With good governance norms under growing pressure, the EU has an opportunity to show decisive leadership in the fight against corruption.

The European Commission’s first EU-wide Anti-Corruption Strategy, building on the recently adopted EU Anti-Corruption Directive, is a chance to strengthen coordination across Member States and realise the promise of the Directive for the EU’s 450+ million inhabitants.

Done well, it will reinforce the security, economic prosperity and political stability that underpin Europe’s long-term competitiveness.

The Basel Institute on Governance has responded to the Commission’s call for evidence with recommendations drawn from more than two decades of research and hands-on work with governments, law enforcement agencies, businesses and civil society. Our submission highlights four areas that we believe should be central to the new Strategy. These are briefly summarised below, and included in full in the submission [PDF download].

Promote a whole-of-society approach

Governments cannot tackle complex corruption risks alone. Businesses, civil society, researchers and affected communities all have a role to play.

The Strategy should therefore explicitly endorse Anti-Corruption Collective Action. This approach brings stakeholders together to identify shared risks, agree standards and develop practical mechanisms for compliance and accountability.

It has been used to address money laundering risks in the financial services sector, bribery and extortion in ports, corruption in public procurement and integrity challenges in the defence sector. It is widely endorsed by organisations including the OECD, UNODC and UN Global Compact, and already included in many national anti-corruption strategies.

Harness data and technology responsibly

Artificial intelligence, big data analytics, open-source intelligence and automated risk indicators can help identify suspicious procurement patterns, conflicts of interest, illicit financial flows and hidden relationships.

Research through the EU-funded FALCON project, of which the Basel Institute is a consortium member, shows that effective anti-corruption systems increasingly depend on the ability to collect, connect and analyse large volumes of information.

The Strategy should support responsible testing of new tools, including through regulatory sandboxes, while also investing in the foundations they require: digitisation, interoperable systems, standardised datasets, machine-readable information and secure cross-border data sharing.

Focus on priority risks and high-risk activities

Beyond these approaches, our submission highlights four high-risk areas requiring particular attention.

• Foreign bribery: Enforcement remains uneven and settlements often fail to address the harm suffered by affected countries and communities. The Strategy should promote stronger enforcement and fairer approaches to compensation and the use of recovered proceeds.
• Public procurement: Risks are rising as Europe increases investment in defence, infrastructure, energy security and strategic technologies. Priorities should include stronger transparency, better oversight and data-driven risk assessment.
• Borders and customs: Corruption at borders can facilitate smuggling, trafficking, sanctions evasion and tax fraud. Greater automation, data integration and consistent procedures can strengthen prevention and detection.
• Financial infrastructure: Shell companies, professional intermediaries, offshore structures and virtual assets can help conceal corrupt proceeds. The Strategy should strengthen links between anti-corruption, anti-money laundering and asset recovery, including through the EU’s new Anti-Money Laundering Authority.

Build in an ongoing research, innovation and learning agenda

Corruption constantly evolves as actors adapt to new laws, technologies and enforcement practices. Anti-corruption policy must evolve too.

Research also shows that anti-corruption laws alone do not change corrupt behaviour. Social norms, political incentives and institutional cultures can sustain corruption even where formal rules are strong.

The Strategy should support sustained applied research and create stronger channels for researchers, policymakers, law enforcement, businesses and civil society to exchange evidence and lessons. It should also use differences between national systems as opportunities to test approaches, evaluate results and improve policy across the Union.

Learn more

• Download the Basel Institute on Governance’s full submission to the European Commission’s call for evidence on the EU Anti-Corruption Strategy.
• See complementary perspectives on the EU Anti-Corruption Directive on how it might affect anti-corruption enforcement from a legal and institutional perspective, and on what the Directive reveals about how corruption is evolving in the EU and beyond.