[{"data":1,"prerenderedAt":310},["ShallowReactive",2],{"news-fcpa-blog-will-the-un-security-council-finally-take-up-the-fight-against-corruption-2605":3,"news-fcpa-blog-will-the-un-security-council-finally-take-up-the-fight-against-corruption-2605-similar":77,"i-heroicons:arrow-left-20-solid":305},[4],{"id":5,"status":6,"date_created":7,"date_updated":8,"title":9,"type":10,"body":11,"date":12,"topic":13,"slug":15,"activity":16,"nid":17,"topics":18,"activities":19,"programme":20,"area":20,"websites":21,"language":20,"image":23,"translation_of":20,"countries":33,"tags":34,"authors":35,"images":74,"translations":75,"content":76},10435,"published","2024-03-19T11:01:54.000Z","2025-08-31T23:14:40.000Z","FCPA Blog: Will the UN Security Council (finally) take up the fight against corruption?","Blog","_This blog was originally published on the FCPA Blog, which was discontinued in February 2024._\n\nThankfully, the economist-led debates in the 1990s about whether corruption is the necessary grease in the wheels of business are long behind. But we would argue that many people, including those most affected by it and possibly even those that are in the anti-corruption business, still don’t fully grasp what corruption does to our world.\n\nWhat’s wrong with a Head of State taking money from companies who want to win public contracts, especially if otherwise he or she seems to be running the country in an acceptable way? Hard to believe but I still get this question often. The answer seems obvious, but it seems the connection between corruption and lack of education or public healthcare is not an automatic one for many people. Thankfully, a few real-life examples usually suffice to demonstrate it.\n\nTaking the obvious next step of acknowledging that corruption is a direct impediment to the enjoyment of human rights already takes more convincing. But in our view, it is crystal clear: States that fail to effectively prevent and punish corruption are in direct violation of their obligations under international human rights treaties.\n\nOur security is protected by police, and terrorism is the business of radicals — or so we think. Yet Transparency International’s 2017 Global Corruption Barometer ranks the police as the most corrupt public institution. It is said that corrupt security services were the cause for a heavily delayed response to the Westgate shopping mall attack in Kenya in 2013. What that means is that people died as a direct result of corruption. Frustration about corruption pushes young people into associating with radical groups as these offer an opportunity to vent their anger. Terrorism flourishes where corruption is rife.\n\nWhy can criminal networks engaged in illegal trafficking in humans, arms and wildlife products operate so freely? Because they can bribe their way through customs and out of courts. And when they have laundered the proceeds of their crimes successfully through the international financial system, they can use these same monies to continue their criminal enterprises.\n\nFinally, let us not forget that when money buys votes, when money buys influence, when money buys politicians, when the media is co-opted by corrupt networks, we lose our fundamental right to participate in the destiny of our countries and consequently of our lives. Institutions of democracy, when undermined by corruption, as they sadly are to varying degrees almost everywhere in the world today, become a farce. They end up protecting rotten systems behind a pretty face.\n\nIs this reason enough to fight corruption? We certainly think so. The international community missed a critical opportunity when the Sustainable Development Goals (SDGs) failed to list anti-corruption as one of their 17 high-level principles. We firmly believe that corruption is the root cause of most if not all hurdles to development; and as long as corruption prevails, achieving the SDGs will remain elusive.\n\nMaybe we have just seen this being corrected this week, which saw the first UN Security Council session on the relationship between corruption and conflict. Maybe we have just experienced the start of a new era for the fight against corruption, one that finally connects corruption to the reasons for which we need to eradicate corruption. To conflict and security, humanitarian crises, human rights, poverty and democracy. Many member states reported proudly about their efforts to eradicate corruption, and to hear this in the UN Security Council is an important first step. But we have heard similar statements many times in the past two decades in other important fora, and yet our global and domestic political and economic structures are possibly more undermined by corruption today than before the signing of the UN Convention against Corruption.\n\nIf elevating this topic to the UN Security Council should have any impact, we need to keep the pressure on and hold member states to account for what they promise in these high-level debates. And we, as anti-corruption practitioners, must be better at breaking thought barriers between our community and that of related areas, so that anti-corruption action is not happening in a silo but connected to where its impact may not be easily visible but where it does the greatest damage to our world.","2018-09-13",[14],"","fcpa-blog-will-the-un-security-council-finally-take-up-the-fight-against-corruption-2605",[14],2605,[],[],null,[22],"Main page",{"id":24,"storage":25,"filename_disk":26,"filename_download":27,"title":9,"type":28,"created_on":7,"modified_on":7,"charset":20,"filesize":29,"width":30,"height":31,"duration":20,"embed":20,"description":20,"location":20,"tags":20,"metadata":32,"focal_point_x":20,"focal_point_y":20,"tus_id":20,"tus_data":20,"uploaded_on":7},"aeb7dba7-8a3b-49c9-b84e-258f5eb52e04","local","aeb7dba7-8a3b-49c9-b84e-258f5eb52e04.webp","tmp.webp","image\u002Fwebp",34454,800,536,{},[],[],[36,57],{"id":37,"news_id":38,"authors_id":53},1031,{"id":5,"status":6,"user_created":39,"date_created":7,"user_updated":40,"date_updated":8,"title":9,"type":10,"body":11,"image":24,"date":12,"topic":41,"slug":15,"activity":42,"nid":17,"topics":43,"activities":44,"programme":20,"area":20,"websites":45,"translation_of":20,"language":20,"countries":46,"tags":47,"authors":48,"images":50,"translations":51,"content":52},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","b0662e2a-864d-4888-a1b7-4342b7570b30",[14],[14],[],[],[22],[],[],[37,49],1032,[],[],[],{"id":54,"name":55,"position":20,"image":56},297,"Gretta Fenner","06f7143f-fe9b-45df-87a0-8c2e8f721109",{"id":49,"news_id":58,"authors_id":70},{"id":5,"status":6,"user_created":39,"date_created":7,"user_updated":40,"date_updated":8,"title":9,"type":10,"body":11,"image":24,"date":12,"topic":59,"slug":15,"activity":60,"nid":17,"topics":61,"activities":62,"programme":20,"area":20,"websites":63,"translation_of":20,"language":20,"countries":64,"tags":65,"authors":66,"images":67,"translations":68,"content":69},[14],[14],[],[],[22],[],[],[37,49],[],[],[],{"id":71,"name":72,"position":20,"image":73},302,"Mark Pieth","2f4f2174-a03c-4bd1-9cbc-848efef795c6",[],[],[],[78,106,134,157,181,206,228,249,280],{"id":79,"body":80,"status":6,"type":10,"date":81,"slug":82,"title":83,"image":84,"countries":85,"topic":87,"activity":90,"tags":91,"nid":92,"topics":93,"activities":94,"authors":95,"images":98,"websites":99,"area":20,"programme":20,"language":20,"translations":100,"translation_of":20,"user_created":39,"date_created":101,"user_updated":102,"date_updated":103,"content":104,"link":105},10429,"_This blog was originally published on the FCPA Blog, which was discontinued in February 2024._\n\n2023 was a mixed bag for the business integrity community. On the one hand, the B20 – the voice of business of the G20 forum of major economies – had no Integrity & Compliance Task Force under the Indian Presidency. That was a major missed opportunity for all of us who care about raising standards of business integrity around the world.\n\nThe B20 Integrity & Compliance [Task Force](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fb20-g20) is a unique platform to discuss and build consensus among businesses on compliance and integrity topics across G20 countries. It provides an opportunity to present G20 governments with specific issues for consideration and implementation. \n\nOn a more positive note, the [OECD Integrity Forum](https:\u002F\u002Fwww.oecd-events.org\u002Fgacif2023) and U.S.-led [Summit for Democracy](https:\u002F\u002Fwww.state.gov\u002Fsummit-for-democracy\u002F) discussions highlighted the private sector’s critical role in the fight against corruption, particularly in high-risk sectors such as infrastructure and energy. \n\n2023 also finished on a high note: For the first time, the UN Conference of the States Parties (CoSP) in Atlanta included a forum [dedicated](https:\u002F\u002Fbusinessintegrity.unodc.org\u002Fbip\u002Fen\u002Fevents\u002Fprivate-sector-forum.html) to business integrity. More than 500 companies supported a [call to action](https:\u002F\u002Funglobalcompact.org\u002Ftake-action\u002Faction\u002Fanti-corruption-call-to-action) on business integrity, which was presented to government delegates at the CoSP. \n\nUpon taking over the G20 Presidency in December, Brazil [announced](https:\u002F\u002Fb20brazil.org\u002Fintegrity-compliance) that the B20 Integrity & Compliance Task Force would be re-introduced. The Task Force will be led by renowned Brazilian business leader, Claudia Sender, with the Brazilian National Conference of Industry (CNI) leading the B20 overall. \n\nAs the B20 [kicks off](https:\u002F\u002Fb20brazil.org\u002Fevent) in Rio de Janeiro at the end of January, strong participation and engagement of the Brazilian and global business community can be expected – including on the integrity agenda.\n\n### Business integrity: the backbone of the wider business agenda\n\n2023 offered some sobering reminders of the need for continued efforts by companies and governments to manage their corruption risks. A notable example was the corruption case in Portugal’s renewable energy sector, which led to the resignation of the Portuguese prime minister.\n\nFueled by geopolitical tensions, corruption is evolving, and economic, social, and political systems are shifting alongside it. \n\n“To stay abreast of these interconnected challenges, companies need to look beyond their internal processes, to increase their engagement in policy platforms and in spaces for dialogue with their communities”, says Robin Hodess of The B Team, a long standing B20 Task Force member. \n\nActive business participation in multi-stakeholder settings can help ensure that new standards, laws, and policies reflect business realities (including stakeholder demands) and can be effectively implemented. \n\n### The B20 Task Force at the forefront of efforts to advance business integrity\n\nAs a multi-stakeholder group with a strong and international business representation, the B20 Integrity & Compliance Task Force has achieved tangible impacts under previous G20 Presidencies. \n\nFor example, it was one of the first business groups to [recommend the introduction of public digital beneficial ownership registers](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fb20-g20\u002Fb20-2018-argentina) and transparent and competitive procurement processes. Both of these issues continue to be front and center for business integrity – and corporate transparency is key to global efforts to curb illicit financial flows. \n\nThe B20 also co-authored with the G20 a [guidance document](https:\u002F\u002Firp-cdn.multiscreensite.com\u002Fe0b6c17a\u002Ffiles\u002Fuploaded\u002FB20-G20%20Anti-corruptionToolkit%20for%20SMEs%202015.1.pdf) on Compliance for SMEs and worked on an [Anti-Corruption Technology Road Map](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-03\u002FB20-Integrity-Compliance-Policy-Paper-30092020.pdf) to promote integrity and compliance. Current debates about the impact of artificial intelligence on business will no doubt have huge implications for business integrity as well in the years to come. \n\nThe ongoing focus on transparency makes business integrity efforts key to the wider agenda for economic transformation, such as the just energy transition. Disclosure on company policies, processes, and impact – whether on anti-corruption or on carbon – helps create accountability, which is [critical for businesses and their commitments to a sustainable economy](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2022-11\u002FB20%20I%20and%20C%20summary.pdf), as the Task Force noted across the past few B20 cycles.\n\nTransparency is also a key element for stakeholder engagement, which is increasingly part of the business integrity agenda.\n\n### The B20 is a community of practice not just a process \n\nOne positive takeaway from the hiatus of the Integrity & Compliance Task Force in 2023 was the continued engagement and commitment of previous Task Force members. Together, we worked to integrate key transparency and business integrity topics in other task forces. \n\nAs a group, we have also been proactive and vocal in the process to reinstate the Integrity & Compliance Task Force during the 2023\u002F24 Brazilian B20 Presidency. Members met regularly, despite having no official home in the B20.\n\nWe updated a [guidance document](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fpublications\u002F1792) that captures a range of good practices and learnings for incoming B20 presidencies, such as:\n\n*   Promoting consistent engagement between the Integrity & Compliance Task Force and the G20 Anti-Corruption Working Group, which advises the G20 leaders on anti-corruption topics.\n*   Ensuring consistency, continuity, and follow-up across G20\u002FB20 Presidencies, including by tracking progress.\n*   Enhancing governance in Task Force management.\n\nThis all reflects what makes the B20 anti-corruption workstream unique: the voice and historical knowledge of its community. \n\n### Looking forward\n\nThrough the Task Force, the business integrity community is actively engaged in shaping the B20 process rather than the other way around. This allows for community ownership. It also means there is impact on the wider business community beyond the recommendations made to the G20 every year.\n\nUnder the Brazilian leadership, the B20 in 2024 promises a re-invigorated Integrity and Compliance Task Force, whose work is cut out for it. The community of practitioners committed to business integrity is ready for the challenge.\n\nTo find out more about the Integrity and Compliance work at the B20 or to join the informal community, see the Basel Institute’s [resource pages](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fb20-g20) and reach out to Robin Hodess, The B Team, [rh@bteam.org](mailto:rh@bteam.org).","2024-01-29","fcpa-blog-strong-leadership-breathes-new-life-into-b20-integrity-amp-compliance-task-force-2598","FCPA Blog: Strong leadership breathes new life into B20 Integrity & Compliance Task Force","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F5e6e9e50-d014-4914-952a-ca023c123b49?width=1000&height=650&format=webp&quality=80",[86],7138,[88,89],"Collective Action","Private Sector",[14],[],2598,[88,89],[],[96,97],1122,1123,[],[22,88],[],"2024-03-19T11:01:32.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-04-15T22:28:52.000Z",[],"\u002Fresources\u002Fnews\u002Ffcpa-blog-strong-leadership-breathes-new-life-into-b20-integrity-amp-compliance-task-force-2598",{"id":107,"body":108,"status":6,"type":109,"date":110,"slug":111,"title":112,"image":113,"countries":114,"topic":115,"activity":117,"tags":119,"nid":124,"topics":125,"activities":126,"authors":127,"images":128,"websites":129,"area":20,"programme":20,"language":20,"translations":130,"translation_of":20,"user_created":39,"date_created":131,"user_updated":40,"date_updated":8,"content":132,"link":133},10386,"_Our Environmental Crime Specialist Dr Amanda Cabrejo le Roux interviewed_ _Brice Böhmer, Climate and Environment Lead at Transparency International and head of its_ [_Climate Governance Integrity programme_](https:\u002F\u002Fwww.transparency.org\u002Fen\u002Fprojects\u002Fclimate-governance-integrity-programme)_. Brice also leads the new Working Group on Corruption in Climate Finance at the_ [_Countering Environmental Corruption Practitioners Forum_](https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-countering-environmental-corruption-practitioners-forum)_, an initiative of the Basel Institute, Transparency International, WWF and TRAFFIC._\n\n_Brice explains how actors involved in climate-related initiatives need to seriously consider how corruption and vested interests can undermine positive policies, destroy the trust needed for good climate governance and divert much-needed funds. Promoting transparency, social accountability and multi-stakeholder dialogue will contribute to improved climate governance at all levels – and to secure better prospects for our planet._\n\n### Climate and corruption: what is the problem?\n\nSeveral problems!\n\nFirst, corruption diverts money that is desperately needed for climate mitigation and adaptation interventions.\n\nSecond, corruption reduces the effectiveness of climate action.\n\nThird, corruption can dilute climate policies, through conflicts of interest and undue influence (lobbying).\n\nLast, we have to look at the negative impact of other forms of environmental corruption on climate efforts. For example, illegal logging facilitated by corruption undermines efforts to preserve forests through climate-focused programmes like REDD+. To ensure that climate efforts are successful we also need to take these forms of corruption into account.\n\nWe consider climate corruption as the _abuse of entrusted power for private gain that results in climate injustice and is hindering climate efforts_. So this goes well beyond the financial side of climate-related efforts. It hits wider governance issues like transparency, accountability, participation and open data.\n\n### What are the forms of corruption at play and what are their effects?\n\nClearly, if large amounts of money are embezzled from climate mitigation and adaptation projects, these efforts will be less successful or may fail altogether. The intended beneficiaries – and our climate – will suffer as a result.\n\nHow much money is stolen is a difficult question to answer, because the world lacks data and even a clear framework for _collecting_ data on climate finance or corruption.\n\nIn a sample of climate projects in Bangladesh, we found that all were affected in some way by corruption. In total, around [35 percent of the funding was lost](https:\u002F\u002Fwww.ti-bangladesh.org\u002Fbeta3\u002Fimages\u002F2020\u002Freport\u002FMitigation-Finance\u002FMitigation_Finance_Governance_ES_EN.pdf). On a global scale, it is estimated that around USD 100 billion per year would be saved if we responded effectively to climate-related corruption risks – the [same amount](https:\u002F\u002Fwww.oecd.org\u002Fclimate-change\u002Ffinance-usd-100-billion-goal\u002F) that wealthy countries originally pledged to send to developing nations every year under the Paris Agreement.\n\nSome forms of corruption can have even more pernicious and long-lasting effects.\n\nImagine a corrupt deal to build a hydroelectric plant, for instance. Government officials award an overpriced contract to a company without the right skills or experience to build the plant in return for bribes or because politicians have a beneficial interest in the company. The result? The public funds are gone. The plant is not built, or is badly built. Perhaps local residents are thrown off their land without adequate compensation or means of seeking redress. Maybe environmental assessments are not carried out or are ignored, damaging the very environment we are trying to protect.\n\nCorruption can take even more insidious forms. We’ve seen the impact of undue influence from oil and gas lobbying on law-making processes, or conflicts of interest that were not brought to light.\n\nThese forms of corruption affect decision making in all countries, including not only developing countries which are recipients of climate finance but also wealthy countries and multilateral institutions which are funding the majority of climate mitigation and adaptation projects.\n\n### What makes climate mitigation and adaptation vulnerable to corruption?\n\nIn our experience over the past 10 years of the Climate Governance Integrity programme, we see the following factors as critical:\n\n*   The large and growing volumes of finance flowing to climate mitigation and adaption projects.\n*   The pressure to disburse funds quickly due to the urgency of tackling climate change, leading to normal rules and systems being bypassed – as it happened in the Covid-19 pandemic.\n*   The involvement of sectors with high corruption risks: infrastructure, energy, mining, forestry.\n*   The fact that many countries receiving climate finance suffer from high levels of corruption. This is clearly visible if you compare Transparency International’s [Corruption Perceptions Index](https:\u002F\u002Fwww.transparency.org\u002Fen\u002Fcpi\u002F2022) with a map of recipients of climate finance.\n*   The technical nature of many climate mitigation and adaptation projects, which can make it easier to deceive independent auditors and evaluators.\n*   The newness of climate institutions and funding channels, which may not have strong corruption controls in place. Many climate-focused institutions are only at the early stages of implementing compliance programmes – sometimes in response to Transparency International advocacy – or conflicts of interest policies.\n\n### What is Transparency International doing about it?\n\nOur Climate Governance Integrity programme arose from the realisation that addressing the corruption risks that threaten climate efforts is vital for the future of our planet. The programme is now structured around three main elements:\n\n*   Climate policy – making policymaking processes and institutions more transparent, inclusive and accountable.\n*   Climate action – reducing the corruption risks which affect interventions, through developing social accountability tools to give greater oversight and voice to civil society organisations and marginalised groups, including indigenous peoples.\n*   Climate justice – giving ways for victims of climate-related corruption to safely blow the whistle or seek redress.\n\nThe programme is coordinated centrally at Transparency International’s Secretariat in Berlin and implemented in collaboration with national chapters from Transparency International’s movement. We are currently expanding, with the goal of reaching 25 countries by the end of 2023.\n\nA lack of data continues to be a problem. At the national and global levels, there are no accessible mechanisms for the public to know how much money is flowing, to where and from whom. There is not even a clear agreement on what “climate finance” includes.\n\nChanging this lies largely in the hands of climate policymakers, but we are doing what we can to improve data on corruption and the climate. Our [Climate and Corruption Atlas](https:\u002F\u002Fwww.transparency.org\u002Fen\u002Fprojects\u002Fclimate-governance-integrity-programme\u002Fclimate-corruption-atlas) collects cases of corruption linked to climate governance. Moving from theoretical risks to real cases will help us estimate the scale of the problems and find better ways to tackle them.\n\n### What is the key to success in tackling climate-related corruption?\n\nDialogue and cooperation between different stakeholders. Specifically, people and organisations engaged in climate efforts need to come together with their counterparts in anti-corruption.\n\nOnly then can they learn to speak the same language. Even simple words like “governance” have different meanings to different people. Say “climate governance”, and climate practitioners think of institutions like the Conference of Parties (COP) of the United Nations Framework Convention on Climate Change (UNFCCC) and international and national governing bodies. Anti-corruption practitioners think of good governance principles like transparency, accountability and participation.\n\nFostering multi-stakeholder dialogue can be project specific. For example, following a [corruption risk assessment of REDD+ in Kenya](https:\u002F\u002Fwww.un-redd.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-10\u002FREDD%20Corruption%20Study%20Kenya%20Final%20December%2018%20Dec%202013%20PRINT%20READY.pdf), a multi-stakeholder REDD+ Integrity Task Force was formed in 2014 from members of government and civil society to respond to the different integrity issues raised.\n\nWe also need wider dialogue and cooperation between anti-corruption practitioners and those in climate\u002Fenvironmental fields, which is the aim of the [Countering Environmental Corruption Practitioners Forum](https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-countering-environmental-corruption-practitioners-forum).\n\nThe Forum’s Corruption in Climate Finance Working Group, which we have just launched, will be shaped by members from the ground up. I’m looking forward to vibrant exchanges on challenges, tools and best practices in the coming months. If you are working in this space or want to be, [do sign up](https:\u002F\u002Fbaselgovernance.us18.list-manage.com\u002Fsubscribe?u=57a44b9c295a8c412a42580fd&id=20f1721883).\n\n### Learn more\n\n*   See Transparency International’s recent paper on [Corruption-free climate finance: Strengthening multilateral funds](\u002F\u002F\u002FCorruption-free%20climate%20finance\u002F%20Strengthening%20multilateral%20funds)\n*   See this briefing paper on [Corruption and Climate Finance](https:\u002F\u002Fwww.u4.no\u002Fpublications\u002Fcorruption-and-climate-finance) by the U4 Anti-Corruption Resource Centre.\n*   Read a related FCPA blog by the Basel Institute: [Is corruption on the climate change agenda?](https:\u002F\u002Ffcpablog.com\u002F2021\u002F11\u002F08\u002Fis-corruption-on-the-climate-change-agenda\u002F)\n*   Learn more about the Basel Institute’s [Green Corruption programme](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption), which tackles the corruption that facilitates environmental degradation.","News","2023-08-30","is-the-climate-crisis-a-corruption-crisis-an-interview-with-brice-bohmer-2501","Is the climate crisis a corruption crisis? An interview with Brice Böhmer","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Ffaf73381-bc59-48b9-86dd-80c3496f7c9a?width=1000&height=650&format=webp&quality=80",[],[116],"Green Corruption",[118],"Insights",[120],{"tags_id":121},{"id":122,"name":123},1303,"Environment",2501,[116],[118],[],[],[22],[],"2023-08-30T10:01:33.000Z",[],"\u002Fresources\u002Fnews\u002Fis-the-climate-crisis-a-corruption-crisis-an-interview-with-brice-bohmer-2501",{"id":135,"body":136,"status":6,"type":10,"date":137,"slug":138,"title":139,"image":140,"countries":141,"topic":142,"activity":144,"tags":145,"nid":146,"topics":147,"activities":148,"authors":149,"images":151,"websites":152,"area":20,"programme":20,"language":20,"translations":153,"translation_of":20,"user_created":39,"date_created":154,"user_updated":40,"date_updated":8,"content":155,"link":156},10430,"_This blog was originally published on the FCPA Blog, which was discontinued in February 2024._\n\nThe release on November 13 of the [12th Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) ranking of money laundering and terrorist financing risks in 152 jurisdictions takes a look at why risks are rising and what to make of the increased crypto scrutiny.\n\n### Increasing risks, decreasing effectiveness\n\nAccording to this year’s Basel AML Index, average global risks of money laundering and terrorist financing increased from 5.25 (out of 10) last year to 5.31.\n\nYes, it’s a small change – but it should be going in the other direction. We saw risks increase in four of the five areas we measure:\n\n*   Corruption and Bribery\n*   Financial Transparency and Standards\n*   Public Transparency and Accountability\n*   Political and Legal Risks\n\nScores for the quality of AML\u002FCFT frameworks remained static.\n\nThe declining effectiveness of AML\u002FCFT systems is also a cause for concern. Effectiveness scores, measured using data from the Financial Action Task Force (FATF), have dipped to 28 percent. Imagine having a household appliance that was only 28 percent effective. You would throw it out, right?\n\nSure, effectiveness varies across regions – different countries have different weak spots. But globally, effectiveness scores are particularly low in critical areas – like beneficial ownership transparency, the misuse of non-profit organizations for terrorist financing, and confiscation of illicit assets.\n\n### Virtual assets compliance is plunging\n\nThe data on how countries are dealing with money laundering risks posed by crypto is still young, as the FATF only added requirements on virtual assets to its 40 Recommendations in 2018. But, on the face of it, things aren’t looking good. Compliance with the relevant Recommendation 15 is plunging as more countries are assessed – from 63 percent in 2021 to 43 percent today. There is no clear data on the effectiveness of measures relating to virtual assets.\n\nCompliance with the FATF Recommendation is especially low in regions that stand to gain the most from FinTech innovation. Sub-Saharan Africa and South Asia, where many people remain excluded from the traditional financial sector, have compliance levels of just 19 percent and 25 percent respectively.\n\n### Is hesitancy the real issue?\n\nTo some extent, our report explains, this plunging compliance with the FATF standard is to be expected. The crypto world is highly technical, volatile, and evolving fast. It is natural for regulators to take a “wait and see” approach and to [experiment](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-38).\n\nAnd it’s good to learn from experiments – as Estonia did [this year](https:\u002F\u002Fdefi-planet.com\u002F2023\u002F05\u002Fover-300-virtual-asset-service-providers-forced-to-shut-down-in-estonia-due-to-new-aml-laws\u002F), after the authorities increased their supervision and noted deficiencies in their light-touch regulations on virtual asset service providers (VASPs). After strengthening them in line with FATF Recommendations, hundreds of VASPs either voluntarily closed down or had their licences revoked.\n\nWe also note cautious grounds for optimism. Even if the amount of illicit funds flowing through virtual assets is growing, the [percentage](https:\u002F\u002Fwww.chainalysis.com\u002Fblog\u002F2023-crypto-crime-report-introduction\u002F) of illicit activity on the blockchain remains well below 1 percent. And regulators are catching up. The EU, for example, is introducing more consistent regulation that will reduce the risks of “regulator shopping” by VASPs, at least within the bloc.\n\nEnforcement successes in crypto asset seizures also demonstrate the huge potential for asset tracing and recovery in this area. The U.S. seized a staggering [$3.6 billion in Bitcoin](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Ftwo-arrested-alleged-conspiracy-launder-45-billion-stolen-cryptocurrency) in connection with the 2016 Bitfinex hack – the largest financial seizure to date. The UK has [reformed its laws](https:\u002F\u002Fwww.gov.uk\u002Fgovernment\u002Fnews\u002Frobust-new-laws-to-fight-corruption-money-laundering-and-fraud) to make it easier to confiscate cryptocurrencies linked to crime, after recovering over $370 million in crypto in 2022.\n\nGiven that our Basel AML Index report separately laments that asset confiscation rates remain stuck below 1 percent, this kind of progress is to be encouraged.\n\nThis all reinforces the sentiment at the latest [Global Conference on Criminal Finances and Cryptocurrencies](https:\u002F\u002Fwww.europol.europa.eu\u002Fmedia-press\u002Fnewsroom\u002Fnews\u002Fshaping-international-response-against-criminal-misuse-of-cryptocurrencies), which we co-organize each year with Europol: that it’s time to embrace the possibilities of virtual assets and to work hard to better understand the evolving risks. But it’s not time to panic.\n\nAs former virtual assets regulator Malcolm Wright [said](https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=DWRkNUq0Rxw) in our Basel AML Index launch webinar, public-private partnerships and cooperation are key to developing regulations that foster a thriving global FinTech industry while protecting users, investors, and the wider financial system from the risks.\n\n\\* \\* \\*\n\nFind out where your country sits in the [Basel AML Index ranking](https:\u002F\u002Findex.baselgovernance.org\u002Franking) this year and check out our report and regional [infographics](https:\u002F\u002Findex.baselgovernance.org\u002Fdownload) for more analysis of current money laundering trends.\n\nFor a deeper dive into the data behind money laundering and terrorist financing risks, you can subscribe to our [Expert Edition](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) versions.","2023-11-20","fcpa-blog-basel-aml-index-risks-are-rising-across-the-board-2599","FCPA Blog: Basel AML Index: Risks are rising across the board","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc9921f94-a0d6-4912-9f50-59b4d3118090?width=1000&height=650&format=webp&quality=80",[],[143],"Anti-Money Laundering",[14],[],2599,[143],[],[150],1132,[],[22],[],"2024-03-19T11:01:33.000Z",[],"\u002Fresources\u002Fnews\u002Ffcpa-blog-basel-aml-index-risks-are-rising-across-the-board-2599",{"id":158,"body":159,"status":6,"type":14,"date":160,"slug":161,"title":162,"image":163,"countries":164,"topic":165,"activity":166,"tags":169,"nid":170,"topics":171,"activities":172,"authors":173,"images":174,"websites":175,"area":20,"programme":20,"language":20,"translations":176,"translation_of":20,"user_created":39,"date_created":177,"user_updated":40,"date_updated":178,"content":179,"link":180},10039,"The Basel Institute on Governance is conducting a survey addressing corporate perspectives on e-government tools for anti-corruption prevention.\n\nWe are writing to ask for your collaboration in sharing your views on this matter. By clicking [HERE](https:\u002F\u002Fsurvey.baselgovernance.org\u002Findex.php\u002Fsurvey\u002Findex\u002Fsid\u002F191349\u002Fnewtest\u002FY\u002Flang\u002Fen) you can answer the survey anonymously, it will only take about 6 minutes.\n\nE-government tools - such as e-procurement, e-tax filing and e-sourcing - aim to promote efficient and clean business. It is often said that reducing personal contacts between companies and government officials helps to reduce the scope for discretionary decisions, diminishing the opportunities for bribery.  Is this your experience in practice?  Does your business take e-government tools into consideration in country corruption risk assessments or when entering a new market? Have they reduced the incidence of bribery solicitation?\n\nThe Basel Institute will be issuing a report providing an inventory of e-government tools to fight corruption. This survey will complement the report to provide a practical view of the prevalence of use of e-government tools by companies, as well as companies’ perceptions of their usefulness in preventing corruption in practice. Find out more on this topic by reading the [FCPA Blog post by Gemma Aiolfi](http:\u002F\u002Fwww.fcpablog.com\u002Fblog\u002F2017\u002F3\u002F15\u002Fdo-e-government-and-digital-technologies-really-help-to-prev.html), Head of Compliance.\n\nThe results from this survey will be made public alongside our research report. Our sincere thanks in advance to all for taking part in the survey and contributing to this important benchmarking effort.\n\nThis project is supported by GSK and Deloitte.","2017-03-15","participate-in-our-survey-do-e-government-and-digital-technologies-really-help-to-prevent-corruption-137","Participate in our survey: Do e-government and digital technologies really help to prevent corruption?","\u002Fpics\u002Fimg-placeholder.png",[],[89],[167,168],"Research","Partnerships",[],137,[89],[167,168],[],[],[22],[],"2022-05-26T22:58:30.000Z","2025-08-31T23:14:59.000Z",[],"\u002Fresources\u002Fnews\u002Fparticipate-in-our-survey-do-e-government-and-digital-technologies-really-help-to-prevent-corruption-137",{"id":182,"body":183,"status":6,"type":10,"date":184,"slug":185,"title":186,"image":163,"countries":187,"topic":188,"activity":190,"tags":191,"nid":192,"topics":193,"activities":195,"authors":196,"images":199,"websites":200,"area":20,"programme":20,"language":20,"translations":201,"translation_of":20,"user_created":39,"date_created":202,"user_updated":102,"date_updated":203,"content":204,"link":205},10432,"_This blog was originally published on the FCPA Blog, which was discontinued in February 2024._\n\nHundreds of billions of dollars of Russian assets sit frozen in bank accounts, buildings, and harbors, thanks to the unprecedented financial sanctions rolled out since the full-scale invasion of Ukraine on February 2022. Understandably, states holding large quantities of Russian assets are under political pressure to permanently seize these and redirect the money to support Ukraine.\n\nBut political pressure and rule of law are different things, and permanently seizing those assets is not as easy as some make it sound. Hence the debate that is currently raging: should states be able to confiscate those assets purely on the basis that they have been sanctioned?\n\nA dangerous path\n\nOur recent working paper [_From Sanctions to Confiscation While Upholding the Rule of Law_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42) examines this debate in depth. It considers the justifiability and legality of new legislative mechanisms that allow a state to permanently seize an asset purely because its holder is under sanction. Canada has already included such a mechanism in its _Special Economic Measures Act_, though it is yet to be tested in court.\n\nIn brief, our analysis concludes that any mechanisms used to confiscate assets need to be in line with the rule of law. They must respect established legal rights and afford due process. If they do not, states open themselves up to legal challenges and the possibility of having confiscation orders overturned after years of wrangling in higher courts. \n\nA better way\n\nThe good news is that most states already have established pathways to target assets that are frozen under sanctions. \n\nIn the working paper, we highlight how both criminal and civil (non-conviction-based) forfeiture mechanisms can be used to target assets where they can be linked to offenses such as sanctions violations, money laundering, or organized crime. \n\nThe U.S. has long used civil forfeiture mechanisms to confiscate assets where it can be demonstrated to a civil standard of proof that the assets were derived from or used in criminal activity. Such mechanisms do not require a criminal conviction before they can be applied. This makes them a powerful option to target the assets of kleptocrats adept at sidestepping criminal prosecutions.\n\nAnother option to seize financially sanctioned assets would be unexplained wealth or [illicit enrichment legislation](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28). Since such laws reverse the burden of proof onto a person to demonstrate the lawful sources of their assets, states would not need to acquire evidence of criminal activity from potentially uncooperative jurisdictions.\n\nNot all countries, however, have non-conviction-based forfeiture or unexplained wealth mechanisms. Where they do, their scope varies widely, and international cooperation is a challenge. Introducing, applying, and cooperating in the context of these laws would go a long way to targeting those frozen assets. \n\nStrengthening systems\n\nBeyond maximizing the toolkit to target assets frozen under sanctions, states can also make smaller but necessary adjustments to maximize the potential of their laws.\n\nThese may include broadening the scope of relevant terms such as “property” or “money laundering” or ensuring that non-conviction-based forfeiture mechanisms apply to the widest possible definition of “unlawful conduct.” \n\nAs the U.S. [has done](https:\u002F\u002Fwww.congress.gov\u002Fbill\u002F117th-congress\u002Fhouse-bill\u002F2617\u002Ftext), states may also need to amend laws governing the end use of seized assets to permit them to be redirected to the victims of aggression rather than returned to the aggressor state from which they were stolen.\n\nBeyond legislation, states could improve domestic and international coordination by establishing specialist law enforcement task forces such as the [U.S. Task Force KleptoCapture](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Fattorney-general-merrick-b-garland-announces-launch-task-force-kleptocapture) and the [Russian Elites, Proxies, and Oligarchs Task Force](https:\u002F\u002Fhome.treasury.gov\u002Fnews\u002Fpress-releases\u002Fjy0839). And as anti-corruption advocates have argued for many years, allocating adequate resources to these efforts so that they can actually be effective is fundamental.\n\nBolstering defenses against kleptocracy\n\nStrengthening and applying established asset recovery mechanisms will not only increase the chances of successfully seizing assets in the long run. It will also uphold the rule of law that the Ukrainians are fighting for.\n\nBeyond that, concerted efforts to strengthen asset recovery mechanisms and cooperation will aid in the broader fight against corruption and related financial crimes.\n\nCorruption is a national security issue and a global security imperative. Stopping corruption is key to stopping kleptocracies from gaining illegitimate power and influence – and, as we have sadly seen, using that to launch illegal wars and to corrupt the rules-based order.","2023-02-27","fcpa-blog-how-seizing-sanctioned-assets-can-strengthen-the-rule-of-law-2600","FCPA Blog: How seizing sanctioned assets can strengthen the rule of law",[],[189],"Asset Recovery",[14],[],2600,[194],"Asset Recovery and Enforcement",[],[197,198],1025,1026,[],[22],[],"2024-03-19T11:01:35.000Z","2026-05-29T22:22:29.000Z",[],"\u002Fresources\u002Fnews\u002Ffcpa-blog-how-seizing-sanctioned-assets-can-strengthen-the-rule-of-law-2600",{"id":207,"body":208,"status":6,"type":10,"date":209,"slug":210,"title":211,"image":163,"countries":212,"topic":213,"activity":214,"tags":215,"nid":216,"topics":217,"activities":218,"authors":219,"images":222,"websites":223,"area":20,"programme":20,"language":20,"translations":224,"translation_of":20,"user_created":39,"date_created":225,"user_updated":40,"date_updated":8,"content":226,"link":227},10434,"_This blog was originally published on the FCPA Blog, which was discontinued in February 2024._\n\nLast week’s publication of our 10th annual [Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fbasel-aml-index-2021-4-things-holding-back-global-fight-against-money-laundering) – which assesses money laundering risks around the world and ranks jurisdictions on how well they’re addressing them – has triggered two types of response.\n\nAs usual, people first want to see how their country is doing on the AML\u002FCFT “league table.” How is the country ranked compared to its neighbors? Has the risk score gone up or down? Sadly, the answer to that last question is: mostly up. The average global money laundering risk score increased slightly this year from 5.22 to 5.3 out of 10.\n\nThis kind of league table response hits headlines, but it misses the point. The point of the Basel AML Index is to illuminate weaknesses in national, regional, and global financial systems that leave them open to abuse by money launderers, those financing terrorism, and other criminals. After all, the fight against corruption and money laundering is not a competition but a team effort.\n\nSome of the weaknesses revealed by the Basel AML Index are caused by the continuous evolution of financial crime typologies. Ten years ago, for example, cryptocurrencies were barely heard of; now, as our [report explores](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-09\u002FBasel_AML_Index_2021_10th%20Edition.pdf), regulators and reporting entities are scrambling to get on top of the risks.\n\nIn other areas, not all jurisdictions are scrambling enough. Our analysis, for example, supports growing concerns that beneficial ownership transparency is not being implemented as fast or as effectively as it should be. This is not only a problem for law enforcement seeking information on suspected criminals or for financial institutions trying to conduct customer due diligence in the dark. It undermines global efforts to combat corruption and money laundering because it leaves opaque spots on the world map where criminals can set up anonymous corporate structures to launder their illicit money.\n\nThen we have the blind spots. This year, we have shone a light on money laundering risks beyond the financial sector. Data-crunching shows that lawyers, accountants, real estate agents, and other designated non-financial businesses and professions (DNFBPs) continue to underperform on compliance with AML\u002FCFT standards. Tighter regulations, more supervision, and credible enforcement are urgently needed to close that gap.\n\nLastly, and most disappointingly, weaknesses that we have pointed out year after year since the first edition of the Basel AML Index have barely been addressed. The effectiveness of AML\u002FCFT systems is the elephant in the room here. On average, countries assessed by the FATF for the effectiveness of their AML\u002FCFT frameworks score a woeful 30 percent. This means it is still all too common for jurisdictions to have laws and institutions in place that are largely compliant with FATF Recommendations yet ineffective in practice.\n\nTired of repeating this message, this year, we looked more closely at the data to see whether the problem was prevention, enforcement, or both. We saw that jurisdictions consistently score even worse for the prevention of money laundering than they do for enforcement. Why this is, is an excellent question to ask and a hard one to answer. Unlike for enforcement, there is very little hard data to measure the effectiveness of preventive measures.\n\nSmart governments, or those that mean what they preach, will look at this and invest more resources in preventing money laundering and terrorist financing. A fire contained is always better than an arsonist caught when the house has burnt down. This obviously shouldn’t come at the expense of enforcement because arsonists also have to be caught and punished.\n\nAnd if all players in government and the private sector work to better understand and address their money laundering risks – as well as keep up with global trends like those above – maybe, just maybe, all countries will creep up the Basel AML Index league table next year.","2022-09-22","fcpa-blog-basel-aml-index-going-beyond-the-money-laundering-leaderboard-2603","FCPA Blog: Basel AML Index – Going beyond the money laundering leaderboard",[],[143],[14],[],2603,[143],[],[220,221],1029,1030,[],[22],[],"2024-03-19T11:01:38.000Z",[],"\u002Fresources\u002Fnews\u002Ffcpa-blog-basel-aml-index-going-beyond-the-money-laundering-leaderboard-2603",{"id":229,"body":230,"status":6,"type":10,"date":231,"slug":232,"title":233,"image":163,"countries":234,"topic":235,"activity":236,"tags":237,"nid":238,"topics":239,"activities":240,"authors":241,"images":243,"websites":244,"area":20,"programme":20,"language":20,"translations":245,"translation_of":20,"user_created":39,"date_created":246,"user_updated":40,"date_updated":178,"content":247,"link":248},10174,"Joe Murphy recently talked in a post on the FCPA Blog about [antitrust concerns](http:\u002F\u002Fwww.fcpablog.com\u002Fblog\u002F2015\u002F3\u002F3\u002Fjoe-murphy-us-antitrust-lawyers-are-nervous-about-business-s.html) under U.S. law for competitors who band together to fight corruption. I'd like to explain how and why the antitrust issue can be mitigated.\n\nBefore I start, it's worth noting that various U.S. companies such as GE, Lockheed, General Dynamics, and others are already active members of various collective anti-corruption efforts, and other companies listed on U.S. exchanges are also participants, including ABB. This shows, I think, that it's possible to get comfortable with meetings and communications among competitors for the purpose of developing and implementing collective anti-corruption strategies.\n\nHere are some of the arguments: The UK [Ministry of Justice Guidance](http:\u002F\u002Fwww.fcpablog.com\u002Fblog\u002F2010\u002F9\u002F23\u002Fbribery-act-guidance-released.html) describes the \"adequate procedures\" a company needs to implement under the UK Bribery Act to defend against a charge of corporate criminal liability for bribery. Included is a reference to involvement in anti-corruption collective action. In _Principle 2: Top-Level Commitment_, the last bullet states that top-level commitment is likely to include \"reference to the organisation’s involvement in any collective action against bribery in, for example, the same business sector.\"\n\nIt's important to note the specific reference to _the same business sector_. This is a strong indication that the UK Ministry of Justice not only permits but encourages competitors to take  collective action in favor of compliance and against corruption.\n\nThe full text of the UK Guidance can be [found here](http:\u002F\u002Fwww.justice.gov.uk\u002Fdownloads\u002Flegislation\u002Fbribery-act-2010-guidance.pdf) (pdf).\n\nHere are some additional points to consider:\n\nAntitrust laws and regulations do not prevent competitors from discussing best practices in relation to compliance issues. In order to mitigate risks of inappropriate exchanges of information by companies during the discussions around corruption risks, there are several things that can be done.\n\n*   The presence of a third-party facilitator such as [the Basel Institute on Governance](https:\u002F\u002Fwww.baselgovernance.org\u002F) is crucial and provides a safeguard for all participants through risk-mitigation precautions undertaken by the facilitator. Such antitrust risk mitigation includes the facilitator proposing the dates, times, and locations for the meetings, issuing the invitations, and providing the meeting agenda. Thereafter, the facilitator should act as the chairperson, formulating the minutes of every meeting, whether by phone, webcams, chatrooms, or in person, and reminding the participants that sensitive information is not to be exchanged. These simple procedures should be followed even if the meetings include senior compliance and legal staff who are already well aware of antitrust laws and regulations.\n*   In the unlikely event that discussions stray toward competitive information even inadvertently, the facilitator needs to interrupt the speaker or speakers. At this point, the facilitator will want to remind those in the room about antitrust (or competition law) related risks. I should point out that in the Basel Institute's long years of experience, this scenario rarely occurs in practice.  \n*   Where there is even a slight indication of a possibly sensitive matter arising in any written document produced through anti-corruption collective action, the facilitator should direct each participating company to clear the proposed text with their antitrust or competition counsel _before_ any further discussions are undertaken. Such antitrust or competition counsel may be in-house anti-competition specialists or external legal counsel.\n\nWe've seen these straightforward precautions and practices work well over many years.\n\nFor these reasons, we at the Basel Institute are confident that any antitrust risk arising from anti-corruption collective action initiatives can be satisfactorily managed and mitigated, even under U.S. legal standards.\n\n_This post initially appeared in the [FCPA Blog](http:\u002F\u002Fwww.fcpablog.com\u002Fblog\u002F2015\u002F3\u002F10\u002Fantitrust-risks-can-be-managed-when-competitors-fight-graft.html) and is reproduced here with permission._","2015-03-10","antitrust-risks-can-be-managed-when-competitors-fight-graft-together-282","Antitrust risks can be managed when competitors fight graft together",[],[88,89],[118],[],282,[88,89],[118],[242],1328,[],[22,88],[],"2022-05-26T22:59:19.000Z",[],"\u002Fresources\u002Fnews\u002Fantitrust-risks-can-be-managed-when-competitors-fight-graft-together-282",{"id":250,"body":251,"status":6,"type":109,"date":252,"slug":253,"title":254,"image":255,"countries":256,"topic":257,"activity":258,"tags":259,"nid":268,"topics":269,"activities":271,"authors":272,"images":273,"websites":274,"area":20,"programme":20,"language":20,"translations":275,"translation_of":20,"user_created":39,"date_created":276,"user_updated":102,"date_updated":277,"content":278,"link":279},9612,"The Basel Institute on Governance has joined forces with the Alliance for Integrity and more than 60 partners from 12 countries to raise awareness of the importance of business integrity – and the challenges it can present to individuals, their families, business partners and society.\n\nThe [Alliance for Integrity](https:\u002F\u002Fwww.allianceforintegrity.org\u002F) is a global business-driven, multi-stakeholder initiative seeking to promote transparency and integrity in the economic system. Its global #United4Integrity campaign, which launches today, features an [interactive video](http:\u002F\u002Fbit.ly\u002FWWYDGlobal) as its centrepiece.\n\nThe protagonist in the video is faced with an integrity dilemma that small business leaders all over the world will recognise. Should she cheat to win that contract? What would _you_ do? Choose whether you would say yes, say no or look away.\n\nThe video encourages viewers to engage in debate about the challenges of doing business with integrity and the potential consequences when things go wrong. There are no easy answers but viewers can visit the campaign website, [what-would-you-do.org](http:\u002F\u002Fwhat-would-you-do.org\u002Fgb\u002Fhome-4\u002F), to find out how engaging in Collective Action can help.\n\n### Sparking debate towards the Global Conference\n\nThe Basel Institute’s [Collective Action team](https:\u002F\u002Fbaselgovernance.org\u002Fcollective-action) has been working closely with the Alliance for Integrity almost since its inception. Our Head of Compliance and Collective Action Gemma Aiolfi, who sits on the Alliance’s Steering Committee, praised the leadership’s initiative in sparking debate:\n\n> It’s easy to forget that at heart, anti-corruption compliance is not about paperwork, checklists and toolkits – it’s about people, values and knowing when and how to do the right thing. This unique campaign by the Alliance for Integrity encourages workers, managers and business leaders alike to openly talk about corporate values and listen to one another’s concerns.\n> \n> I strongly encourage you to take this journey and to connect with the Alliance for Integrity to find out how you can join this vibrant global partnership.\n\nVisit the [campaign website](http:\u002F\u002Fwhat-would-you-do.org\u002Fgb\u002Fhome-4\u002F) and [interact with the video](http:\u002F\u002Fbit.ly\u002FWWYDGlobal) here. We invite you to share this important message with your networks using the campaign hashtag #United4Integrity.\n\nThe campaign culminates in the Global Conference of the Alliance for Integrity on 27-29 April 2021. It is open to all and free of charge. Register via the [event platform here](https:\u002F\u002Fallianceforintegrity.plazz.net\u002F#dashboard.html?).\n\n### More insights on business integrity and Collective Action\n\n*   See this recent Q&A with Susanne Friedrich, Director of Alliance for Integrity, on [how Collective Action can help SMEs overcome the pandemic](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fhow-collective-action-can-help-smes-overcome-pandemic-qa-alliance-integritys-susanne-friedrich).\n*   Susanne Friedrich also appears in a short video filmed at the Basel Institute’s 2018 International Collective Action Conference to answer the question: [“What is Collective Action and what is its value in combating corruption?](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Fcollective-action-videos)”\n*   Scarlet Wannenwetsch’s article on Anti-Corruption Collective Action appeared in the [16th Compliance Bulletin](https:\u002F\u002Fwww.allianceforintegrity.org\u002FwAssets\u002Fdocs\u002Fpublications\u002FCompliance-Bulletin\u002FAfIn_ComplianceBulletin_16.pdf) of Alliance for Integrity in collaboration with the Global Compact Network Germany.\n*   Gemma Aiolfi’s article on [Integrity and anti-corruption in the private sector post covid-19](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fhere-today-and-gone-tomorrow-integrity-and-anti-corruption-private-sector-post-covid-19), written in April 2020, generated vivid debate among the community and was republished on the FCPA Blog.\n*   This [quick guide to integrity and anti-corruption compliance for SMEs](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fgemma-aiolfis-quick-guide-integrity-and-anti-corruption-compliance-smes) outlines five simple things that any business can do to raise levels of integrity in their organisation. It’s available on the Alliance for Integrity campaign website, alongside other useful publications on anti-corruption Collective Action.","2021-03-29","what-would-you-do-alliance-for-integrity-global-campaign-launches-with-thought-provoking-video-1994","What would you do? Alliance for Integrity Global Campaign launches with thought-provoking video","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F83ba0bb3-1192-4472-ab47-f5649cb0ee58?width=1000&height=650&format=webp&quality=80",[],[88,89],[118,168],[260,264],{"tags_id":261},{"id":262,"name":263},830,"Business integrity",{"tags_id":265},{"id":266,"name":267},1274,"Ethics",1994,[88,89,270],"Business Integrity Ethics and Compliance",[118,168],[],[],[22,88],[],"2022-05-26T22:53:15.000Z","2026-05-29T22:21:46.000Z",[],"\u002Fresources\u002Fnews\u002Fwhat-would-you-do-alliance-for-integrity-global-campaign-launches-with-thought-provoking-video-1994",{"id":281,"body":282,"status":6,"type":10,"date":283,"slug":284,"title":285,"image":286,"countries":287,"topic":288,"activity":290,"tags":291,"nid":294,"topics":295,"activities":296,"authors":297,"images":298,"websites":299,"area":20,"programme":20,"language":20,"translations":300,"translation_of":20,"user_created":39,"date_created":301,"user_updated":102,"date_updated":302,"content":303,"link":304},10352,"_Business entities wishing to implement projects funded by Multilateral Development Banks (MDBs, also referred to as International Financial Institutions) will be interested to know that six major MDBs have agreed and published new General Principles for Business Integrity Programmes. Such programmes play an important part in the MDBs’ efforts to fight fraud and corruption in the projects they finance or otherwise support._\n\n_These General Principles provide non-exhaustive, non-binding guidance for business entities that implement such projects. Notably, they recommend engagement in Collective Action to encourage other business entities to implement integrity programmes as well._\n\n_In this guest blog, Lisa Miller of the World Bank Group and Duncan Smith of the European Investment Bank explain, especially for businesses seeking to implement MDB-financed projects, what the General Principles are and the role business integrity programmes play in MDBs’ anti-fraud and anti-corruption efforts._\n\nSix major Multilateral Development Banks (MDBs)—the African Development Bank ([AfDB](http:\u002F\u002Fwww.afdb.org\u002Fen)), Asian Development Bank ([ADB](http:\u002F\u002Fwww.adb.org\u002F)), European Bank for Reconstruction and Development ([EBRD](http:\u002F\u002Fwww.ebrd.com\u002Fhome)), European Investment Bank ([EIB](http:\u002F\u002Fwww.eib.org\u002F)), Inter-American Development Bank ([IDB](http:\u002F\u002Fwww.iadb.org\u002Fen)), and [World Bank Group](http:\u002F\u002Fwww.worldbank.org\u002Fen\u002Fhome)—have agreed and published new General Principles for Business Integrity Programmes.\n\nThe MDBs provide essential support for development projects in countries seeking assistance, in particular financial support. They are public, not commercial, multilateral lending institutions. The MDBs, among other things, lend money to their member countries (public borrowers) to carry out key development projects, which the borrowers implement.\n\nThe projects often involve the purchase of goods, works, and services through public procurement systems in which private entities seek to win contracts under the MDB-supported projects.\n\nUnfortunately, some entities seek to improperly influence (e.g., via bribes) or otherwise distort the process, such as through the submission of fraudulent information in a bid for such contracts. The potential for misconduct also exists throughout the project lifecycle.\n\n### MDB expectations and control mechanisms\n\nIt is essential that the funds provided by the MDBs are used for their intended purposes and are not misused, whether by borrowers or by the entities that compete for or win contracts under MDB-supported projects. The MDBs therefore expect entities participating in such projects to maintain the highest standard of integrity.\n\nThe MDBs’ expectations in that regard are set out in financing agreements with borrowers and contracts entered into between borrower agencies and the contractors and consultants that work under such projects. The MDBs also have in place mechanisms to monitor related procurement processes and contract performance.\n\nIn addition, each MDB has an integrity function, to which any suspected misuse of funds or other prohibited practices under such projects should be reported. In this respect, the MDBs have adopted harmonised definitions of fraud, corruption, collusion and coercion (commonly collectively referred to simply as “fraud and corruption”) which are set out in the [International Financial Institutions Uniform Framework for Preventing and Combating Fraud and Corruption](https:\u002F\u002Fwww.eib.org\u002Fen\u002Fabout\u002Fdocuments\u002Fifi-anti-corruption-task-force-uniform-framework.htm) (the Framework).\n\nIf an allegation has been investigated by an MDB (or MDBs if the project is co-financed) and a finding of misconduct has been substantiated, each MDB has an internal administrative process to sanction those who have engaged in such misconduct (e.g., debarment or exclusion). \\[1\\]\n\nMoreover, some MDBs have signed an Agreement for Mutual Enforcement of Debarment Decisions among Multilateral Development Banks, commonly referred to as the [Cross-Debarment Agreement](http:\u002F\u002Fcrossdebarment.org\u002Foai001p.nsf\u002FHome.xsp?SessionID=CWO0W588ZO), under which an entity that is debarred by one MDB for an initial period exceeding one year also generally is debarred by the other MDBs. \\[2\\]\n\n### The role of business integrity programmes\n\nA business integrity programme should clearly articulate an entity’s values, as well as the policies and procedures used to prevent, detect, investigate and remediate misconduct in the entity’s operations.\n\nAs set out by the MDBs in their respective policies and procedures, an entity’s business integrity programme is often relevant in connection with the MDBs’ frameworks for investigating and sanctioning fraud and corruption. For example, the business integrity programme of a company that is accused of misconduct may be considered in an MDBs’ investigation and sanctions proceedings, such as in determining an appropriate sanction.\n\nIn addition, when an entity is sanctioned by an MDB, the MDB may impose conditions for the entity’s reinstatement or release from sanction that require the entity to develop and implement a business integrity programme. In such cases, whether the entity has put in place and is effectively implementing a programme designed to prevent, deter, detect, investigate and remediate prohibited practices will be considered by the MDB in its assessment of the entity’s application for reinstatement or release from sanction.\n\nAs effective business integrity programmes become more common among the entities that participate in MDB-supported projects, it is hoped that the risk of misconduct in such projects will decline. As Principle 29 of the document makes clear, Collective Action can help to encourage the widespread adoption of effective business integrity programmes.\n\nBusiness integrity programmes therefore play an important part in MDBs’ efforts to fight fraud and corruption in the projects they support.\n\nThe General Principles are intended as non-exhaustive, non-binding guidance relating to business integrity programmes in the context of MDB-financed projects. Companies also may wish to refer to the General Principles as guidance for their programmes in other contexts. Indeed, it is a good business practice to have such a programme in place, and to implement the programme consistently and effectively, as a standard approach to doing business.\n\nIn addition, the General Principles are intended to be adaptable to entities of all types and sizes that are operating in various environments. The policies and procedures comprising a business integrity programme should be based on a comprehensive risk assessment of the entity’s operations and should be tailored accordingly. The programme should address and include provisions intended to minimise the occurrence of the identified risks, and it should be structured such that it will accommodate changing circumstances and evolve over time.\n\n### Core elements of a programme\n\nWhile a programme should reflect an entity’s own circumstances and integrity risk profile, key features, such as those set out in the General Principles, should be incorporated into the programme as appropriate.\n\nThe General Principles cover the following core principles, among others:\n\n*   Risk Assessment\n*   Prohibited Misconduct\n*   Management Roles\n*   Integrity Function\n*   Internal Controls\n*   Reporting, Investigation, and Remediation\n*   Training, Communication, Advice, and Accessibility\n*   Business Partners\n*   Collective Action\u002FExternal Engagement\n\n### In conclusion\n\nThe General Principles set out important guidance relating to the MDBs’ efforts to ensure the funds they lend to states are used only for development purposes. The General Principles are intended as guidance relating to the prevention of fraud and corruption and can be adopted and implemented by entities in all sectors and of all sizes.\n\nThe General Principles may be found at [Cross Debarment (adb.org)](https:\u002F\u002Flnadbg4.adb.org\u002Foai001p.nsf\u002FContent.xsp?action=openDocument&documentId=E89FC5403A8D0B654825896E0017FAD9) including an Appendix that sets out additional guidance relating to the core principles.\n\n### Notes\n\n\\[1\\] MDB investigation teams also may refer suspected criminal conduct to relevant law enforcement agencies that have the full range of criminal investigation tools (e.g., search and arrest warrants).\n\n\\[2\\] For legal reasons, EIB did not sign the Cross Debarment Agreement but recognizes that the debarment should be identified and disclosed under the EIB Covenant of Integrity ([EIB Guide to Procurement](https:\u002F\u002Fwww.eib.org\u002Fen\u002Fpublications\u002Fguide-to-procurement), Annex 3).\n\n### About the authors\n\nLisa Miller is the World Bank Group Integrity Compliance Officer and heads the Integrity Compliance Office in [the World Bank Group's Integrity Vice Presidency](https:\u002F\u002Fwww.worldbank.org\u002Fen\u002Fabout\u002Funit\u002Fintegrity-vice-presidency\u002F). She previously was a Senior Counsel in the World Bank's Legal Vice Presidency, focusing on sanctions and legal procurement matters. Prior to joining the World Bank, she was in private legal practice in Boston and Washington, DC, where her practice focused on integrity compliance, sanctions, public procurement, and corporate matters. \n\nDuncan Smith will soon retire as Deputy Head of Investigations at EIB. After passing the English Bar, he prosecuted corporate fraud & corruption cases at the UK’s DTI & SFO. He then spent 7 years at World Bank Investigations (as Team Leader, later Policy Adviser); he moved to EIB in 2007 to investigate large cases and address prevention\u002Fdeterrence\u002Foutreach & negotiate settlements. He co-authored the International Financial Institutions Anti-Corruption Uniform Framework Agreement (2006) & MDB harmonization documents (e.g., General Principles on Settlements). He has written many articles on the subject, including for Basel Institute on Governance & FCPA Blog and has authored two books: [Promoting Integrity in the Work of International Organisations: Minimising Fraud and Corruption in Projects](%20Minimising%20Fraud%20and%20Corruption%20in%20Projects) (2021) and [Fraud and Corruption: Cases & Materials](https:\u002F\u002Flink.springer.com\u002Fbook\u002F10.1007\u002F978-3-031-10063-5) (2022).","2023-03-27","business-integrity-programmes-multilateral-development-banks-harmonise-their-guidance-2417","Business integrity programmes: Multilateral Development Banks harmonise their guidance ","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F0e0e8557-bb5a-4596-ac88-4a6e910bc584?width=1000&height=650&format=webp&quality=80",[],[88,289],"Compliance",[118],[292],{"tags_id":293},{"id":262,"name":263},2417,[88,270],[118],[],[],[22,88],[],"2023-03-27T08:29:43.000Z","2026-05-29T22:22:25.000Z",[],"\u002Fresources\u002Fnews\u002Fbusiness-integrity-programmes-multilateral-development-banks-harmonise-their-guidance-2417",{"left":306,"top":306,"width":307,"height":307,"rotate":306,"vFlip":308,"hFlip":308,"body":309},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>",1780676493581]