[{"data":1,"prerenderedAt":278},["ShallowReactive",2],{"news-basel-institute-letter-of-commitment-to-un-global-compact-107":3,"news-basel-institute-letter-of-commitment-to-un-global-compact-107-similar":30,"i-heroicons:arrow-left-20-solid":273},[4],{"id":5,"status":6,"date_created":7,"date_updated":8,"title":9,"type":10,"body":11,"date":12,"topic":13,"slug":14,"activity":15,"nid":18,"topics":19,"activities":20,"programme":21,"area":21,"websites":22,"language":21,"image":21,"translation_of":21,"countries":24,"tags":25,"authors":26,"images":27,"translations":28,"content":29},9990,"published","2022-05-26T22:58:08.000Z","2025-08-31T23:14:59.000Z","Basel Institute Letter of Commitment to UN Global Compact","","The Basel Institute has recently published its letter of commitment to the UN Global Compact and its Ten Principles. The Basel Institute has partnered with UNGC since 2013 in support of our shared goal of combating corruption. The letter of commitment is the Basel Institute’s second Communication on Engagement and describes activities and outcomes of our efforts in support of the UN Global Compact Principles, and in particular its tenth principle on corruption, from November 2015 through October 2017.\n\nBelow is the full text of the letter.\n\nUnited Nations Global Compact – Communication on Engagement\n-----------------------------------------------------------\n\n### Statement of Continued Support\n\nThe Basel Institute on Governance is pleased to confirm its commitment to the United Nations Global Compact (UNGC) and its Ten Principles. The Basel Institute is a non-profit organization, think-tank, and Centre of Excellence focused on combating and preventing corruption and recovering stolen assets obtained through corruption in fulfillment of the UNGC’s 10th Principle on Anti-Corruption. The Basel Institute has partnered with the UNGC since 2013 in support of our shared goal of combating corruption. This is the Basel Institute’s second Communication on Engagement and describes activities and outcomes of our efforts in support of the UN Global Compact Principles from November 2015 through October 2017. \n\n### Description of Actions and Measurement of Outcomes\n\nThe International Centre for Collective Action (ICCA), which is part of the Basel Institute on Governance, won a competitive tender to develop and maintain the B-20 Hub on Anti-Corruption Collective Action in partnership with the UN Global Compact in July 2013. To that end, the ICCA launched a new website [www.collective-action.com](http:\u002F\u002Fwww.collective-action.com) in June 2014, which it continues to maintain and update. This website serves as a comprehensive, interactive online database, as well as a resource centre for all information on Anti-Corruption Collective Action, including examples of Collective Action initiatives and practical tools and other knowledge products to support Collective Action.\n\nSince October 2015, the Basel Institute and UNGC are collaborating intensively on a joint project sponsored by the Siemens Integrity Initiative entitled: “Scaling up Anti-Corruption Collective Action: B20 Hub on Anti-Corruption Collective Action.” In this context, the Basel Institute is providing expert support to the United Nations Global Compact Office, as well as the local Global Compact networks in Brazil, Japan, Kenya, and Nigeria. The objective of this project is to enhance the knowledge and capacity of these UNGC local networks to promote Collective Action as a tool to generate tangible anticorruption action by businesses in their networks. Most recently, the Basel Institute co-hosted and contributed to a workshop and clinic on Anti-Corruption Collective Action in New York at the Global Compact Offices for local UNGC networks, held on the sidelines of this year’s Global Compact Leaders Summit in New York in September 2017.\n\nBeyond this particular project, the Basel Institute continuously raises awareness of the UN Global Compact as an example of Collective Action at conferences and in its own Collective Action initiatives, as well as the Global Compact principles in the ICCA’s ongoing trainings with the private sector and other actors.\n\nFinally, the Basel Institute has been an active member in the UNGC Local Network Switzerland, for example, through our attendance at the Swiss Global Compact Dialogue 2017, Responsible Business: Let's make Global Goals Local Business, on 2 February 2017. We were also delighted that the Swiss Global Compact Network’s Senior Programme Leader and Network Representative, Mr. Antonio Hautle, attended, alongside other representatives of the United Nations Global Compact Office, our Bi-Annual International Integrity Conference, Anti-Corruption Collective Action: Evidence, Experience, and Impact in October 2016. The Basel Institute remains interested in pursuing further collaboration with the local network as well as the wider membership of UNGC Switzerland. The ICCA also stands ready to provide advice and support to any other local Global Compact Network to support the pursuit of Anti-Corruption Collective Action Initiatives.\n\nWhile the Basel Institute has not sought to identify how many companies or organizations have joined the Global Compact as a result of our awareness-raising or training activities, we have adopted a detailed monitoring & evaluation plan tracking our activities promoting Collective Action as a tool for preventing corruption and the outcome and impact of these activities. For example, in the last two years, the Basel Institute has conducted over 23 trainings on Anti-Corruption Collective Action, which has resulted in the Basel Institute being appointed to a facilitation role of three new industry-specific Anti-Corruption Collective Action Initiatives.\n\nThe Basel Institute remains steadfast in our commitment to contribute to the global fight against corruption and looks forward to continued collaboration with the UN Global Compact and promotion of its Ten Principles in the years to come.\n\nGretta Fenner Managing Director Basel Institute on Governance","2017-10-30",[10],"basel-institute-letter-of-commitment-to-un-global-compact-107",[16,17],"Partnerships","International cooperation",107,[],[16,17],null,[23],"Main page",[],[],[],[],[],[],[31,59,90,112,135,164,186,211,249],{"id":32,"body":33,"status":6,"type":34,"date":35,"slug":36,"title":37,"image":38,"countries":39,"topic":40,"activity":44,"tags":45,"nid":46,"topics":47,"activities":48,"authors":49,"images":50,"websites":51,"area":21,"programme":21,"language":21,"translations":52,"translation_of":21,"user_created":53,"date_created":54,"user_updated":55,"date_updated":56,"content":57,"link":58},10370,"The Wolfsberg Group’s recent updates to its renowned [Anti-Bribery and Corruption Programme Guidance](https:\u002F\u002Fwb-db.basel.institute\u002Fassets\u002F2b55cd0e-b47f-482a-ae28-fe390ab516ef\u002FWolfsberg%20ABC%20Guidance.pdf) for financial institutions has made quite some waves.\n\nIn part, the interest is due to the practical value of the Guidance for financial institutions seeking to comply with anti-corruption legislation and mitigate risks of bribery and corruption throughout their operations. It is also due to the reputation of the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F), a long-standing association of 13 global banks that develops frameworks and guidance to manage financial crime risks, and one of the world’s most successful [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) initiatives.\n\nThe various updates to the Guidance over nearly 20 years track important evolutions in the field of anti-corruption compliance in the financial industry.\n\nFor instance, the 2023 Guidance expands its scope to cover all forms of corruption (not just bribery) in line with current international standards, and extends its guidance on non-monetary or quasi-monetary corruption risks such as gifts and hospitality, donations and employment opportunities.\n\nThe Guidance also emphasises the role of senior leadership in making a strong anti-corruption commitment, moving towards the idea of compliance as a way to embed values and integrity throughout an organisation.\n\n### At the forefront of evolutions in anti-corruption compliance\n\nWe were pleased to contribute to the consultation process through our [Private Sector](https:\u002F\u002Fbaselgovernance.org\u002Fprivate-sector) team. Our former Head of Compliance and now Senior Advisor, Gemma Aiolfi, worked on the original version and has been involved in all subsequent updates since then.\n\nAs Gemma explained in this [interview](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fevolutions-anti-corruption-compliance-hope-future), financial institutions were one of the sectors that pioneered compliance due to their need to mitigate financial crime risks, including the laundering of proceeds of corruption in transactions. Following the realisation that staff or intermediaries working for the bank also posed corruption risks – bribes to win government business or high net-worth clients, for instance – anti-corruption programmes extended to cover these risks too. Gemma Aiolfi said:\n\n> Financial institutions still face that dual challenge compared to non-financial firms: complying with ever-higher regulations and expectations to identity and report suspicious transactions and clients, while also ensuring their own staff and intermediaries act with integrity in their everyday business.\n\n### New Wolfsberg Group website\n\nThe new Anti-Bribery and Corruption Programme Guidance and the [Executive Summary](https:\u002F\u002Fwb-db.basel.institute\u002Fassets\u002F61f0b4b9-7b91-4fda-9c45-fb14c005bcfd\u002FWolfsberg%20ABC%20Guidance%20Executive%20Summary.pdf) are available on the [Wolfsberg Group’s brand new website](https:\u002F\u002Fwolfsberg-group.org\u002F), developed by our IT team together with colleagues in the Wolfsberg Group Secretariat.\n\nThe new user-friendly website is part of efforts to make the Wolfsberg Group’s practical guidance and standards documents, training materials, comment letters and FAQs accessible to as many financial crime compliance practitioners as possible. An increasing number of publications are now available in several languages.\n\nThe development marks another upwards step in the Wolfsberg Group’s journey, following its establishment as a legal entity in 2021. Read more about that journey in this [interview](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fcollective-action-banking-wolfsberg-groups-role-fast-evolving-industry) with the Group’s Executive Secretary Alan Ketley.","News","2023-06-05","wolfsberg-group-on-the-rise-new-anti-corruption-guidance-and-website-2459","Wolfsberg Group on the rise: new anti-corruption guidance and website","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F6b10ab8f-3435-417d-8f8a-0c1dd451c2c9?width=1000&height=650&format=webp&quality=80",[],[41,42,43],"Anti-Money Laundering","Collective Action","Private Sector",[10],[],2459,[41,42,43],[],[],[],[23,42],[],"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","2023-06-05T10:01:27.000Z","dfef11db-1bc6-47e9-a61d-93443995484b","2026-05-08T21:11:08.000Z",[],"\u002Fresources\u002Fnews\u002Fwolfsberg-group-on-the-rise-new-anti-corruption-guidance-and-website-2459",{"id":60,"body":61,"status":6,"type":62,"date":63,"slug":64,"title":65,"image":66,"countries":67,"topic":69,"activity":71,"tags":73,"nid":74,"topics":75,"activities":77,"authors":78,"images":80,"websites":81,"area":21,"programme":21,"language":82,"translations":83,"translation_of":21,"user_created":53,"date_created":85,"user_updated":86,"date_updated":87,"content":88,"link":89},10548,"[Ver versión en español](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fel-desmantelamiento-de-la-ley-de-recuperacion-de-activos-mas-exitosa-de-peru-es-un-paso-atras).\n\nSometimes it seems like high-level support for the fight against corruption and crime is being turned on its head. That includes in Peru, a close partner country of the Basel Institute on Governance for more than a decade.\n\nA flagship achievement in this time has been the adoption of a new non-conviction based forfeiture law in 2018, Extinción de dominio, and its rollout across the country via a judicial subsystem including decentralised and specialised prosecutor’s offices, tribunals and appeals courts.\n\nPeru’s Extinción de dominio law is widely seen as a gamechanger in the fight against corruption and serious organised crime. Last year, the Attorney General applauded the law’s use to [recover USD 94 million](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fperu-celebrates-five-years-its-non-conviction-based-forfeiture-law-usd-94-million-so-far) in illicit assets. It has been applied in both [domestic](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fquispe-callo-case-perus-provincial-prosecutors-recover-corrupt-assets-through-non-conviction) and [international](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fswitzerland-return-usd-85-million-peru-precedent-setting-case-non-conviction-based-forfeiture) cases that have set important precedents and bolstered the message that crime doesn’t pay.\n\nSince the adoption of the United Nations Convention against Corruption (UNCAC) in 2003, non-conviction based forfeiture has become an international standard. The Extinción de dominio law is based on a common [model](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Flatin-americas-model-law-non-conviction-based-forfeiture-illicit-assets-turns-10-what-now) in Latin America that was first introduced by the United Nations Office on Drugs and Crime (UNODC). It aligns with the requirements of the Financial Action Task Force (FATF), whose updated Recommendations 4 and 38 now make [non-conviction based forfeiture legislation mandatory](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Ffatf-seeks-change-landscape-international-asset-recovery-what-means-latin-america). GAFILAT, the Latin American chapter of the FATF, has also [recognised the usefulness](https:\u002F\u002Fwww.facebook.com\u002FCorteSuprema\u002Fposts\u002Fimportante-el-secretario-ejecutivo-de-gafilat-advirtió-que-la-𝗮𝗽𝗿𝗼𝗯𝗮𝗰𝗶𝗼́𝗻-𝗱𝗲-𝗹𝗮-\u002F995126142647976\u002F) of this tool in the Latin American context.\n\nYet now it is on a cliff edge, on the verge of being dismantled or weakened to the extent that it is almost useless.\n\n### Fighting _against_ the rule of law\n\nAt the end of 2024, we [warned](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fel-desmantelamiento-de-la-recuperacion-de-activos-en-el-peru-un-llamado-la-cautela-y-la) of an attack on Extinción de dominio in the form of Bill 3577-2022. This seeks to amend Peru’s Extinción de dominio legislation by, among other things, making its application conditional on a criminal conviction.\n\nIn doing so, the Bill distorts the legal concept of _non-conviction based_ forfeiture. By introducing a criminal conviction as a basic condition for its application, the bill renders the current law (almost) useless. It introduces a fundamental contradiction that lacks logic or legal justification. Similar restrictions have been introduced in [Ecuador](https:\u002F\u002Fecuadorchequea.com\u002Fextincion-de-dominio-sin-necesidad-de-sentencia-plantea-el-ejecutivo\u002F) recently, which have drastically reduced the scope of the law’s application.\n\nUnfortunately, the Bill was [passed by Congress](https:\u002F\u002Fwww.infobae.com\u002Fperu\u002F2025\u002F04\u002F11\u002Fcongreso-aprueba-debilitar-el-proceso-de-extincion-de-dominio-modificaciones-beneficiarian-a-implicados-en-casos-de-corrupcion\u002F) at a second reading on 10 April 2025, despite concerns raised by the Attorney General’s Office, Judiciary and even the President.\n\nAt this point, it is unclear whether the Bill will affect only future cases or whether it will impact the thousands of ongoing cases at the national and international levels. Legal principles and common sense would suggest the former, but the entire process of amending the law has been driven more by political than legal considerations.\n\n### Potential consequences\n\nWhat seems clear is that the defence lawyers of those impacted by the new Bill will soon take action to release assets currently secured by preventive measures.\n\nThis includes high-profile political figures, such as former presidents convicted of corruption in the Lava Jato (Odebrecht) corruption scandal. For example, assets seized by specialised Extinción de dominio prosecutors in relation to the recent conviction of [former President Alejandro Toledo](https:\u002F\u002Fwww.pbs.org\u002Fnewshour\u002Fworld\u002Fperus-former-president-alejandro-toledo-sentenced-to-20-years-in-corruption-case) risk being released.\n\nIt's not only about corruption. Ongoing Extinción de dominio proceedings are also targeting illicit assets linked to other forms of serious and organised crime, like drug trafficking and environmental crimes such as illegal fishing, mining and deforestation. These cases too would fall by the wayside. \n\n### What’s the rationale?\n\nLike any novel law, there have been some inconsistencies and concerns around its application in practice. I explored these concerns in a recent [Working Paper](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-54) and argued for closer alignment with international human rights standards in order to ensure trust and legitimacy, as well as international cooperation.\n\nThese concerns were triggered by the law’s _application in practice_, not by its concept or legal\u002Fsocial legitimacy. In brief, the issues fall into two camps:\n\n*   Technical: Prosecutors and judges have in some cases applied criteria that are not in line with [those developed by human rights tribunals](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-54). Analysis of flawed cases shows that it has been applied to confiscate assets of innocent third parties or of companies due to the fault or negligence of their employees. Specialised training for relevant prosecutors and judges on sensitive and technical issues such as the infringement of fundamental rights would go a long way to eliminating this risk.\n*   Political: One reason for the above issue is the emergence of a “tough” discourse against organised crime. This attracts many supporters and gives rise to populist rhetoric of efficient law enforcement against the “bad guys\". It has led to misperceptions that the Extinción de dominio law is a cudgel to wield against organised crime. The consequences are a small number of violations of international standards that have given opponents a valid argument to attack the essence of the law, even though the errors stem from its implementation.\n\nCriticism is the basis for continuous improvement, so we welcome the raising of these concerns through open discussion. We believe that addressing them should be a priority and will ultimately make the law more effective.\n\nThe Basel Institute has actively supported initiatives to do this, for example through conventions of [judges](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fjudges-convention-shows-why-peru-leader-recovering-proceeds-corruption-through-non-conviction) and [prosecutors](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fperu-celebrates-five-years-its-non-conviction-based-forfeiture-law-usd-94-million-so-far) and through [open dialogues](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fdebating-perus-non-conviction-forfeiture-law-episode-1) with experts, as well as through our participation in GAFILAT and other relevant asset recovery forums.\n\n### Wider implications\n\nIn my view, and the view of many of my counterparts across Peru and the region, this attack on Extinción de dominio will have a disastrous impact on the fight against corruption and other serious crime in Peru. As well as potentially destroying or diminishing ongoing cases, it eliminates the deterrent effect of asset recovery laws and opens the door to impunity. \n\nIt will also likely harm Peru’s international standing. The FATF’s updated Recommendations 4 and 38 not only make the adoption of non-conviction based forfeiture laws mandatory; the FATF has made it clear that such a law must also be operational and effective, and it must respect human rights. The Bill is contrary to the letter and spirit of these Recommendations and deeply contradicts them.\n\nThis legislative setback is expected to affect Peru’s performance in its upcoming fifth-round mutual evaluation by the FATF. The consequences of this could have significant reputational and economic consequences for Peru, [particularly if it is grey listed](https:\u002F\u002Fwww.u4.no\u002Fpublications\u002Fthe-impact-of-grey-listing-by-the-financial-action-task-force-fatf).\n\n### Reasons for hope\n\nMy first hope is that the amendments are not ratified by the President of the Republic, who has the constitutional power to veto them.\n\nA second source of hope is the judicial branch. Resistance can be expected from frontline judges in specialised Extinción de dominio lower courts, given that the legal actions to unfreeze assets mentioned above will most likely be decided in these courts. Ultimately, it will probably be the Supreme Court or the Constitutional Court that will determine if and when the new Bill will be applied and rule on its compatibility with the constitution and international law. \n\nFinally, there is hope of support from the international community, as this issue is relevant not only for Peru. It is also a critical issue for other countries seeing similar attacks on laws that are proven to be effective against high-level corruption and organised crime.\n\n### Learn more\n\n*   [Working Paper 54: Targeting illicit wealth through non-conviction based forfeiture](\u002F\u002F\u002FUsers\u002Foscarsolorzano\u002FDownloads\u002F•%09https:\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-54) by Oscar Solórzano explores Extinción de dominio laws in Latin America and argues for their closer alignment with international human rights standards to foster trust and legitimacy.\n*   View a series of [conversations on YouTube](https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=mIV_R8FOYNw&list=PLYRnhpCcnLP9s4bZW_W390N64JDFJXJnw&index=2) by experts of the Basel Institute’s International Centre for Asset Recovery debating the topic.\n*   See Oscar Solórzano’s [2024 statement in Spanish](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fel-desmantelamiento-de-la-recuperacion-de-activos-en-el-peru-un-llamado-la-cautela-y-la) on this issue.","Blog","2025-05-05","dismantling-perus-most-successful-asset-recovery-law-is-a-step-backwards-for-the-country-and-justice-2802","Dismantling Peru’s most successful asset recovery law is a step backwards for the country – and justice","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F8f3c6b41-962f-4dbe-89c3-9ee02d70c018?width=1000&height=650&format=webp&quality=80",[68],7069,[70],"Asset Recovery",[72],"Insights",[],2802,[76],"Asset Recovery and Enforcement",[72],[79],1082,[],[23],"English",[84],10547,"2025-05-06T10:01:36.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-29T22:22:36.000Z",[],"\u002Fresources\u002Fnews\u002Fdismantling-perus-most-successful-asset-recovery-law-is-a-step-backwards-for-the-country-and-justice-2802",{"id":91,"body":92,"status":6,"type":34,"date":93,"slug":94,"title":95,"image":96,"countries":97,"topic":98,"activity":99,"tags":100,"nid":101,"topics":102,"activities":103,"authors":104,"images":105,"websites":106,"area":21,"programme":21,"language":21,"translations":107,"translation_of":21,"user_created":53,"date_created":108,"user_updated":86,"date_updated":109,"content":110,"link":111},9745,"One of our two submissions to the UN General Assembly Special Session against Corruption 2021 concerns adapting domestic legislation and practice to enable states to fully cooperate in asset recovery matters.\n\n### Our recommendation\n\n> We urge member states to consider for inclusion in the UNGASS political statement a reference to the obligations of UNCAC State Parties to make more efforts to be fully compliant, in letter and in spirit, with UNCAC provisions on international cooperation to recover stolen assets. In particular, member states should through the political statement be urged to implement the following measures:\n> \n> *   Member States shall introduce Non-Conviction Based Confiscation (NCBC) measures in order to provide for judicial proceedings for the confiscation of property that has been acquired through, or that is related to, the commission of an offence established in the Convention.\n> *   Member States shall adopt such measures as may be necessary to permit its competent authorities to provide assistance in obtaining evidence and to provide assistance in freezing or seizing assets in relation to NCBC investigations and proceedings in another State Party, and to give effect to an order of NCBC issued by a court or other competent authority of another State Party.\n> *   Member States shall adopt such measures as may be necessary to allow confiscation of assets subject to the power of disposal of a public official if the wealth of the person has increased disproportionately during her\u002Fhis public function and it has not been demonstrated that the asset in question was acquired legitimately.\n> *   Member States shall interpret the principle of dual criminality in line with Article 43(2) of the Convention.\n> *   Member States shall take such measures as may be necessary to permit its competent authorities to provide information and evidence to another State Party without prior notification to the affected person (if the requesting country demonstrates that such is necessary in light of the nature of the conduct under investigation).\n> *   Member States shall take such measures as may be necessary to recognize damage to another State Party as a basis for returning confiscated assets or monies refunded as the disgorgement of profits.\n\n### Our reasons\n\nCases in which victim countries of large-scale corruption have recovered stolen assets through the mechanisms of Mutual Legal Assistance in Criminal Matters (MLA) are still rare. International cooperation in financial investigations, the securing of assets and the enforcement of confiscation orders can founder when faced with a range of legal, political and practical obstacles. These include:\n\n*   Countries are increasingly adopting NCBC procedures to recover assets which are the proceeds of corrupt activities. Although recognised by international treaties and legislation, acknowledged best practice and affirmed by international courts, there remain barriers in international cooperation with certain countries refusing MLA requests in investigations and for the enforcement of final NCBC orders. This failure to provide a wider measure of assistance in cases which arise from corrupt activities undermines the ability of victim countries to recover stolen assets.\n*   The competent authorities of certain State Parties misinterpret the principle of dual criminality to the disadvantage of the requesting state. Instead of looking at the substance of the criminal conduct under investigation, MLA requests are often refused solely based on the legal terminology applied by the requesting State. The latter does not live up to Art. 43(2) UNCAC on the dual criminality principle. \n*   Despite the advances in international cooperation and the developments in legislation in both criminal and civil forms of confiscation of assets, the recovery of assets remains challenging given the increasing levels of sophistication by which assets are concealed. Increasingly countries are adopting investigative tools or criminal, civil or administrative measures to address unexplained wealth accumulated by public officials or those associated with them. These procedures are to be encouraged where fundamental rights are respected and judicial oversight is integral.\n*   While in many jurisdictions investigative measures aimed at obtaining evidence can be carried out secretly, where the nature of the criminal conduct under investigation justifies it, the MLA legislation of certain countries makes it obligatory to notify the affected person prior to transmitting information and evidence to another country. A prime example is the notification of bank account holders where access to information on their bank account is requested by a foreign authority. This notification to the affected person may compromise the effective investigation and prosecution of corruption offences, may alert criminals of the need to dissipate assets so that they cannot be recovered in the event of a conviction and may endanger the personal safety of law enforcement professional investigating the offending.\n*   There has been a welcome increase in the number of cases where the corrupt activities of private sector entities and corporate executives have been prosecuted or where prosecution has been deferred through a negotiated settlement leading to the payment of financial penalties and conditions agreed as to future conduct. The financial penalties, in part, seek to disgorge the profits gained by corporations and individuals as a result of their corrupt activities. The proceeds of these often multimillion dollar fines are usually retained by the investigating \u002F prosecuting jurisdiction with insufficient regard to the harm caused in the jurisdiction where the corrupt activities took place.\n\n### More information\n\n*   View our [contribution on asset recovery to the Consultation Process](https:\u002F\u002Fungass2021.unodc.org\u002Fuploads\u002Fungass2021\u002Fdocuments\u002Fsession1\u002Fcontributions\u002FUNGASS_submission_Basel_Institute_-_Submission_2_Asset_recovery.pdf) in Preparation of the UN General Assembly Special Session against Corruption 2021 (submission 2 in the document). The text contains extra references to support our points.\n*   See [opening remarks and a presentation of key concepts of NCBC procedures and the UNCAC's \"favourability\" principle](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Ffavourability-principle-uncacs-plug-adapter-enforcement-non-conviction-based-confiscation) at our side event at the Conference of the States Parties to the UNCAC in December 2019.\n*   View background [briefing notes on international cooperation in asset recovery and NCBC procedures](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Finternational-cooperation-asset-recovery-and-non-conviction-based-confiscation-briefing), prepared for the above side event.\n*   Read an [interview with Peruvian prosecutor Dr Hamilton Castro](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Flandmark-asset-recovery-case-puts-peruvian-non-conviction-based-confiscation-legislation-test), describing a high-profile asset recovery case that is putting the country's recent NCBC legislation to the test (also in [Spanish](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fun-caso-historico-de-recuperacion-de-activos-pone-prueba-la-legislacion-peruana-de-extincion)).\n*   Visit the official website of the [UNGASS against Corruption 2021](https:\u002F\u002Fungass2021.unodc.org\u002Fungass2021\u002Findex.html).","2020-04-24","recommendations-to-the-ungass-on-enabling-full-cooperation-in-asset-recovery-matters-1707","Recommendations to the UNGASS on enabling full cooperation in asset recovery matters","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F0013b3c9-b56f-4feb-9723-884c8cd659bf?width=1000&height=650&format=webp&quality=80",[],[70],[17],[],1707,[76],[17],[],[],[23],[],"2022-05-26T22:55:05.000Z","2026-05-29T22:21:53.000Z",[],"\u002Fresources\u002Fnews\u002Frecommendations-to-the-ungass-on-enabling-full-cooperation-in-asset-recovery-matters-1707",{"id":113,"body":114,"status":6,"type":62,"date":115,"slug":116,"title":117,"image":118,"countries":119,"topic":120,"activity":121,"tags":122,"nid":123,"topics":124,"activities":125,"authors":126,"images":128,"websites":129,"area":21,"programme":21,"language":21,"translations":130,"translation_of":21,"user_created":53,"date_created":131,"user_updated":86,"date_updated":132,"content":133,"link":134},9789,"Recovering criminals’ ill-gotten assets, i.e. confiscating property, cars, yachts, cash and other funds gained through corruption or other acquisitive crimes, is a big topic in law enforcement. Among other benefits, asset recovery acts as a deterrent against crime and makes a clear public statement that illicit wealth will be targeted and returned to the public treasury. There is much discussion and numerous publications about how we recover illegally gained wealth through a legal process in the court system. How to find the assets in the first place gets less attention.  Unlike the recovery process, the tracing of assets has no set structure. Providing an investigator uses tactics and techniques that are legal in their jurisdiction, they are free to use as much flair and imagination as they like.  In our desire to be innovative and modern, however, we mustn’t overlook some fundamental investigative skills that will help us trace even the most cleverly hidden assets. This quick guide looks at a few of these and explains why they’re important to keep in mind.\n\n### Intelligence: the key to unlock information\n\nBasic information to trace assets often comes from so-called “closed sources” such as company records, land registries, vehicle licensing departments and credit reference agencies. They are “closed” because databases containing this type of information, where they exist, are restricted by data protection laws.  To gain access, we need specific intelligence that suggests there is data relating to our subject in a particular database. Requesting access to data without specific intelligence is commonly referred to as a fishing expedition. For example, if we don’t hold any information that suggests our suspect has travelled overseas or crossed any national border, then we are not justified in accessing information held by the immigration or border control services.  So, asset tracing is not only about finding assets, but finding information that can unlock these closed sources and lead us to other assets that may be more carefully hidden.  And in jurisdictions where these closed sources don’t exist, we still need basic information to trace the asset itself.\n\n### Does digital data hold the key?\n\nIt is now common for investigators to download mobile phone data and copy (“ghost”) computer hard drives. Many also trawl through open-source websites and social media platforms for photographs and hints to gain a better understanding of the suspect’s lifestyle and assets. This is all well and good. It’s amazing how often even clever criminals give themselves away by publicly posting photos of themselves on Facebook or Instagram. But a persistent investigator will not stop at the digital search.\n\n### Searching: going that step further\n\nYou would be excused for thinking that the purpose of undertaking searches of a suspect’s property is to locate assets like jewellery, cars, bank account details, etc, and where necessary seize or restrain the property in order to minimise the risk of dissipation. But an investigator should also apply their best detective skills and look at the search as a gateway to obtain information that leads us to the less obvious acquisitions. What kind of information? Well, for example, an individual holding Bitcoins will need to remember a 64-digit passcode called a “private key” or, if they are using a more sophisticated wallet, the 12 or 24 words used to generate the wallet. Any sensible person will write down these codes and keep them in a secure place, like at home, work or on a mobile phone.  Car keys are often left behind in searches unless they unlock a brand-new Lamborghini parked outside the door. True, the keys to a 20-year old rust bucket may not be of interest as an asset, but what is inside? Perhaps cash, banking documents and even purchase receipts that not only provide us with knowledge of the suspect’s lifestyle and expenditure, but also place them in a particular place at a particular time.  Other keys may reveal the existence of further properties or storage that should also be located and searched, for the same reason.\n\n### Revisiting witnesses and suspects\n\nMany jurisdictions recover assets through a civil hearing that follows a criminal conviction. The time between the two hearings can be several months. This provides a window of opportunity to revisit witnesses without risking any suggestion of interference with the criminal prosecution case. Although the first purpose of witnesses is to secure evidence of the criminal offence, they may also hold valuable knowledge of a suspect’s lifestyle and assets. With little or no understanding of the asset recovery process, they may not think this knowledge is relevant. A good financial investigator will ask them the right questions to elicit the information. It’s not just witnesses that can provide useful information during this window of opportunity, but sometimes the convicted individuals themselves. Many want to make a clean start and will disclose the existence of assets out of fear that the case may be revisited if undisclosed assets are identified later. A visit or even a letter to convicted persons can easily yield dividends.\n\n### Communicating widely\n\nOne final forgotten skill is that of communication. Outside the confines of the legal system, there is no restriction on any individual to speak to any person at any time.  Investigators need to get out from behind their desks and make contacts outside their sphere of operations, be it socially at the gym, in a club or in the workplace. Making themselves available to any potential whistle-blowers, informants or witnesses, or even making steps to identify such individuals, will often lead to them striking lucky.  It’s worth remembering that somebody knows somebody, who knows somebody, that knows something… and that something could be the key to successfully tracing a criminal’s hidden wealth. \n\n### Find out more\n\n*   Learn about the Basel Institute’s [International Centre for Recovery](\u002Fnode\u002F25) (ICAR), which provides training, technical assistance and legal\u002Fpolicy advice on financial investigation and asset recovery.\n*   See related quick guides to [intelligence](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fmanuel-medinas-quick-guide-intelligence), [international cooperation in asset recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fshane-nainappans-quick-guide-international-cooperation-asset-recovery), [illicit enrichment](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fandrew-dornbierers-quick-guide-illicit-enrichment) and [effective training on financial investigations](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fphyllis-atkinsons-quick-guide-effective-training-financial-investigations).\n*   For more on the wider benefits of asset recovery, read the Basel Institute [Working Paper 29: Recovering assets in support of the SDGs – from soft to hard assets for development](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-29-recovering-assets-support-sdgs-soft-hard-assets-development).\n*   [Download a PDF of this quick guide.](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-08\u002Fqg14_tracing_assets.pdf)","2019-11-27","phill-joness-quick-guide-to-fundamental-skills-in-tracing-assets-1029","Phill Jones’s quick guide to fundamental skills in tracing assets","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F557d8f9a-9a9a-4592-9e1d-cf9490b7216e?width=1000&height=650&format=webp&quality=80",[],[70],[72],[],1029,[76],[72],[127],872,[],[23],[],"2022-05-26T22:55:42.000Z","2026-05-29T22:21:55.000Z",[],"\u002Fresources\u002Fnews\u002Fphill-joness-quick-guide-to-fundamental-skills-in-tracing-assets-1029",{"id":136,"body":137,"status":6,"type":62,"date":138,"slug":139,"title":140,"image":141,"countries":142,"topic":143,"activity":144,"tags":146,"nid":151,"topics":152,"activities":153,"authors":154,"images":156,"websites":157,"area":21,"programme":21,"language":21,"translations":158,"translation_of":21,"user_created":53,"date_created":159,"user_updated":160,"date_updated":161,"content":162,"link":163},9817,"During 2018 and 2019, the world has faced serious money laundering scandals involving reputable institutions. Surprisingly, abuses of financial systems were uncovered in countries that have low risk scores in the [Basel AML Index](http:\u002F\u002Findex.baselgovernance.org\u002F), like Estonia and Sweden.\n\nThese countries have correspondingly low risk scores in other indices that the Basel Institute uses to analyse the quality of anti-money laundering and counter financing of terrorism (AML\u002FCFT) frameworks and quantify corruption, financial transparency and standards, public transparency and accountability, and legal and political risks.\n\n### Are ML\u002FTF evaluation systems flawed?\n\nDoes this mean that systems for evaluating money laundering and terrorist financing (ML\u002FTF) risks – including the Basel AML Index – are fundamentally flawed or biased?\n\nNo. It does mean, however, that when using a risk assessment tool such as the Basel AML Index Expert Edition it is important to understand the [methodology](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index\u002Fmethodology) behind the results, what it can and cannot [measure](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index\u002Fwhat-does-basel-aml-index-measure), and which [indicators](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-aml-index\u002Fmethodology\u002Findicators) it relies upon.\n\nThe Basel AML Index is a composite index based on 15 well-established indicators and is not anyone’s personal evaluation. If some overall scores and rankings look implausible – for example, because major money laundering scandals have occurred in supposedly low-risk countries – the key is to analyse both the indicators behind the scores and the reasons why these cases of money laundering occurred.\n\nTools are more powerful when users understand their limitations and not only their uses.\n\n### Red flags in addition to country risk\n\nTools are also more powerful when used in combination with other evidence-based tools and procedures.\n\nAn analysis of recent high-profile money laundering cases shows it is important for financial institutions and companies to check for the following red flags:\n\n*   Politically exposed persons (PEPs). Cases involving illicit money from Russia and former Soviet countries were largely connected to PEPs or powerful businesspeople with vested interests. According to [media](https:\u002F\u002Feuobserver.com\u002Fjustice\u002F144524) reports, for example, EUR 122 million were linked to Russian businessman Iskander Makhmudov. Viktor Yanukovych, the former Ukrainian President, funnelled a suspected bribe of EUR 3.7 million via Swedbank in 2011.\n*   Non-resident legal persons. It is [stated](https:\u002F\u002Fwww.moneylaunderingnews.com\u002F2018\u002F11\u002Fdanske-bank-money-laundering-scandal-the-tip-of-the-icebergs\u002F) that Russian and other non-Baltic customers accounted for a notably high percentage of Danske Bank’s Estonia business, through which over USD 200 billion are estimated to have been laundered between 2007 and 2015.\n*   Beneficial ownership and offshore jurisdictions. Shell companies are used to conceal the true nature of illicit transactions and the identities of those responsible. In the so-called [Russian Laundromat](https:\u002F\u002Fwww.occrp.org\u002Fen\u002Flaundromat\u002Fthe-russian-laundromat-exposed\u002F) scandal, to take one example of many, money entered the scheme via a set of shell companies in Russia that exist only on paper and whose ownership cannot be traced. \n*   Illicit trading. High-risk large transactions related to mis-invoicing and fictitious trade deals are a serious issue. Illicit trading schemes like fraudulent letters of credit, fake invoices, vessels re-routing to pick up illegal goods, and trading in non-existing goods were used frequently in the Russian Laundromat activity. These methods helped to mask movements of illicit money.\n*   Geographical proximity to high-risk countries. As financial crimes are global in nature and the issue of [exporting corruption](https:\u002F\u002Fwww.transparency.org\u002Fwhatwedo\u002Fpublication\u002Fexporting_corruption_2018) is now widely recognised, countries which have borders with high-risk neighbours are vulnerable to increased levels of risk. In the latest Laundromat schemes, Baltic countries served as a gateway for illicit funds from former Soviet countries to enter the Western banking system.\n\n### Measuring money laundering risks\n\nThe 8th edition of the [Basel AML Index](\u002Fnode\u002F229), an independent annual ranking that assesses the risk of money laundering and terrorist financing (ML\u002FTF) around the world, will be released on 19 August 2019.","2019-08-16","what-can-we-learn-from-recent-money-laundering-cases-992","What can we learn from recent money laundering cases?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F515a9ba9-91a8-4417-a6e9-333901cd19d3?width=1000&height=650&format=webp&quality=80",[],[41],[145,72],"Basel AML Index",[147],{"tags_id":148},{"id":149,"name":150},818,"Anti-money laundering",992,[41],[145,72],[155],1261,[],[23,145],[],"2022-05-26T22:56:06.000Z","b0662e2a-864d-4888-a1b7-4342b7570b30","2025-12-08T23:00:53.000Z",[],"\u002Fresources\u002Fnews\u002Fwhat-can-we-learn-from-recent-money-laundering-cases-992",{"id":165,"body":166,"status":6,"type":34,"date":167,"slug":168,"title":169,"image":170,"countries":171,"topic":173,"activity":174,"tags":175,"nid":176,"topics":177,"activities":178,"authors":179,"images":180,"websites":181,"area":21,"programme":21,"language":21,"translations":182,"translation_of":21,"user_created":53,"date_created":183,"user_updated":160,"date_updated":8,"content":184,"link":185},10115,"Experts from the Basel Institute’s International Centre for Collective Action (ICCA) were in Kigali, Rwanda on 25-27 January to support the country’s Office of the Ombudsman in developing Collective Action strategies for public-private sector cooperation to tackle corruption.\n\nTo kick-start this process, a workshop on the topic was held on 26 January in Kigali, preceded by preparatory meetings with the Office of the Ombudsman and the Private Sector Federation, the latter being an umbrella organisation representing the business Chambers and Associations in Rwanda. The workshop brought together roughly 80 participants, mostly from a cross-section of the Rwandan private sector, as well as members of the public sector, and civil society. The event was opened by the Ombudsman, Ms Aloysie Cyanzayire and the meeting was facilitated by the Permanent Secretary of the Ombudsman’s office Mr Xavier Mbarubukeye and Gemma Aiolfi of the ICCA.\n\nIn the presentations by Will Nero and Gemma Aiolfi, a variety of examples of anti-corruption Collective Action as a tool to promote trust, and to create a sustained dialogue with the aim of identifying joint activities for the private and public sectors, were described as an introduction to the workshop participants as to what might be possible for them to achieve through Collective Action.\n\nIn the second half of the workshop, small group sessions provided opportunities for in-depth exchanges between business and government with members of the Ombudsman office acting as facilitators to the discussions. Both private sector representatives and the civil servants raised examples of corruption challenges that they faced in their daily operations, as well as pointing to good practices among both sectors to mitigate corruption risks, and recommendations for further continuation of the dialogue and what more the private and public sector could do together to prevent corruption.\n\nThe ICCA and the Office of the Ombudsman will consolidate the ideas that emerged from the discussions, presenting main resolutions and suggested activities for implementation, with follow up through the office of the Ombudsman and the ICCA.\n\nThe visit to Kigali by Gemma Aiolfi and Will Nero happened to coincide with Transparency International Rwanda’s press conference on 27 January 2016 to announce the results of the 2015 edition of the Corruption Perceptions Index. The ICCA provided comments to the press corps on hand, supporting the speakers from TI and the Deputy Ombudsman Mr Clement Musangabatware, who noted the progress made by Rwanda to improve its ranking in the annual CPI, while also stating that work is still much needed to improve collaboration between the public and private sector to tackle all forms of corruption, as well as greater interaction between Rwanda and regional states on anti-corruption best practice.","2016-01-29","promoting-public-private-cooperation-to-counter-corruption-in-rwanda-with-the-office-of-the-ombudsman-294","Promoting public-private cooperation to counter corruption in Rwanda with the Office of the Ombudsman","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F6db74b77-ca1b-4ebe-9001-d9d30f11be4b?width=1000&height=650&format=webp&quality=80",[172],7670,[42,43],[10],[],294,[42,43],[],[],[],[23,42],[],"2022-05-26T22:59:00.000Z",[],"\u002Fresources\u002Fnews\u002Fpromoting-public-private-cooperation-to-counter-corruption-in-rwanda-with-the-office-of-the-ombudsman-294",{"id":187,"body":188,"status":6,"type":34,"date":189,"slug":190,"title":191,"image":192,"countries":193,"topic":195,"activity":197,"tags":199,"nid":200,"topics":201,"activities":202,"authors":203,"images":204,"websites":205,"area":21,"programme":21,"language":21,"translations":206,"translation_of":21,"user_created":53,"date_created":207,"user_updated":86,"date_updated":208,"content":209,"link":210},10448,"USD 94 million dollars is the amount of money recovered so far by the Peruvian State through its _Extinción de Dominio_ law, according to Attorney General Juan Carlos Villena Campana.\n\nIntroduced in 2018, the non-conviction based forfeiture law has been rolled out across the country via a subsystem of specialised prosecutor’s offices, tribunals and courts. The development and implementation of the law was supported by the Basel Institute and its International Centre for Asset Recovery (ICAR), which has worked with the country’s criminal justice authorities since 2013.\n\nThe Attorney General lauded the law at a two-day National Meeting of Specialised Prosecutors in Extinción de Dominio on 5-6 June 2024. He also praised the specialised prosecutors who have been using it successfully to recover assets linked to financial and organised crime.\n\nThe event was organised with the support of the Embassy of Switzerland in Peru and the [Programa GFP Subnacional](https:\u002F\u002Fwww.gfpsubnacional.pe\u002F), a long-running programme to strengthen public finance management that is funded by the Swiss SECO Cooperation in Peru and implemented by our local team.\n\nThe following is an adapted translation of the [Peruvian Government’s press release](http:\u002F\u002Fwww.gob.pe\u002Finstitucion\u002Fmpfn\u002Fnoticias\u002F967500-fiscal-de-la-nacion-estado-peruano-recupero-94-millones-de-dolares-desde-que-iniciaron-sus-funciones-las-fiscalias-extincion-de-dominio).\n\n### Asset recovery weakens criminal networks and is vital for development\n\nThe Attorney General, Juan Carlos Villena Campana, inaugurated the First National Meeting of the Specialised Prosecutors in Extinción de Dominio that is being held for two days at the headquarters of the Public Prosecutor’s Office, with the support of the Embassy of Switzerland in Peru, Programa GFP Subnacional of the Swiss Cooperation Programme - SECO and Basel Institute on Governance.\n\nIn his speech, Villena Campana highlighted the work carried out by the specialised prosecutors of the country’s subsystem for Exintinción de Dominio. Praising their dedication and effort, he explained how they have managed to recover more than USD 94 million dollars in tangible and intangible assets in favour of the State. The assets had been illegally obtained by criminal organisations.\n\nHe argued that these specialised prosecutors' offices weaken the capacity of criminal organisations, saying:\n\n> The legal mechanism of Extinción de Dominio, through these prosecutors’ offices, has become a powerful tool for combating the assets of organised crime. The ability to recover these resources is fundamental for promoting development and progress in Peru.\n\n### Scaling up and creating sustainable systems\n\nVillena Campana considered that, taking into account that this is an emerging subsystem, it is necessary to standardise, systematise and document the procedures of these prosecutors' offices in order to facilitate and improve the work of both the prosecutorial and administrative staff.\n\nAll of this is aimed at strengthening society's confidence in the Attorney General’s Office and, in general, in the justice system.\n\nHe also highlighted other actions, such as the implementation and adaptation of the prosecutorial management system for all specialised prosecutor’s offices. This will systematise the procedural aspects at the national level.\n\nIn addition, he mentioned the development of a tech-driven system of expert reports and a draft manual for parallel criminal and financial investigations, the latter led by the specialised prosecutors.\n\n### Switzerland: long-running support leads to success\n\nThe Swiss Ambassador to Peru, Paul Garnier, said that the ties of collaboration between Peru and Switzerland have a long history. In the area of asset recovery, it is clear that proactive and determined cooperation has borne fruit. He recalled:\n\n> It is with satisfaction that we recall the first recovery processes at the beginning of the century that allowed Peru to recover significant sums of money from Switzerland and other States.\n\nAmbassador Garnier highlighted the joint work of the Swiss Economic Cooperation – SECO and the Basel Institute on Governance as strategic allies. He mentioned the Basel Institute’s contribution, based on its global experience, in preventing and combating corruption and in strengthening governance systems.\n\nThe opening ceremony was also attended by Elma Sonia Vergara Cabrera, National Coordinator and Senior Prosecutor of the Specialised Prosecutor's Offices for Extinción de Dominio; prosecutorial and administrative staff of the Public Prosecutor's Office; and Oscar Solórzano, Head of Latin America at the Basel Institute on Governance.\n\n### Learn more\n\n*   Watch a short [video](https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=LiLe0snLIXI) by Peru's Public Prosecutor's Office about the law and subsystem.\n*   See extracts from [speeches](https:\u002F\u002Fwww.linkedin.com\u002Ffeed\u002Fupdate\u002Furn:li:activity:7204830470226784256) by Swiss Ambassador Paul Garnier and Prosecutor Vergara Cabrera.\n*   Read an [interview](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fquispe-callo-case-perus-provincial-prosecutors-recover-corrupt-assets-through-non-conviction) with a Specialised Prosecutor from Cusco about the use of the non-conviction based forfeiture law to recover assets arising from corruption.\n*   Find out about the [Subnational Public Finance Management Strengthening Programme](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-finance-peru), which leads the rollout of the specialised subsystem and supported the organisation of the two-day event.\n*   Learn about the work of the Basel Institute’s [International Centre for Asset Recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery), which receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.","2024-06-06","peru-celebrates-five-years-of-its-non-conviction-based-forfeiture-law-usd-94-million-so-far-2637","Peru celebrates five years of its non-conviction based forfeiture law – USD 94 million so far","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F7d34fdd9-0610-40fa-872b-65de07a1fefc?width=1000&height=650&format=webp&quality=80",[194],7120,[70,196],"Public Finance Management",[198,16,17],"Events",[],2637,[76,196],[198,16,17],[],[],[23],[],"2024-06-06T22:01:30.000Z","2026-05-29T22:22:29.000Z",[],"\u002Fresources\u002Fnews\u002Fperu-celebrates-five-years-of-its-non-conviction-based-forfeiture-law-usd-94-million-so-far-2637",{"id":212,"body":213,"status":6,"type":62,"date":214,"slug":215,"title":216,"image":217,"countries":218,"topic":221,"activity":224,"tags":225,"nid":238,"topics":239,"activities":240,"authors":241,"images":243,"websites":21,"area":21,"programme":21,"language":82,"translations":244,"translation_of":21,"user_created":53,"date_created":245,"user_updated":160,"date_updated":246,"content":247,"link":248},10615,"When Bulgaria joined the European Union in 2007, many believed it would lead to more secure, transparent and less corrupt borders. New regulations, infrastructure modernisation and digitalised customs procedures all followed. European standards and money arrived together.\n\nYet corruption did not disappear at the Kapitan Andreevo border checkpoint, the main land crossing between Bulgaria and Türkiye and one of the busiest gateways between Europe and Asia. Instead, it evolved.\n\nThis is the central finding of a recent [article](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fevolution-corruption-and-crimes-kapitan-andreevo-border-checkpoint-impact-eu-accession) by the Prevention, Research and Innovation team of the Basel Institute on Governance – Dr Jacopo Costa, Dr Claudia Baez Camargo, Noémi Jäger and Dr Saba Kassa – published in the _Journal of Illicit Trade, Financial Crime, and Compliance_.\n\nThe article examines how criminal networks, smugglers, businesses and corrupt officials adapted to Bulgaria’s EU integration. It illustrates how corruption behaves like an adaptive ecosystem: when regulations and border control technologies change, corruption changes with them.\n\nA border built for opportunity – legal and illegal\n\nBorder spaces concentrate discretionary power in the hands of customs officers, border guards, inspectors and regulators, while bringing together also traders, transport companies, migrants, smugglers, criminal groups and political actors.\n\nKapitan Andreevo is a particularly instructive case due to its strategic location, with thousands of trucks, travellers and goods passing through the border checkpoint daily.\n\nBefore Bulgaria’s EU accession, corruption at the checkpoint was already deeply embedded. The 1990s brought economic crisis, shortages of consumer goods, weak state capacity and rapidly expanding informal markets. Smuggling became a profitable survival strategy.\n\nBorder officials could be bribed to overlook undeclared goods, counterfeit products and tax evasion. Duty-free shops in the \"no man's land\" between Bulgaria and Türkiye became hubs for smuggling cigarettes, alcohol and petroleum products.\n\nCorruption operated at multiple levels:\n\n*   everyday exchanges between traders, drivers and officials, often based on long-standing personal relationships, at the lower level\n*   connections between politicians, senior civil servants, business elites and organised crime at the higher level.\n\nSmuggling routes required political protection. Profits flowed upward through patronage systems.\n\nEU accession changed the rules of the game\n\nBulgaria’s EU accession radically transformed the legal and institutional environment. The country had to align its customs regulations, VAT rules, excise tax systems, phytosanitary standards and border procedures with EU standards – a gradual process requiring significant investment. The reforms affected almost every aspect of border governance.\n\nCustoms procedures became increasingly digitalised. New systems such as the VAT Information Exchange System (VIES) and the Excise Movement and Control System (EMCS) improved cross-border monitoring.\n\nPhytosanitary and veterinary inspections became stricter. Migration controls tightened through alignment with Schengen rules and access to systems like the Schengen Information System (SIS) and international databases of stolen documents and vehicles.\n\nMeanwhile, new border control technologies – X-ray machines, scanners, thermal cameras and risk-analysis tools – expanded the state’s capacity to detect illicit activity.\n\nFrom a policy perspective, this appeared to be a modernisation success story. But criminal systems rarely remain static when the environment changes.\n\nCorruption did not decline – it adapted\n\nThe most striking finding is that stronger controls often increase the strategic value of corruption.\n\nAfter EU accession, crossing the border illegally became more difficult, risky and expensive. Corruption became necessary not only to speed up procedures but to bypass sophisticated control and regulatory systems.\n\nIn other words, modernisation transformed the function of corruption: Criminal actors began targeting specialised procedures, such as food safety inspections, VAT systems, automated license plate recognition, laboratory testing and digital customs controls.\n\nVAT fraud and the manipulation of digital systems\n\nVAT fraud illustrates this adaptation clearly. Within the EU, exports are often subject to a VAT rate of 0 (zero) percent, which means companies can reclaim any VAT they have already paid domestically. Criminal actors exploited this through \"carousel fraud\" schemes involving fictitious transactions chains.\n\nAt Kapitan Andreevo border checkpoint, for example, corruption allegedly enabled traders to manipulate customs procedures. One method involved corrupt officials manually entering fake truck registrations into customs systems to simulate border crossings, enabling fraudulent VAT refunds for exports that never occurred.\n\nEven more revealing was the manipulation of automated license plate recognition: corrupt actors reportedly disabled automated recognition and manually entered altered plates using Cyrillic characters resembling Latin letters, allowing smugglers to bypass alerts and inspections.\n\nThis illustrates a pattern seen in many modern corruption systems: digitalisation does not automatically eliminate corruption. Instead, corruption turns towards the technological systems themselves.\n\nFood safety, privatisation and rent-seeking\n\nEU food safety and phytosanitary regulations created new bottlenecks and forms of discretionary authority. The research describes two recurring manipulation strategies:\n\n*   selective sampling during inspections, where officials took samples only from \"clean\" sections of shipments; and\n*   falsification of laboratory tests to certify unsafe products as compliant.\n\nThese risks increased after some border functions were outsourced to private companies. At Kapitan Andreevo, food testing, parking operations and vehicle disinfection were privatised. This reform, intended to increase efficiency, allegedly created new opportunities for rent extraction.\n\nThe controversy surrounding Eurolab 2011, which reportedly obtained monopolistic control over food safety testing under questionable legal arrangements became emblematic of these tensions.\n\nThe broader implication: privatisation of public functions does not necessarily reduce corruption risks. It can shift them into hybrid public-private arrangements where accountability is weaker and oversight is more fragmented.\n\nThe rise of “routinised” corruption\n\nThe study highlights the increased organisation of corruption itself. Today, no single official can independently guarantee a smuggling route. Procedures involve multiple agencies, overlapping inspections and layered oversight.\n\nAs a result, corruption evolved towards collective coordination. Customs officers, border guards, supervisors, intermediaries and sometimes political actors participate in networks where bribes are pooled and redistributed.\n\nThese schemes resemble coordinated organisational systems with revenue-sharing mechanisms, internal hierarchies and protection structures rather than isolated rogue actors.\n\nThis reflects an important conceptual change: border corruption can function as an embedded institutional ecosystem sustained through cooperation, mutual dependence and political protection.\n\nDrug trafficking: when corruption becomes too risky\n\nInterestingly, corruption is not always the preferred strategy. In drug trafficking, for example, the risks are dramatically higher. Border officials caught facilitating drug trafficking could face severe criminal penalties, including organised crime charges and lengthy prison sentences.\n\nAs a result, traffickers increasingly invest in sophisticated concealment methods. One example is the \"twin trucks\" strategy: several nearly identical trucks carrying similar cargo cross the border simultaneously during heavy traffic, with only one of them containing drugs. Since inspection capacity is limited, the probability is high that the \"clean\" trucks are checked while the drug shipment passes undetected.\n\nThis shows that corruption and criminality do not always go hand in hand. Sometimes, stronger anti-corruption measures push criminals towards deception and concealment rather than bribery.\n\nThe bigger lesson: criminal systems are adaptive\n\nThe case study of the Kapitan Andreevo border crossing is not just about Bulgaria. Policymakers often assume that more technology, controls and regulation will automatically reduce corruption and illicit trade.\n\nBut criminal systems and corruption adapt. Informal networks reorganise around the vulnerabilities created by reforms. Every regulatory innovation creates new incentives, bottlenecks and opportunities for exploitation.\n\nThis does not mean reforms are useless. Many EU measures have clearly strengthened border management. However, reforms must be designed with an understanding of adaptive behaviour. Otherwise, states risk producing unintended consequences: stronger incentives for bribery, use of alternative trafficking routes, technological manipulation, new forms of collusion or opaque privatisation structures.\n\nI and my co-authors argue for a more integrated approach that combines anti-corruption and anti-crime strategies. We also emphasise the importance of anticipatory governance and foresight-oriented policymaking that try to predict how illicit actors will respond to institutional changes before reforms are implemented.\n\nThis may be the most important lesson from Kapitan Andreevo. Borders are not static lines defended by static institutions against static threats. They are evolving ecosystems where states, markets, technologies and criminal actors constantly adapt to one another.\n\nLearn more\n\n*   Access the full article, “[The Evolution of Corruption and Crimes at Kapitan Andreevo Border Checkpoint: The Impact of EU Accession](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fevolution-corruption-and-crimes-kapitan-andreevo-border-checkpoint-impact-eu-accession)”.\n*   Read our [Quick Guide 38 to border corruption](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fqg38) for a short introduction.\n*   Read our Working Paper 58, “Corruption as a facilitator of drug trafficking in the port of Rotterdam” for a related analysis.","2026-05-26","how-stronger-borders-can-create-smarter-corruption-lessons-from-one-of-europe039s-most-strategic-border-crossings-2972","How stronger borders can create smarter corruption: lessons from one of Europe's most strategic border crossings","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F693afaed-084c-4590-aafd-c2d51b28adf7?width=1000&height=650&format=webp&quality=80",[219,220],7814,7815,[222,223],"Prevention"," Research and Innovation",[72],[226,230,234],{"tags_id":227},{"id":228,"name":229},859,"Corruption risks",{"tags_id":231},{"id":232,"name":233},982,"Anti-corruption",{"tags_id":235},{"id":236,"name":237},1374,"Law enforcement",2972,[222,223],[72],[242],1373,[],[],"2026-06-04T21:13:44.000Z","2026-06-04T21:14:56.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-stronger-borders-can-create-smarter-corruption-lessons-from-one-of-europe039s-most-strategic-border-crossings-2972",{"id":250,"body":251,"status":6,"type":34,"date":252,"slug":253,"title":254,"image":255,"countries":256,"topic":257,"activity":258,"tags":260,"nid":261,"topics":262,"activities":263,"authors":264,"images":266,"websites":267,"area":21,"programme":21,"language":21,"translations":268,"translation_of":21,"user_created":53,"date_created":269,"user_updated":160,"date_updated":270,"content":271,"link":272},10445,"Published today, the 2023 Annual Report of the Basel Institute on Governance features seven stories from our work around the world to promote good governance and counter corruption.\n\nThe stories showcase different ways in which we collaborate with partners globally to advance knowledge, practice and policy on anti-corruption, asset recovery and business integrity. They illustrate not just _what we do,_ but _how we work_ to achieve real and lasting progress towards a more peaceful, just and sustainable world. \n\nRead the foreword by Peter Maurer below and [download the annual report](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-05\u002Fbasel_institute_annual_report_2023_spreads.pdf).\n\n> The final preparations of this annual report were overshadowed by the tragic news that Gretta Fenner, Managing Director of the Basel Institute on Governance for nearly two decades, had passed away in a car accident in Kenya on 6 April 2024.\n> \n> While we continue to be deeply saddened by the loss, we also know that Gretta was immensely proud of the Basel Institute’s achievements in 2023, as well as of the progress made over the Institute’s 20 years of existence – the latter, a large part of her legacy.\n> \n> And there are indeed many reasons to be proud and optimistic. While corruption scandals hit the headlines, the more important stories of anti-corruption progress tend to advance quietly over years. Many of the standout achievements in this annual report are not just from 2023.\n> \n> Second, anti-corruption tools yield benefits that go far beyond the immediate goal of reducing corruption risks. For example, when we provide advice to companies on compliance and multi-stakeholder Collective Action (page 18), the goal is not merely to reduce the risk of compliance-related violations but to foster resilient, ethical companies, fair competition and thriving industries.\n> \n> A third reason for optimism is that corruption is finally appearing on the agenda where it really matters – notably in the environmental sector. Our Green Corruption team has been working hard to embed anticorruption and asset recovery tools in the environmental sphere, and to build bridges between the anti-corruption and conservation communities (pages 14 and 17).\n> \n> At the Basel Institute, connections like these feed into our evolving understanding of corruption and of the changing tactics of power brokers on the political and geopolitical stage. From a narrowly defined legal concept, corruption has become a phenomenon that connects the biggest issues of our time. \n> \n> What global challenge is not caused or worsened by misuses of power and influence, with the aim of benefitting the few over the many?\n> \n> As Gretta said at the Munich Security Conference shortly before her passing, the old idea of corruption as “just” bribery causes us to overlook patterns of behaviour that have long-term, systemic impacts on both national and global stability.\n> \n> So, while we are a centre of technical competence, and advise governments worldwide on their laws and policies on corruption and asset recovery, the solutions we bring are never isolated from their political and social context.\n> \n> And we use behavioural science to better understand what really causes corrupt behaviour, and what might work to shift social norms towards compliance with laws, codes of ethics and other elements of the formal anti-corruption and anti-money laundering architecture.\n> \n> That is also why a big focus of our work is on engaging and connecting with others in the anti-corruption, asset recovery and business integrity fields, and beyond. Even if, or rather especially if, they have competing priorities. Only through negotiation and dialogue can one forge the type of common understanding and consensus that form the basis of effective and concerted action against corruption.\n> \n> As the stories in this annual report show, the trust and partnership of our donors and collaborators are vital in order for us to make progress in often turbulent and unpredictable political contexts. We are deeply grateful to those who support our ultimate goal of fighting corruption for a better world, who trust our way of working and who are willing to invest for long-term success.\n> \n> By jointly designing interventions and building in flexibility, we can continue to leverage our individual and collective resources, achieve greater impact and relevance and keep alive Gretta’s legacy over the Institute’s next 20 years and beyond.","2024-05-28","2023-annual-report-foreword-by-peter-maurer-2634","2023 Annual Report: Foreword by Peter Maurer","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F57bcce3f-245f-41d0-aabd-2fa58a0c5a09?width=1000&height=650&format=webp&quality=80",[],[10],[259,72],"Reports",[],2634,[],[259,72],[265],1113,[],[23],[],"2024-05-28T10:01:30.000Z","2025-08-31T23:14:40.000Z",[],"\u002Fresources\u002Fnews\u002F2023-annual-report-foreword-by-peter-maurer-2634",{"left":274,"top":274,"width":275,"height":275,"rotate":274,"vFlip":276,"hFlip":276,"body":277},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>",1780676427846]