Findex.baselgovernance.org).\n*   On 7-8 December, the Basel Institute is hosting the 5th annual [Global Conference on Criminal Finances and Cryptocurrencies](https:\u002F\u002Fbaselgovernance.org\u002F5CrC) in collaboration with INTERPOL and Europol. Sign up to be notified when registration opens.\n*   Federico Paesano's [quick guide to cryptocurrencies and money laundering investigations](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-1-cryptocurrencies-and-money-laundering-investigations) offers a short overview of how cryptocurrencies can be used to facilitate serious crimes or launder stolen money, and what law enforcement can do about it.","2021-09-15","what-this-year039s-basel-aml-index-says-about-money-laundering-threats-from-cryptocurrencies-2093","What this year's Basel AML Index says about money laundering threats from cryptocurrencies","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F69911f93-2118-4c8c-8d7a-cd6fea019b71?width=1000&height=650&format=webp&quality=80",[],[123,124],[126,158,17],[237],{"tags_id":238},{"id":102,"name":103},2093,[123,137],[126,158,17],[243],1186,[],[23,126],[],"2022-05-26T22:52:34.000Z","2026-05-29T22:21:42.000Z",[],"\u002Fresources\u002Fnews\u002Fwhat-this-year039s-basel-aml-index-says-about-money-laundering-threats-from-cryptocurrencies-2093",{"id":252,"body":253,"status":6,"type":10,"date":254,"slug":255,"title":256,"image":257,"countries":258,"topic":259,"activity":260,"tags":261,"nid":264,"topics":265,"activities":266,"authors":267,"images":269,"websites":270,"area":21,"programme":21,"language":21,"translations":271,"translation_of":21,"user_created":41,"date_created":272,"user_updated":144,"date_updated":273,"content":274,"link":275},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",[],[123,124],[17],[262],{"tags_id":263},{"id":133,"name":134},2760,[123,137],[17],[268],1090,[],[23],[],"2025-02-06T11:01:49.000Z","2026-05-29T22:22:34.000Z",[],"\u002Fresources\u002Fnews\u002Ffatf-grey-list-truth-and-myths-2760",{"id":277,"body":278,"status":6,"type":10,"date":279,"slug":280,"title":281,"image":282,"countries":283,"topic":284,"activity":285,"tags":286,"nid":287,"topics":288,"activities":289,"authors":290,"images":292,"websites":293,"area":21,"programme":21,"language":21,"translations":294,"translation_of":21,"user_created":41,"date_created":295,"user_updated":42,"date_updated":8,"content":296,"link":297},10298,"The [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) – the Basel Institute’s global money laundering index and risk assessment tool – is adding environmental crime data to its set of indicators of money laundering and terrorist financing (ML\u002FTF) risk. The data will come from the [Global Organized Crime Index](https:\u002F\u002Focindex.net\u002F).\n\nThe change will be implemented in the 11th Public Edition of the Basel AML Index, due out in September this year, as well as in the subscription-based [Expert Edition](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) from September onwards.\n\n### Environmental crime a growing money laundering threat\n\nCrimes involving wildlife, minerals, fish, forests and waste not only threaten the health of our planet and sustainable livelihoods, but the integrity of financial systems. Such crimes are a highly profitable criminal enterprise, [generating around USD 110 to 281 billion in illicit gains each year](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Fmethodsandtrends\u002Fdocuments\u002Fmoney-laundering-from-environmental-crime.html) according to the Financial Action Task Force (FATF).\n\nThe FATF identifies environmental crimes as one of the designated predicate offences for money laundering and urges both the public and private sectors to do more to detect financial flows from environmental crimes.\n\nDeveloped by the Global Initiative Against Transnational Organized Crime and first published in 2021, the Global Organized Crime Index goes some way to addressing a lack of reliable data on countries' risks related to environmental crimes. It covers 193 jurisdictions. The data is based on thorough desk research of publicly available information conducted by country\u002Fregion-based experts. It has a well-documented methodology and a strong quality assurance process.\n\nFrom the next edition, the Basel AML Index will include data on crimes involving flora, fauna and non-renewable resources. The data will appear in the category “Quality of AML\u002FCFT framework” with a 5 percent weighting in the overall score. Environmental crime risks will therefore have the same weighting in the Basel AML Index as the current indicators on human trafficking and narcotics trafficking. The weighting of the Financial Secrecy Index will reduce accordingly from 20 percent to 15 percent.\n\n### Annual review: keeping up with ML\u002FTF trends\n\nThe decision to add environmental crime data was made at the formal annual review meeting, which gathers a group of experts in AML\u002FCFT, compliance and risk assessment. The annual review ensures that the Basel AML Index [methodology and indicators](https:\u002F\u002Findex.baselgovernance.org\u002Fmethodology) remain valid and representative of current money laundering and terrorist financing risk trends.\n\nOther key decisions were:\n\n#### 1 – To exclude data on four countries from the World Bank’s Extent of Corporate Transparency Index\n\nThe Extent of Corporate Transparency Index is part of the World Bank’s Doing Business report, which was [discontinued](https:\u002F\u002Fwww.worldbank.org\u002Fen\u002Fnews\u002Fstatement\u002F2021\u002F09\u002F16\u002Fworld-bank-group-to-discontinue-doing-business-report) in September 2021 following the publication of an investigation into data irregularities.\n\nThe data reflects corporate transparency in ownership stakes, compensation, audits and financial prospects. Transparency of this type of information in the business sector is a key aspect when considering money laundering risks, since secrecy in these areas allows the true ownership of assets to be hidden. In the Basel AML Index, it is included as an indicator in the category “Financial transparency and standards” with a 2.5 percent weight in the overall risk score.\n\nSince there is no other public indicator that fully substitutes the Extent of Corporate Transparency Index, the Basel AML Index will continue to use the data until the World Bank releases its replacement to the Doing Business report. Data on Azerbaijan, China, Saudi Arabia and the United Arab Emirates will be excluded due to the [identified discrepancies](https:\u002F\u002Fthedocs.worldbank.org\u002Fen\u002Fdoc\u002F791761608145561083-0050022020\u002Foriginal\u002FDBDataIrregularitiesReviewDec2020.pdf).\n\n#### 2 – To publish short reports on jurisdictions delisted from the FATF grey or black lists\n\nAs part of the assessment process of the Financial Action Task Force (FATF) and its regional bodies, a jurisdiction may be placed on a [“grey list”](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Fhigh-risk-and-other-monitored-jurisdictions\u002F) (subject to increased monitoring) or “black list” (a high-risk jurisdiction subject to a call for action). This follows identified failings in how the jurisdiction addresses its ML\u002FTF risks.\n\nBeing placed on the FATF’s grey or black lists has a negative impact on a jurisdiction’s investment climate, trade and capital flows.\n\nThe Basel AML Index Expert Edition dashboard highlights a jurisdiction’s placement on the FATF grey or black lists for informational purposes, but these lists are not used when calculating its overall risk score. This is because the Index already uses FATF data from Mutual Evaluation Reports and Follow-Up Reports as a significant component (35 percent weight) of the overall score.\n\nThe Basel AML Index will from now on publish special briefings on jurisdictions delisted from the grey or black lists. The briefings will cover the main issues that led to the listing, the action plan developed to address them, and publicly available data on how it was implemented. [Find the first briefing on Malta here](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-briefing-maltas-delisting-fatf-grey-list).\n\n### More\n\n*   The Basel Institute on Governance has developed and maintained the Basel AML Index since 2012 through its [International Centre for Asset Recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery).\n*   The Public Edition of the Basel AML Index, with its accompanying [report and infographics on money laundering risk trends](https:\u002F\u002Findex.baselgovernance.org\u002Fdownload), is published annually in August\u002FSeptember.\n*   The [Expert Edition](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) of the Basel AML Index is an ML\u002FTF country risk-rating tool for compliance, risk assessment, policy and research purposes. The Expert Edition Plus option offers a detailed comparative analysis of the FATF Mutual Evaluation Reports and special reports on ML\u002FTF risks in small jurisdictions. Subscription to the Expert and Expert Plus editions is free for public-sector, international, non-profit and academic organisations, plus independent journalists.","2022-07-27","environmental-crime-data-added-to-money-laundering-risk-indicators-in-basel-aml-index-2259","Environmental crime data added to money laundering risk indicators in Basel AML Index","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fca5778e2-f6ae-4133-bc36-4016b535721b?width=1000&height=650&format=webp&quality=80",[],[123],[126],[],2259,[123],[126],[291],1161,[],[23,126],[],"2022-08-14T19:46:08.000Z",[],"\u002Fresources\u002Fnews\u002Fenvironmental-crime-data-added-to-money-laundering-risk-indicators-in-basel-aml-index-2259",{"id":299,"body":300,"status":6,"type":83,"date":301,"slug":302,"title":303,"image":304,"countries":305,"topic":306,"activity":309,"tags":310,"nid":318,"topics":319,"activities":320,"authors":321,"images":322,"websites":323,"area":21,"programme":21,"language":21,"translations":324,"translation_of":21,"user_created":41,"date_created":325,"user_updated":42,"date_updated":8,"content":326,"link":327},9646,"How effectively does the Business 20 (B20) process channel recommendations on anti-corruption from the business community up to the Group of Twenty (G20) leaders? Are there ways to increase the uptake of B20 recommendations by the G20 Anti-Corruption Working Group (ACWG) and in the final Communiqué at the G20 Summit?\n\nThe hundreds of business representatives that take part in B20 process each year, including in its anti-corruption workstreams, are keen to know the answers to those questions. Simply put, they wish to know that the time and effort they invest in the B20 process is well spent. Participants rightly want to make the process as efficient and effective as possible.\n\nThis paper helps to answer the questions by analysing the responsiveness of the G20 leaders to the B20’s recommendations on anti-corruption from 2010 to 2017. The analysis uses three previous attempts to measure the impact of the B20 process on G20 outcomes, by the German and Russian presidencies and by the International Chamber of Commerce (ICC).\n\nThree points stand out:\n\n#### 1\\. Standalone taskforces or cross-cutting workstreams?\n\nFirst, the form of the anti-corruption workstream matters. Taking advantage of the flexibility of the G20 process, most presidencies in this period have set up standalone anti-corruption taskforces. Benefits include clear ownership of the topic and a more focused, sustained and coordinated discussion.\n\nOthers have included corruption as a cross-cutting theme. The Australian presidency in 2014 did both, and was the most successful in terms of uptake of anti-corruption recommendations.\n\n#### 2\\. Strong, ongoing relationships\n\nContinuity and relationships are vital in a process that evolves so dynamically each year, with each presidency setting its own priorities and establishing its own working structures. The B20 has cultivated a close working relationship with the ACWG, a factor that has clearly and positively affected the uptake of its anti-corruption recommendations.\n\nThis is important because the ACWG’s bi-annual or tri-annual Anti-Corruption Action Plans are the central working documents to capture and translate G20 commitments into action and to report on progress. They are one of the few ways of holding G20 leaders to account for their commitments on anti-corruption.\n\n#### 3\\. Strategic alignment of focus topics\n\nThe analysis also highlights an increased uptake of B20 anti-corruption recommendations following a more strategic and pragmatic alignment of the B20 with G20 focus topics.\n\n### So far, so high-level\n\nDuring the first seven years of the B20 anti-corruption work, the G20 uptake has been limited to high-level recommendations. Action-oriented recommendations were ignored.\n\nThe B20 has, for example, consistently called on G20 governments to work together with the private sector to foster anti-corruption Collective Action initiatives and to support the development of [High Level Reporting Mechanisms](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Fhrlm) (HLRMs) to address corruption issues in public procurement – so far to little avail.\n\n### Looking back to look forward\n\nTaking stock and assessing the effectiveness in uptake not only helps to better tailor the B20 approach for upcoming cycles. It is also an important tool to demonstrate impact to engaged businesses, to strengthen sustainable engagement and to ensure the impact the B20 process is striving for reflects the expectation of the engaged business community. \n\nWe hope this analysis, and our plans to apply similar assessment methods to the 2018-2020 cycles, will help to hone the efforts of those involved in the B20 anti-corruption dialogues in upcoming cycles. All eyes will be on Italy now, which takes over the presidency from Saudi Arabia in 2021.\n\n[Download the report here](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fg20s-responsiveness-b20-anti-corruption-recommendations-2010-2017-part-i-baseline). This report is part of a wider Collective Action project funded by the [Siemens Integrity Initiative](https:\u002F\u002Fnew.siemens.com\u002Fglobal\u002Fen\u002Fcompany\u002Fsustainability\u002Fcompliance\u002Fcollective-action.html).","2020-12-09","new-report-highlights-3-ways-to-enhance-b20g20-dialogue-on-anti-corruption-1938","New report highlights 3 ways to enhance B20–G20 dialogue on anti-corruption","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fb0533ef1-930e-4abd-8c72-f3cba38b9ec2?width=1000&height=650&format=webp&quality=80",[],[209,307,308,210],"HLRM","Integrity Pacts",[93,158,212],[311,314],{"tags_id":312},{"id":313,"name":209},909,{"tags_id":315},{"id":316,"name":317},1299,"Development assistance",1938,[209,307,308,210],[93,158,212],[],[],[23,209],[],"2022-05-26T22:53:44.000Z",[],"\u002Fresources\u002Fnews\u002Fnew-report-highlights-3-ways-to-enhance-b20g20-dialogue-on-anti-corruption-1938",{"left":329,"top":329,"width":330,"height":330,"rotate":329,"vFlip":331,"hFlip":331,"body":332},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>",1780676469279]