[{"data":1,"prerenderedAt":334},["ShallowReactive",2],{"news-how-mushroom-sites-and-disinformation-stand-in-the-way-of-combating-corruption-in-bulgaria-2707":3,"news-how-mushroom-sites-and-disinformation-stand-in-the-way-of-combating-corruption-in-bulgaria-2707-similar":82,"i-heroicons:arrow-left-20-solid":329},[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":20,"topics":21,"activities":22,"programme":23,"area":23,"websites":24,"language":23,"image":26,"translation_of":23,"countries":37,"tags":61,"authors":62,"images":79,"translations":80,"content":81},10497,"published","2024-10-14T10:01:37.000Z","2025-08-31T23:14:40.000Z","How mushroom sites and disinformation stand in the way of combating corruption in Bulgaria","Blog","How does the media influence public discourse on corruption and anti-corruption? And how can we ensure information integrity in an age of disinformation, propaganda, fake news and hybrid attacks? \n\nTo answer those questions in the context of Bulgaria, Sensika, a global media monitoring and analytics firm, processed more than 44 million articles in Bulgarian online media outlets and more than 20 million Facebook posts and comments on corruption and anti-corruption topics between January 2023 and February 2024.\n\nThe [research report](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbulgaria-media-2024) – an update of similar research in [2021–2022](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcorruption-and-anti-corruption-narratives-bulgarian-media-media-monitoring-and) – supports the Basel Institute's technical assistance programme with the Bulgarian Government and was funded by the Swiss Agency for Development and Cooperation (SDC) and the United States Agency for International Development (USAID).\n\nThis comprehensive examination offered us valuable perspectives on the media’s role in shaping public opinion on governance and integrity. The findings underpin the importance of smart government communication and the informed and critical consumption of information by citizens. The research methodology employed AI technologies and was bolstered by human interventions for accurate trend spotting, sentiment analysis and deep-dive content monitoring. A short summary is below.\n\n### Corruption is headline news; integrity less so\n\nBetween 2023 and early 2024, both corruption and anti-corruption narratives received sustained attention and coverage. This contrasts with 2021–2022, when  corruption-related narratives attracted more media attention than news on anti-corruption efforts. Interesting findings include:\n\n*   Comments on Facebook often outnumbered original posts. Even allowing for the activities of trolls and bots, this suggests a reactive audience keen to discuss these issues.\n*   Corruption-related keywords saw sustained interest in terms of both volume and reach, a finding consistent with our recent [public opinion research](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcorruptionsurveybg2024) indicating corruption as one of citizens’ top three concerns.\n*   Integrity-related keywords had a more limited reach, suggesting that users are more interested in narratives exposing wrongdoing than in those highlighting virtue. \n\n### Disinformation via mushroom sites and social media\n\nIn the context of anti-corruption as well as in general, disinformation and fake news have far-reaching negative implications: distorted information space, manipulated public opinion, amplified divisions and polarised societies.\n\nThis makes the job of anti-corruption practitioners and government officials extremely challenging, as they try to devise smart communication strategies to counter these trends and promote informational integrity on corruption and anti-corruption topics. \n\nAs the research points out, hybrid attacks _flood_ the public discourse with large volumes of manipulative content.Disinformation is spread by _seeding_ superficial news stories and narratives in mushroom websites and amplifying them on social media via armies of trolls and bots.\n\nMushroom websites are _impostor_ online media outlets, designed to provide anonymity and plausible deniability for their creators. They are created in bulk by malicious actors to seed disinformation, propaganda and fake news. During disinformation campaigns, they “pop up, multiply and grow” in a coordinated manner. Afterwards they either disappear or become inactive until the next campaign.\n\nSocial media platforms amplify what mushroom sites publish. Trolls and bots, using fake user profiles, share disinformation, propaganda and fake news across different social networks to artificially boost engagement metrics. This way they _trick_ the platforms’ algorithms and make the content look _organically viral_. \n\nAs a result, many social media users suffer increased cognitive vulnerability. The increased consumption of news through social media and mobile devices has led to more unconscious behaviour, meaning more impulsive reactions to media content that reinforces their existing beliefs. Often users distribute disinformation and fake news without reading beyond the headlines or checking the source.\n\n### What does this look like in Bulgaria?\n\nBulgaria is no stranger to malign forces seeking to disrupt the integrity of the public information space for private gain. It is also no stranger to destructive smear campaigns that aim to slander, defame and silence reformers.\n\nLast year, for example, a well-orchestrated malicious campaign was executed through hundreds of mushroom sites against then Minister of Justice Krum Zarkov, an outspoken voice for anti-corruption legislative reforms. The smear campaign falsely accused Minister Zarkov of strangling cats and eventually necessitated a public rebuttal.         \n\nThis year’s research also observed apparently coordinated disinformation campaigns in both online media outlets and Facebook. Mushroom websites published sensationalist content about notable individuals. Suspicious Facebook users, potentially trolls, posted similar or identical comments under different posts in a limited time frame. It is not unlikely that this amplification of sensationalist narratives influenced public perception and discussion around corruption- and anti-corruption issues.\n\n### Corruption and sensationalism\n\nCoverage of corruption-related narratives in Bulgarian online and social media illustrates the significance of corruption as a critical issue, with continued exposure of scandals across various domains. These narratives reveal systemic concerns within the governmental, judiciary and law enforcement sectors. They not only achieved impressive media coverage volume but also reached extensive audiences, underscoring the gravity of corruption as a key societal issue – a point confirmed by our [public opinion research](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcorruptionsurveybg2024).\n\nLegitimate media, mushroom websites and media aggregators play distinct roles in disseminating corruption-related content:\n\n*   Social media platforms drive traffic to mushroom websites and media aggregators. In Bulgaria, Facebook plays an outsized role in referring users to mushroom sites.\n*   Legitimate media provide a steady stream of articles, often using indirect language to discuss corrupt practices.\n*   Mushroom websites amplify particular corruption-related events and disseminated biased or selective news with often sensationalist undertones.\n*   Aggregators broaden the content’s reach.\n\n### The good news: anti-corruption discourse is also strong\n\nOur research showed the steady presence of anti-corruption keywords in legitimate online media, with peaks around specific events like new legislative measures, government actions or high-profile corruption cases.\n\nConstitutional anti-corruption reforms and the enactment of a newAnti-Corruption Law in 2023 saw significant media coverage. The dismissal of Chief Prosecutor Ivan Geshev and the introduction of a legal mechanism for investigation and criminal liability of the position of Chief Prosecutor incited widespread media debate on the need for increased governance accountability and transparency. The topic was actively discussed on Facebook, amplifying public engagement on issues of governance and justice. \n\nBulgaria’s aspirations to join the OECD were another subject of media attention, signifying a dedication to bolstering good governance frameworks in line with international standards. This was also exemplified by coverage of the [implementation of the Whistleblower Protection Act](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Frolling-out-bulgarias-new-whistleblower-protection-act).\n\n### Learn more\n\n*   Download [_Corruption and anti-corruption narratives in Bulgarian media: Media monitoring and analysis report 2024_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbulgaria-media-2024)","2024-10-14",[14],"","how-mushroom-sites-and-disinformation-stand-in-the-way-of-combating-corruption-in-bulgaria-2707",[17,18,19],"Research","Reports","Insights",2707,[],[17,18,19],null,[25],"Main page",{"id":27,"storage":28,"filename_disk":29,"filename_download":30,"title":9,"type":31,"created_on":32,"modified_on":32,"charset":23,"filesize":33,"width":34,"height":35,"duration":23,"embed":23,"description":23,"location":23,"tags":23,"metadata":36,"focal_point_x":23,"focal_point_y":23,"tus_id":23,"tus_data":23,"uploaded_on":32},"0987552a-0136-4ab0-a102-990136f44901","local","0987552a-0136-4ab0-a102-990136f44901.webp","tmp.webp","image\u002Fwebp","2025-05-12T21:10:15.000Z",40108,1400,732,{},[38],{"id":39,"news_id":40,"countries_id":55},7092,{"id":5,"status":6,"user_created":41,"date_created":7,"user_updated":42,"date_updated":8,"title":9,"type":10,"body":11,"image":27,"date":12,"topic":43,"slug":15,"activity":44,"nid":20,"topics":45,"activities":46,"programme":23,"area":23,"websites":47,"translation_of":23,"language":23,"countries":48,"tags":49,"authors":50,"images":52,"translations":53,"content":54},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","b0662e2a-864d-4888-a1b7-4342b7570b30",[14],[17,18,19],[],[17,18,19],[25],[39],[],[51],1101,[],[],[],{"id":56,"name":57,"code":58,"latitude":59,"longitude":60},22,"Bulgaria","BG",42.73388,25.48583,[],[63],{"id":51,"news_id":64,"authors_id":76},{"id":5,"status":6,"user_created":41,"date_created":7,"user_updated":42,"date_updated":8,"title":9,"type":10,"body":11,"image":27,"date":12,"topic":65,"slug":15,"activity":66,"nid":20,"topics":67,"activities":68,"programme":23,"area":23,"websites":69,"translation_of":23,"language":23,"countries":70,"tags":71,"authors":72,"images":73,"translations":74,"content":75},[14],[17,18,19],[],[17,18,19],[25],[39],[],[51],[],[],[],{"id":77,"name":78,"position":23,"image":23},548,"Renne Traicova",[],[],[],[83,114,137,164,202,228,257,281,306],{"id":84,"body":85,"status":6,"type":10,"date":86,"slug":87,"title":88,"image":89,"countries":90,"topic":91,"activity":94,"tags":95,"nid":104,"topics":105,"activities":106,"authors":107,"images":108,"websites":109,"area":23,"programme":23,"language":23,"translations":110,"translation_of":23,"user_created":41,"date_created":111,"user_updated":42,"date_updated":8,"content":112,"link":113},9522,"The Natural Resource Governance Institute (NRGI) has launched tailored guidance on measures that companies in the oil, gas and mining sectors can adopt to reduce corruption risks when partnering with state-owned enterprises (SOEs).\n\nPublished on a user-friendly website, [Anticorruption Guidance for Partners of State-Owned Enterprises](https:\u002F\u002Fresourcegovernance.org\u002Fsoe-anticorruption) also recommends measures SOEs can take to strengthen their own anti-corruption safeguards. The guidance was [launched at a virtual event](https:\u002F\u002Fyoutu.be\u002FG5NJ3Ryc7jM) on 26 January 2022, at which our Head of Collective Action Gemma Aiolfi moderated a panel discussion.\n\nIn this interview, [Alexandra Gillies](https:\u002F\u002Fresourcegovernance.org\u002Fabout-us\u002Fexpert\u002Falexandra-gillies), Advisor to the NRGI and co-author of the guidance alongside Tom Shipley, explains how and why they developed the guidance over two years of research and multi-stakeholder consultations with private companies, SOEs and civil society stakeholders, including our [Collective Action team](https:\u002F\u002Fbaselgovernance.org\u002Fcollective-action).\n\nHer insights throw light on the NRGI’s approach of conducting extensive, multi-stakeholder consultation and trust-based discussion, which is central to many Collective Action initiatives. A similar process could help practitioners in other sectors and countries to develop guidance that both addresses pertinent corruption risks and has a good chance of being widely adopted.\n\n### Anti-corruption recommendations already exist for extractive industries and for SOEs. Why did you decide a fresh approach was needed?\n\nOil, gas and mining industries are crucial to many countries’ development, but the benefits to citizens continue to be lost through corruption. Despite the many valuable efforts to raise standards of integrity and implement safeguards against corruption in these sectors, something is clearly missing the mark.\n\nAnd the stakes are only going to rise with the commodities boom and explosion in demand for transition minerals. Three issues stand out:\n\nFirst, interactions between international companies and SOEs in charge of oil, gas and mining resources remain a major problem area.\n\nThis finding emerged clearly from our detailed analysis of over 100 past corruption cases across many countries. Initial conversations with compliance officers confirmed that existing measures, and the standard risk-based approach to addressing corruption risks more generally, face difficulties in the case of interactions with some SOEs. They were open to fresh ideas.\n\nSecond, existing compliance systems often focus narrowly and inwardly on protecting companies from penalties for violating anti-bribery laws.\n\nYet many forms of corruption that are the most harmful to citizens are not covered by bribery laws, such as when political elites syphon off hundreds of millions of dollars that could be public revenue. We were keen to address the risks of company activities _enabling_ corruption by helping corrupt actors to carry out their schemes.\n\nThird, voluntary anti-corruption guidance needs buy-in from companies if it is to be effectively implemented across enough of the sector to make a difference.\n\nThis means it needs to take into account how companies interact with SOEs in their operations, the risks they face, and what is feasible to implement in their anti-corruption and due diligence systems. We therefore wanted to prioritise learning from private companies and other stakeholders about what’s working and what’s not in their relationships with SOEs. This is where a Collective Action approach helped.\n\n### Who is the guidance aimed at and why?\n\nDespite the focus of the guidance on five specific risk areas between extractive industry companies and SOEs – due diligence, high-risk agents, political exposure, safeguarding payments and joint ventures – many of the recommendations are relevant to a broad stakeholder group.\n\nAs well as producers directly involved in extracting natural resources, we proactively involved other companies in the supply chain, notably commodity traders and suppliers to oil, gas and mining companies. Although we drew on existing relationships at NRGI, we also reached out to get new companies involved in the conversation.\n\nWithin these companies, we are targeting not only compliance teams but also commercial departments and those responsible for external affairs, transparency, human rights and related issues. This is because we take a broad view of what counts as corruption and what kind of anti-corruption measures can help. In SOEs, we spoke to compliance teams or, where dedicated compliance functions do not yet exist, we engaged the leadership or the legal and procurement departments.\n\nThis mix reflects the professional backgrounds of those who took part in the workshops and consultation process.\n\n### What were their incentives to take part?\n\nI believe there was a genuine interest among participants in getting new ideas to tackle these common problem areas. And sharing experiences with like-minded professionals who have similar concerns is not only useful and enriching, but enjoyable.\n\nReputation is also an important factor. As with many Collective Action initiatives, engaging in such a consultation process helps to demonstrate that the company is proactively addressing corruption risks. This is particularly strong for companies that have faced public corruption issues that have damaged their reputation in the eyes of the public, investors or potential employees.\n\nThird, many appreciated the chance to contribute to industry guidance that might become widely accepted standards or influence other standards down the road. Companies have an interest in making it realistic and feasible.\n\n### Can you recap the process?\n\nFirst we conducted a lot of background research, particularly looking into past corruption cases in the extractive sector to understand the problem we were trying to address. The analysis made clear the vulnerability of SOEs in diverse countries to corruption. We then spent some time considering who should be involved in the conversations, including which types of company and from which countries, and getting initial ideas and feedback from colleagues.\n\nAfter a few initial conversations with relevant stakeholders, we scheduled a first gathering to get feedback on the topic. Prior to the meeting, we discussed the project with many of the invited company representatives in order to provide adequate background. At that first meeting, held in December 2019, around 30 people from companies, academic institutions, NGOs, international organisations and other entities gathered to discuss new approaches to preventing corruption, with a focus on SOEs.\n\nDrawing on the discussions, we then identified five priority areas of business interactions between companies and SOEs that represented particularly high corruption risks – and importantly, where existing measures are not proving sufficient to mitigate them. We then held interviews with stakeholders on these topics, which helped us gather frank feedback on what’s working and what’s not in each area.\n\nThen, we organised five virtual, invitation-only workshops, one on each of the topics of focus. The workshops provided additional ideas regarding good practices and prevailing challenges, and created opportunities for companies and experts to share ideas on sensitive issues.\n\nNext came the drafting and ongoing consultations with the workshop participants and other stakeholders, including SOE compliance teams, representatives from risk advisory consultancies, anti-corruption experts and academics, and investors. We also consulted with international banks that do business with SOEs; these can provide valuable inspiration for companies seeking to strengthen their systems for conducting customer due diligence.\n\nDrawing on these inputs as well as additional research, we then drafted the guidance, shared it with the participants, and received a very robust set of feedback.\n\n### Were you seeking consensus?\n\nNo. Importantly, we were clear from the start that the guidance would be the product of _consultation_, but not _consensus_. As an independent organisation promoting transparency and accountability in natural resource governance, we knew we might put forward some more ambitious ideas that don’t have much support among private companies.\n\nThis is a different approach from that of the [Extractive Industries Transparency Initiative](https:\u002F\u002Feiti.org\u002F) (EITI), for example, which seeks consensus on its global standard. Civil society organisations sometimes also unilaterally publish recommendations.\n\nBoth approaches have merit, but we believe a middle way is appropriate in this case: the guidelines are informed by participants’ views and reflect what is realistic and feasible, but we are not asking companies to endorse or sign up to them all.\n\n### What are the prospects for widespread adoption, and how will you know?\n\nWe hope that, as a first step, some of the participating companies adopt elements of the guidance. We of course also hope to see widespread adoption by companies and SOEs in the sectors. That includes those not directly involved in the development of the guidance.\n\nThe participatory approach makes it more likely that companies and SOEs in the sectors will adopt the guidance. Many representatives were actively engaged in its development and can see the results of their contributions. Having been involved in the discussions, they can also understand why in some instances the final document doesn’t always reflect their views.\n\nThe consultation process also enabled us to build good working relationships, so we hope to get positive responses to our follow-up surveys on the impact of the guidance on policies and practices within the companies.\n\nOne difficulty with measuring the impact of the guidance is that companies rarely disclose information about their anti-corruption practices beyond high-level statements. We believe this is a missed opportunity. Many of those involved in the consultations are doing impressive work to mitigate corruption risks and strengthen their anti-corruption safeguards. They should be shouting this kind of thing from the rooftops.\n\n### What are potential obstacles?\n\nOne big barrier to adoption is the widespread concept of “risk appetite” in business, which weighs up potential financial rewards against financial and other risks, including corruption risks. If the deal is potentially very lucrative, it could tip the balance towards going ahead despite corruption risks that can harm the public interest.\n\nOur guidance seeks to address by encouraging companies to set clear upfront rules – red lines – on what they will not tolerate in any circumstances, even if the financial rewards are huge. But changing that ingrained risk appetite approach more generally is going to take a lot more than our guidance.\n\n### What lessons did you learn and what will you take forward?\n\nFirst, a thorough stakeholder mapping is helpful to gather an influential group of stakeholders.\n\nIn this case, we identified that we needed to reach out to more supplier companies, which have traditionally been left out of conversations around extractive sector transparency and governance. Stakeholder mapping doesn’t guarantee a perfect mix – our group leaned significantly towards North American, European and Australian companies – but successful Collective Action doesn’t require every single actor to be around the table.\n\nSecond, building trust between participants – who may be direct competitors – goes beyond basic elements such as confidentiality and anonymity.\n\nWe found it useful to clarify from the start that this guidance is NRGI guidance, not the result of consensus or something that companies will be asked to endorse. This helped to set expectations and gave participants the freedom and security to engage with the issues openly and in a good faith way. And that in turn encouraged more hesitant participants to do the same.\n\nThird, don’t be afraid to talk about sensitive issues – but to do it in an empirically grounded and evidence-based way.\n\nWe felt empowered by our research and data on corruption in the sector. These allowed us to ask pertinent questions, push back where needed and generate real debate. Without that expertise or evidence base, you are standing on much shakier ground.\n\nGoing forward, we see great potential for more multi-stakeholder discussion and potentially building Collective Action initiatives around specific issues within the guidance. For example, requirements that companies use third-party agents in particular markets, or around how to utilise beneficial ownership information and respond to political exposure in the supply chain.\n\n### Learn more\n\n*   Visit the [Anticorruption Guidance for Partners of State-Owned Enterprises](https:\u002F\u002Fresourcegovernance.org\u002Fsoe-anticorruption) website and view the [launch event](https:\u002F\u002Fyoutu.be\u002FG5NJ3Ryc7jM).\n*   Learn more about the work of the [NRGI](https:\u002F\u002Fresourcegovernance.org\u002F) in promoting good governance in oil, gas minerals.\n*   Learn more about [Collective Action at the Basel Institute](https:\u002F\u002Fbaselgovernance.org\u002Fcollective-action) and find resources, inspiration and event information on our [B20 Collective Action Hub](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub).","2022-03-14","how-a-participatory-approach-helped-the-nrgi-to-develop-effective-anti-corruption-guidance-for-oil-gas-and-mining-sectors-2198","How a participatory approach helped the NRGI to develop effective anti-corruption guidance for oil, gas and mining sectors","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F24d0505c-1b97-44b2-af4e-5b8c5f09923f?width=1000&height=650&format=webp&quality=80",[],[92,93],"Collective Action","Private Sector",[19],[96,100],{"tags_id":97},{"id":98,"name":99},804,"Natural resources",{"tags_id":101},{"id":102,"name":103},859,"Corruption risks",2198,[92,93],[19],[],[],[25,92],[],"2022-05-26T22:51:56.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-a-participatory-approach-helped-the-nrgi-to-develop-effective-anti-corruption-guidance-for-oil-gas-and-mining-sectors-2198",{"id":115,"body":116,"status":6,"type":10,"date":117,"slug":118,"title":119,"image":120,"countries":121,"topic":122,"activity":124,"tags":126,"nid":127,"topics":128,"activities":129,"authors":130,"images":131,"websites":132,"area":23,"programme":23,"language":23,"translations":133,"translation_of":23,"user_created":41,"date_created":134,"user_updated":42,"date_updated":8,"content":135,"link":136},9555,"_Why do so many jurisdictions score so poorly for the effectiveness of their anti-money laundering systems? What's the biggest problem - prevention or enforcement? Answer from our [Basel AML Index 2021 report](https:\u002F\u002Findex.baselgovernance.org\u002Fdownload): Ineffective systems are the general rule, but jurisdictions consistently score worse for prevention than for enforcement. Excerpt:_\n\n[Last year in our 2020 Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fbasel-aml-index-2020-released-today) we lamented jurisdictions’ consistently poor results in terms of the effectiveness of their anti-money laundering and counter financing of terrorism (AML\u002FCFT) systems. It is all too common for jurisdictions to have laws and institutions in place that are largely compliant with FATF Recommendations yet ineffective in practice.\n\nThe Wolfsberg Group, a Collective Action initiative of 13 global banks that develops frameworks and guidance on financial crime risks, reinforced our concerns in a June 2021 statement on [Demonstrating Effectiveness](https:\u002F\u002Fwww.wolfsberg-principles.com\u002Fsites\u002Fdefault\u002Ffiles\u002Fwb\u002FWolfsberg%20Group_Demonstrating_%20Effectiveness_JUN21.pdf):\n\n> “\\[L\\]argely in response to supervisory expectations, AML\u002FCFT risk assessments are focused on technical compliance with requirements rather than the effectiveness of the \\[financial institution’s\\] efforts to prevent and detect financial crime”.\n\nData on the effectiveness of AML\u002FCFT systems is drawn from Financial Action Task Force (FATF) Mutual Evaluation Reports. The FATF uses 11 “Immediate Outcomes” (IOs) to assess the effectiveness of AML\u002FCFT systems according to its 40 Recommendations.\n\nThe 11 IOs and the assessment methodology are detailed on the [FATF website](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Fmutualevaluations\u002Fdocuments\u002Feffectiveness.html).\n\n### Is there any sign of improvement in the figures for 2021?\n\nNot really. Based on the latest FATF data, the average score for effectiveness across all assessed jurisdictions is only 30%. That is two times lower than the average score for technical compliance with FATF Recommendations, which stands at 64%.\n\nWeak spots vary between jurisdictions, but overall they are as shown in the chart below:\n\nWeakest spots in the effectiveness of AML\u002FCFT measures globally\n\n### Are jurisdictions doing better at prevention or enforcement?\n\nIdeally, AML\u002FCFT systems need to be particularly effective at preventing money laundering from occurring. Enforcement remains of course important, and it must be effective. But relying too heavily on catching the criminals _post factum_ presents an unreasonable risk and also means that some damage invariably will remain.\n\nSo we should be asking if jurisdictions doing enough on the prevention side, or if they are too heavily focused on enforcement. To explore this question, we divided FATF data on effectiveness criteria (IOs, see chart above) into two categories:\n\nFATF indicators on the effectiveness of AML\u002FCFT systems\\* Prevention Enforcement IO1: Risk, policy and coordination IO7: Money laundering investigation and prosecution IO3: Supervision IO8: Confiscation IO4: Preventive measures IO9: Terrorist financing investigation and prosecution IO5: Legal persons and arrangements IO6: Financial intelligence (mainly enforcement) IO10: Terrorist financing preventive measures (mainly prevention)  \n\n_\\*Note that IO2 is not included as it refers to elements of both prevention and enforcement, while IO11 is not relevant to the topic._\n\nBased on an analysis of 112 jurisdictions assessed with the FATF's latest (fourth-round) methodology by 15 July 2021, the data shows that jurisdictions are less effective at preventing ML\u002FTF than at enforcing AML\u002FCFT measures. And this is in a context where performance for enforcement is unsatisfactory already.\n\n*   Globally, average effectiveness for prevention was 27%, compared to 31% for enforcement.\n*   Nineteen jurisdictions (17%) scored zero for the effectiveness of their preventive measures, compared to 12 jurisdictions (11%) for enforcement.\n*   Nine jurisdictions demonstrated zero effectiveness in both prevention and enforcement criteria. These are: Cape Verde, Democratic Republic of the Congo, Haiti, Mali, Mauritania, Mozambique, Pakistan, Uganda and Vanuatu.\n*   The UK and Spain are the only jurisdictions assessed so far to achieve scores of 67% or above for both prevention and effectiveness criteria.\n\nA regional perspective shows some variation, but the same overall story: When it comes to money laundering, jurisdictions seem to be more effective at enforcement than prevention.\n\nRegion Prevention average Enforcement average East Asia and Pacific 26% 32% Eastern Europe and Central Asia 37% 38% Latin America and Caribbean 25% 26% Middle East and Northern Africa 32% 40% North America 53% 56% South Asia 7% 13% Sub-Saharan Africa 5% 8% Western Europe and EU 37% 43%\n\nThat being said, it is a well known fact that measuring effectiveness in prevention is considerably more difficult than measuring effectiveness at enforcement, for which data and statistics are often available from law enforcement and judicial actions.\n\n### So what?\n\nThese findings should ring an alarm bell for policy makers. Jurisdictions should invest more resources in the prevention of ML\u002FTF, because a fire contained is always better than an arsonist caught when the house has burnt down. Although of course, the arsonists must also be caught and punished.\n\nWe are far from arguing that such an increase of resources for prevention should come at the detriment of enforcement. On the contrary, both sides clearly need a serious boost, except perhaps the boost for prevention needs to be even more serious than that for enforcement.\n\n### More from the Basel AML Index\n\n*   Find out about the Basel AML Index, view the latest Public ranking and find out whether your organisation is eligible for a free Expert Edition account at our brand new website: [index.baselgovernance.org](https:\u002F\u002Findex.baselgovernance.org\u002F).\n*   See the [Basel AML Index 2021 press release](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fbasel-aml-index-2021-4-things-holding-back-global-fight-against-money-laundering).","2021-10-05","how-effective-are-jurisdictions-at-preventing-money-laundering-insights-from-the-10th-basel-aml-index-2094","How effective are jurisdictions at preventing money laundering? Insights from the 10th Basel AML Index","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F9c489ac0-b4df-4771-a677-f371cc071104?width=1000&height=650&format=webp&quality=80",[],[123],"Anti-Money Laundering",[125],"Basel AML Index",[],2094,[123],[125],[],[],[25,125],[],"2022-05-26T22:52:25.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-effective-are-jurisdictions-at-preventing-money-laundering-insights-from-the-10th-basel-aml-index-2094",{"id":138,"body":139,"status":6,"type":10,"date":140,"slug":141,"title":142,"image":143,"countries":144,"topic":148,"activity":150,"tags":153,"nid":154,"topics":155,"activities":156,"authors":157,"images":158,"websites":159,"area":23,"programme":23,"language":23,"translations":160,"translation_of":23,"user_created":41,"date_created":161,"user_updated":42,"date_updated":8,"content":162,"link":163},9563,"_A guest blog by Elisabeth Danon, Legal Analyst, OECD Anti-Corruption Division._\n\nHow can governments in South East Europe partner with the vibrant business sector and civil society to help combat corruption?\n\nOECD experts and practitioners shared some novel ideas on this question at a two-day webinar on Collective Action – Building Alliances Against Corruption in South East Europe on 16 and 17 September.\n\nThe event convened the Collective Action community in South East Europe to take stock of the advancement of the project [Fair Market Conditions for Competitiveness in the Adriatic Region](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Finitiatives-database\u002Ffair-market-conditions-competitiveness-adriatic). This project is being conducted under the umbrella of the OECD South East Europe Regional Programme and is supported by the Siemens Integrity Initiative.\n\n### Improving business integrity in Serbia, Bosnia and Herzegovina, and Croatia\n\nThe three-year business integrity project aims to promote a level playing field and fair market conditions in Serbia, Bosnia and Herzegovina, and Croatia. All three countries have significant potential for strong and sustainable economic development, but are hampered by relatively high levels of perceived corruption.\n\nAmbitioning to be a multi-stakeholder initiative, the project gathers government officials, business representatives, civil society and academia to address country-specific drawbacks by applying international standards. It aims to: \n\n*   raise awareness about OECD standards and good practices of anti-corruption, integrity and fair competition for competitiveness with governments, business and civil society;\n*   build capacity and foster the implementation of concrete OECD recommendations with regard to the transparency and efficiency of anti-corruption and competition authorities; and\n*   promote the latest knowledge on international standards and practices in the area of anti-corruption and integrity for competitiveness in academic curricula.\n\nThe September webinar, which was part of a series of events organised in the context of the project, consisted of a plenary roundtable on _Instruments and Global Lessons for Implementing Collective Action_, and three country-specific roundtables on _Putting Collective Action Into Practice – Factors of Success__._\n\nPolicy practitioners and experts from OECD countries shared practical experiences in implementing policy reforms to strengthen fair competition and combat corruption across the economy and society.\n\nAmong the OECD-supported instruments presented as a way to create a fair and competitive playing field was the [High Level Reporting Mechanism (HLRM)](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Fhrlm).\n\n### How HLRMs can provide early and pragmatic resolutions to integrity issues\n\nThe HLRM, jointly developed by the OECD and the Basel Institute of Governance, is a reporting mechanism created to effectively address complaints of bribery solicitation and related practices that involve public officials. Upon receipt of a complaint, the HLRM triggers a process of rapid analysis and pragmatic response on the part of a government.\n\nExamples of different contexts can include:\n\n*   public procurement\n*   the issuance of commercial licenses\n*   tax refunds\n*   the release of goods by customs authorities.\n\nThe goal is to restore the status quo before a reported problem escalates further and to allow interactions between public and private stakeholders to proceed smoothly.\n\nThe HLRM can be customised according to the needs and reality of different countries – an essential feature of any Collective Action initiative. Representatives of the public sector, business, civil society and other stakeholders participate in its design and implementation.\n\nThe HLRM anticipates a whole-of-a-society approach to tackling corruption and enhancing public integrity as described in the [2017 OECD Recommendation of the Council on Public Integrity](http:\u002F\u002Fwww.oecd.org\u002Fcorruption\u002Frecommendation-public-integrity.htm). By providing a tool to companies facing solicitation of bribes, the HLRM can also contribute to the fight against foreign bribery, driven at the global level by the [OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions](https:\u002F\u002Fwww.oecd.org\u002Fcorruption\u002Foecdantibriberyconvention.htm).\n\nTo date, customised models of the HLRM have been deployed in Colombia and Argentina. During the roundtables, experts from the OECD and the Basel Institute on Governance provided insights on those existing models, and how the mechanism could be replicated in Serbia, Bosnia Herzegovina and Croatia, based on the priorities and specifies of each country.\n\nBy supporting Collective Action and implementing a HLRM, governments would be demonstrating their real commitment to the joint fight against corruption and their leadership in efforts to create a fair and clean business environment for all.","2021-09-22","how-collective-action-can-help-improve-business-integrity-in-south-east-europe-2101","How Collective Action can help improve business integrity in South East Europe","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fe7cc2427-74d4-4f32-91bf-ce308a599aca?width=1000&height=650&format=webp&quality=80",[145,146,147],7304,7305,7306,[92,149,93],"HLRM",[151,19,152],"Events","Partnerships",[],2101,[92,149,93],[151,19,152],[],[],[25,92],[],"2022-05-26T22:52:32.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-collective-action-can-help-improve-business-integrity-in-south-east-europe-2101",{"id":165,"body":166,"status":6,"type":10,"date":167,"slug":168,"title":169,"image":170,"countries":171,"topic":173,"activity":176,"tags":179,"nid":188,"topics":189,"activities":191,"authors":192,"images":194,"websites":195,"area":23,"programme":23,"language":23,"translations":196,"translation_of":23,"user_created":41,"date_created":197,"user_updated":198,"date_updated":199,"content":200,"link":201},9609,"The following summary reflects key messages emerging from the [Harnessing the intangible: enhancing integrity during crises](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002F25-march-oecd-knowledge-partner-event-enhancing-integrity-during-crises) Knowledge Partner session on 25 March 2021 at the 2021 OECD Global Anti-Corruption & Integrity Forum.\n\nHosted by the Basel Institute and moderated by Claudia Baez Camargo, Head of Public Governance, the event explored how practitioners could tailor approaches to strengthen integrity during an emergency response to counter recurrent social norms and informal practices.\n\nThe panel incorporated a wide range of perspectives from health, anti-corruption and behavioural research, featuring Dina Balabanova and Eleanor Hutchinson of the London School of Hygiene and Tropical Medicine, David Jackson of the U4 Anti-Corruption Resource Centre, and Ruth Persian of The Behavioural Insights Team.\n\n### Why aren’t traditional approaches to tackling corruption and promoting integrity working?\n\nA key takeaway from the session is that mainstream anti-corruption interventions focusing on accountability, transparency and law enforcement measures have not been as effective as we would like in combatting corruption.\n\nCould this be because we don’t make enough effort to understand the local context, social networks and power dynamics in the target countries as well as individual actors’ experience and motivation? A growing body of evidence suggests so.\n\nFor example, [recent research](https:\u002F\u002Fresearchonline.lshtm.ac.uk\u002Fid\u002Feprint\u002F4659908\u002F1\u002FACE-WorkingPaper014-NigeriaAbsenteeism-190916.pdf) carried out in Nigeria by the London School of Hygiene & Tropical Medicine reveals that the causes of absenteeism among Nigerian health workers are much more complex than one might expect. They encompass economic pressures, structural inefficacies and managerial\u002Forganisational dynamics, with the research also emphasising that these are shaped by sociocultural factors and political relationships.\n\nWithout a more nuanced analysis of how and why people behave as they do and the context in which they make decisions, laws and rules alone are unlikely to change the drivers of corrupt behaviour. Initiatives are increasingly focusing on improving health system governance, but thinking about the “upstream” social and political factors is essential.\n\nExploring social norms can offer insights into the drivers of unethical\u002Fcorrupt decision-making. For instance, the Basel Institute’s current [research project in Tanzania under the GI-ACE programme](https:\u002F\u002Face.globalintegrity.org\u002Fprojects\u002Ftanzhealth\u002F) shines a spotlight on, among other things, social norms related to returning favours or serving family members first. Health workers are put under pressure to make special concessions to their kinship or those who offer gifts. If people follow these informal rules, merely changing or strengthening laws or rules will not get rid of the underlying drivers of corruption or violations of integrity.\n\nThe message is clear: when designing interventions, it is critical to first understand the context, including what social norms are at play and which behavioural and structural barriers to behaviour change the different actors face.\n\n### Are we less rational than we think – and even worse in a crisis?\n\nTraditional economic thinking has assumed that human beings are rational agents acting according to an analytical, cost\u002Fbenefit analysis. In his best-selling book, _Thinking, Fast and Slow_, Daniel Kahneman referred to this as slow “System 2” thinking. In contrast, System 1 thinking is fast and automatic, and more susceptible to environmental influences and biases than we think.\n\nHowever, policies and systems are often designed with only System 2 in mind. Furthermore, in situations where decision-makers act under a lot of pressure and stress – as is the cases in crises –  evidence shows that System 1 is most likely to take over when making decisions.\n\nThis has to be taken into account when designing interventions. In the context of the Covid-19 pandemic, interventions could support medical staff and policy makers by simplifying how information is displayed and framed. For instance, a [study](https:\u002F\u002Fwww.bi.team\u002Fblogs\u002Fredesigning-hospital-prescription-charts-to-reduce-prescribing-errors\u002F) showed how changing how prescription instructions are framed can lead a significant reduction in prescription errors in UK’s National Health Service (NHS).\n\nIt seems likely that this finding can be generalised: by providing information at the right time and an easily accessible format and by simplifying decision-making, people working under a lot of stress are supported to take the right course of action.\n\n### Do crises amplify integrity issues? Or is “crisis” mode quite normal?\n\nThe pandemic has merely exacerbated the fact that health systems around the world are in a constant state of crisis, with regular shortages and understaffing. This generates different pressures on staff workers, with a direct link to integrity issues.\n\nOne issue relates to the political economy of a country. For instance, sanctioning health workers for corrupt behaviour if they enjoy political protection may lead to severe consequences – like job losses – for head of departments. An intervention that does not take this into account would do more harm than good.\n\nGendered norms and expectations also drive behaviour. In the case of absenteeism among Nigerian health workers mentioned above, for example, female nurses are often expected to juggle their shifts with family care and contribution to the household economy (e.g. farming).\n\nMerely changing rules or management without understanding people’s behaviour and the expectations they face in a complex system will not yield the expected results. As for political power, understanding how social and family networks are structured and operate is key to designing effective anti-corruption interventions.\n\n### Harnessing behavioural insights to drive change\n\nA solid [political economy analysis](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance\u002Ftechnical-assistance) will help build understanding among anti-corruption practitioners – but what should they do with that understanding? The next step is to understand how to use these insights into different networks to design more effective interventions. This is the idea behind another GI-ACE project led by the Basel Institute on [Harnessing Informality: Designing Anti-Corruption Network Interventions and Strategic Use of Legal Instruments](https:\u002F\u002Face.globalintegrity.org\u002Fwp-content\u002Fuploads\u002F2019\u002F09\u002FBC_ext_project.pdf).\n\nTo continue with the example of absenteeism among health workers, individuals who are negatively affected by this (more working hours, more pressure due to the added activities related to the Covid-19 responses) may be more likely to support an intervention to address the issue.\n\nSo, clearly identifying networks of allies with a reason to support a change in favour of integrity should be an essential step of any intervention.\n\n### How social norms affect behaviour – for better or for worse\n\nAnother interesting point raised during the session was how we all belong to different reference groups which form part of our identity. Social norms stem from these reference groups and influence our behaviours in different ways.\n\nWe follow descriptive norms because they relate to common behaviour, whereas we respect injunctive norms because we think that _others_ think these behaviours are socially appropriate. For example, assisting our family materially because we think that others perceive this as the right thing to do. \n\nThese last norms generate social pressure as we are scared by the social sanctions we would incur by violating them. Social norms become particularly salient during crises when, as mentioned above, System 1 thinking is likely to take over in stressful situations where actors need to make fast decisions under a lot of pressure.\n\nRather than changing social norms, perhaps the objective in the Covid-19 crisis and more generally should therefore be relieve individuals from the pressures generated by the norms.\n\nNorms of elites need careful consideration. Cases of decision-makers violating social distancing norms may make it permissible to violate health guidelines in the eyes of the public. However, research shows that trend-setters – i.e. people within groups leading by example by adopting virtuous behaviours associated with social norms (like respecting social distancing) – play an equally important role in changing undesirable behaviours associated with social norms. Revealing information about these virtuous behaviours within reference groups can incentivise others to change their own behaviour vis-à-vis a social norm.\n\nAnother option that requires careful consideration and handling – and a deep understanding of political economy, behaviours and norms – is for governments to publicly condemn corrupt behaviour using normative interventions, for example naming and shaming individuals who violated covid-19 regulations.\n\n### Can social norms be changed?\n\nSo: relieving individuals from the pressures generated by social norms is one avenue for intervention. Another common form of intervention aims to correct people’s incorrect perceptions of social norms. More drastically, perhaps some norms need to change in order to form the basis of a stronger, healthier and more resilient society. Is this possible?\n\nThe short answer that emerged at the session is yes. Three elements must be present:\n\n*   People need a reason to change.\n*   People must trust each other.\n*   A mechanism must be in place to let change occur (e.g. a civic space).\n\nThis implies that changing social norms to encourage integrity is a collective effort. It is also an immensely challenging one – but nonetheless essential if we wish to enhance integrity during crises as well as during “business as usual”.\n\n### Learn more\n\n*   Read more about our Public Governance team’s [research on social norms and related factors here](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance\u002Fresearch-projects).\n*   Learn more about the UK-funded Anti-Corruption Evidence (ACE) programme and its two components: [SOAS-ACE](https:\u002F\u002Face.soas.ac.uk\u002F) (led by SOAS University of London) and [GI-ACE](https:\u002F\u002Face.globalintegrity.org\u002F) (led by Global Integrity).\n*   Read a publication on the [London School of Hygiene & Tropical Medicine (LSHTM)](LSHTM)  website by Dr Dina Balabanova (LSHTM), Professor Obinna Onwujekwe (University of Nigeria) and Dr Eric Umar (University of Malawi) on [Understanding and eliminating health sector corruption impeding UHC at district level in Nigeria and Malawi: institutions, individuals and incentives](https:\u002F\u002Fwww.lshtm.ac.uk\u002Fresearch\u002Fcentres-projects-groups\u002Funderstanding-and-eliminating-health-systems-corruption).\n*   Watch a [video recording of the session on YouTube](https:\u002F\u002Fyoutu.be\u002FffVS76k4qNg).","2021-04-14","how-to-enhance-integrity-during-crises-lessons-from-behavioural-science-2008","How to enhance integrity during crises: lessons from behavioural science","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F82be3e12-2443-4f36-b39b-0141a42f1473?width=1000&height=650&format=webp&quality=80",[172],7343,[174,175],"Prevention"," Research and Innovation",[151,17,19,177,178],"Anti-corruption interventions","Presentations",[180,184],{"tags_id":181},{"id":182,"name":183},848,"Behavioural science",{"tags_id":185},{"id":186,"name":187},1381,"Health",2008,[190],"Prevention Research and Innovation",[151,17,19,177,178],[193],1196,[],[25],[],"2022-05-26T22:53:12.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-07T21:29:42.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-to-enhance-integrity-during-crises-lessons-from-behavioural-science-2008",{"id":203,"body":204,"status":6,"type":10,"date":205,"slug":206,"title":207,"image":208,"countries":209,"topic":211,"activity":212,"tags":213,"nid":218,"topics":219,"activities":220,"authors":221,"images":222,"websites":223,"area":23,"programme":23,"language":23,"translations":224,"translation_of":23,"user_created":41,"date_created":225,"user_updated":42,"date_updated":8,"content":226,"link":227},9640,"This case study and Q&A looks at a recent UK Business Integrity Initiative-funded project in Ghana to create and implement 10 service delivery charters for government licensing and approval authorities through a Collective Action approach. The project was carried out by the [Ghana Integrity Initiative](https:\u002F\u002Fwww.tighana.org\u002F), which is the local chapter of Transparency International, in collaboration with the [Private Enterprise Federation](https:\u002F\u002Fwww.pef.org.gh\u002Findex.php\u002Fen\u002F).\n\n### What is the idea behind service delivery charters?\n\nService delivery charters (SDCs) are tools meant to close the critical knowledge gap between service providers and service users. The paradigm example is this:\n\n> A citizen or businessperson goes into the local vehicle authority office and requests a replacement driving licence, a process that should cost 100 cedis and take one week. “It will take 4 weeks and cost 200 cedis,” says the official, “but I can arrange it more quickly if you pay me an express fee.”\n\nHow can someone in that situation demand compliance if they do not know what they should expect from a government service provider and what they can demand? Time and again, our assessments have shown that this kind of systemic knowledge imbalance opens up opportunities for corruption.\n\nThe basic idea behind service charters is to close that knowledge gap. But to us, more important than the document is the conversations that take place between the different stakeholders. We didn’t start this project with the aim of creating 10 pieces of paper, but of getting more businesses to engage openly and productively with public institutions on integrity issues.\n\n### Who benefits and how?\n\nIn theory, service delivery charters are a win-win-win tool. Citizens and businesses receive enhanced standards of service, including faster turnaround times and standard and predictable pricing. They are less likely to be asked to pay extra “fees” for regular services, increasing trust in institutions.\n\nAnother benefit from the government’s perspective is that if services are provided properly and on time, then productivity increases.\n\n### Tell us about SDCs in practice\n\nGhana’s [Commission on Human Rights and Administrative Justice](https:\u002F\u002Fchraj.gov.gh\u002F) (CHRAJ) had already developed a template service delivery charter, or “client service charter” as it was known, in collaboration with the Public Sector Reform Secretariat. But there were challenges in implementing the idea effectively.\n\nOne barrier to implementation that we noted is a lack of capacity in government authorities. Our approach therefore includes support for building this capacity through a sustainable “train the trainer” model plus a written manual.\n\nAnother barrier is getting buy-in from all sides: high-level politicians, the officials in charge of providing the services, and the citizens and businesses that use them. This is why we need a Collective Action approach that encourages dialogue and fosters mutual understanding.\n\nOur goal was not just to create and roll out the charters, but to get more businesses to engage with public institutions on integrity issues.\n\n### Why the focus on business-government dialogue?\n\nAs a local chapter of Transparency International, the Ghana Integrity Initiative is a civil society organisation that works towards reducing corruption in our country. We see that the biggest users of government services – and therefore those most often exposed to corruption – are businesses that interact with authorities to obtain licences, permits, vehicle registrations, etc.\n\nTo better understand the needs and experiences of businesses in Ghana, and to get them actively involved in this Collective Action, we partnered with the Private Enterprise Federation (PEF). The PEF is a non-profit, non-political, independent apex business association. It represents the majority of various umbrella Ghanaian business associations and chambers that are constituted by individual businesses.\n\n### Can you take us through the process of developing an SDC?\n\nWe took the CHRAJ’s template charter as a base and worked collaboratively to enhance it, drawing in expertise to make sure it better reflects Ghana’s legislative frameworks for service delivery and related institutional arrangements. We also studied best practices in comparison to what was really happening on the ground.\n\nThe next stage involved a gap analysis, in which we visited the authorities, assessed the various services they offered and established the “value chain” of each service from start to finish. We invariably found gaps, which we discussed in detail at a meeting with the heads of each authority. How can we close these gaps? And how can we then codify them back into the service charter?\n\nWe found both the private-sector representatives and the government counterparts to be proactive and interested throughout the process. Some officials added extra provisions to the charter and made suggestions to improve it. They also told their counterparts in other government departments about our joint work, and we started to receive further requests for support outside the original scope of the project. A good sign, I think, that the project provided value.\n\nThe moment of truth was bringing the private and public sector representatives together in a meeting to validate the final document and tie up any loose ends. Facilitating such a meeting requires great sensitivity and an understanding of how to build trust between the groups.\n\n### Roll-out and communication  what is the plan?\n\nAt the very least, the service delivery charters will be put up at the point of service delivery. The Federation will also inform those members who have not been involved in the project until now.\n\nOn the government side, the Minister for Public Service Reform was due to launch the charters earlier this year. This was disrupted due to the pandemic. High-level endorsement of anti-corruption tools is important, so we hope this will still go ahead shortly despite the disruption caused by the elections this month.\n\nWith additional funding support, we would be able to roll them out through the media, such as radio talk shows where service providers and users discuss the charters and what value they bring. Short messages and information campaigns on social media also have a lot of potential to inform local citizens.\n\n### And then?\n\nFirst we want to make sure they continue to be implemented and effective in practice. The authorities can expect some “mystery clients”…\n\nSecond, we’d like to them to be codified into law. This would add teeth to the charters by making them legally enforceable.\n\nThird, we would like to expand the project and roll it out to more institutions, particularly at the subnational level, as this is where most people actually interact with service providers. Given the higher levels of illiteracy outside of the nation’s capital Accra, this would need to go hand in hand with greater support for local people and businesses in monitoring service delivery as well as budgets and procurement.\n\n### Any final message to fellow anti-corruption practitioners?\n\nYou don’t always need to reinvent the wheel, you need to make the wheels you have roll faster and better. In other words, it’s important that existing transparency and anti-corruption mechanisms are actually implemented effectively and sustainably.\n\nAnd the best way to do this is through a Collective Action approach that gets all sides around the table, talking, understanding each other, building trust and buying in to the benefits.\n\n_You can find this project and 260+ other anti-corruption Collective Action projects on the database of the [B20 Collective Action Hub](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub)._\n\n### About the UK Business Integrity Initiative and Challenge Fund\n\nThe UK's Business Integrity Initiative Challenge Fund was launched to support innovative, business-focused, Collective Action initiatives aiming at reducing corruption or promoting human rights to improve the investment climate in emerging markets and developing countries. IMC Worldwide has been working closely with the UK Foreign, Commonwealth and Development Office (FCDO) as the Business Integrity Initiative Challenge Fund Manager. [Find out more](https:\u002F\u002Fmedium.com\u002Fbusiness-integrity-initiative-challenge-fund\u002Fintroducing-the-challenge-fund-5db5e337932a).\n\nThe UK Business Integrity Initiative previously supported a project of the Basel Institute to provide training and guidance packages to small- and medium-sized businesses on anti-corruption compliance, corruption and bribery prevention, and anti-corruption Collective Action. Although the subsidies have now ended, the Basel Institute continues to provide these cost-effective and tailored packages to interested SMEs all over the world. [Find out more](https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F892).","2020-12-15","how-service-delivery-charters-in-ghana-are-creating-dialogue-between-citizens-businesses-and-government-1946","How service delivery charters in Ghana are creating dialogue between citizens, businesses and government","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc6d48e64-7957-4c25-a43d-59428d5b02f7?width=1000&height=650&format=webp&quality=80",[210],7361,[92,93],[177,152],[214],{"tags_id":215},{"id":216,"name":217},1378,"Public financial management",1946,[92,93],[177,152],[],[],[25,92],[],"2022-05-26T22:53:39.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-service-delivery-charters-in-ghana-are-creating-dialogue-between-citizens-businesses-and-government-1946",{"id":229,"body":230,"status":6,"type":10,"date":231,"slug":232,"title":233,"image":234,"countries":235,"topic":237,"activity":239,"tags":240,"nid":245,"topics":246,"activities":247,"authors":248,"images":250,"websites":251,"area":23,"programme":23,"language":23,"translations":252,"translation_of":23,"user_created":41,"date_created":253,"user_updated":198,"date_updated":254,"content":255,"link":256},9658,"Our recent policy brief on [Curbing wildlife trafficking in Uganda: lessons for practitioners](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpolicy-brief-5-curbing-wildlife-trafficking-uganda-lessons-practitioners) summarises the main findings from extensive field research on the drivers, facilitators and strategies of wildlife trafficking in Uganda.\n\nThe first question took a behavioural lens to the question of [_why_ Uganda has become a hub for wildlife trafficking](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fwildlife-trafficking-uganda-poverty-governance-and-perceptions) in East Africa. The second question looks at _how_ wildlife trafficking happens in Uganda. \n\nThe research evidence suggests that coordination, concealment and corruption are the three basic ingredients of the trafficking networks’ modus operandi in Uganda.\n\n### A top-down, orchestrated supply chain\n\nPoverty and weak rule of law generate incentives for diverse groups of people to respond to the demand for wildlife products. And while the supply of wildlife products can be established opportunistically from the bottom up, this is not the predominant characterisation of how large volumes of products are sourced in the region. Rather, the findings suggest that wildlife products are procured, handled and transported through a top-down, orchestrated and organised supply chain. \n\nFour key functional roles sustain this supply chain in Uganda and the region, connecting poachers and local middlemen around wildlife habitats to urban middlemen and buyers in the larger towns and cities. While at its higher echelons there is a need to develop long-term relationships of trust, as one moves to the grassroots the trafficking networks can rely on a large supply of willing accomplices to support their operations.\n\nThe number of network members, their relative roles, the nature of the collaboration, the relative distance between them and their physical bases can all differ. The research suggests that this fluid shape and dynamic structure of the network forms the backbone of a strategic infrastructure of cooperation that facilitates wildlife trafficking. \n\n### Border crossings – who helps, who turns a blind eye?\n\nHidden in backpacks, back seats of cars, inside fuel trucks and military trucks or whatever other creative strategy is employed, wildlife products can enter Uganda both through official and unofficial border crossings. The wildlife products find their way from border towns to Kampala where they are consolidated, concealed and cleared for export in preparation for long-haul transport. The research suggests that products most frequently are trafficked out of Uganda via road towards the port of Mombasa in Kenya or via air out of Entebbe Airport. At the same time, the attractiveness of particular routes is not static but changes and adapts to the conditions on the ground.  \n\nAlong the chain, the trafficking networks are frequently aided by private sector agents, from customs clearing agents and freight forwarders, who help cover up their illicit transport activities, to individuals working at banks and other financial institutions, who work to keep their ill-gained profits from being detected.\n\nWhile concealment is necessary, it is not sufficient to manage the trafficking of high volumes of wildlife products out of Uganda. It is here where corrupt relationships with public officials come in. \n\n### One-off bribes vs long-term relationships\n\nSuch relationships are varied and multifaceted, as the research suggests. For instance, corruption can be a one-off problem-solving strategy, for example to secure the release of a trafficker who has been caught red-handed. However, public officials are not only bribed when the network hits a snag in their operation. In other cases, they may be proactively and strategically co-opted to prevent the law enforcement chain from being activated in the first place. \n\nThe research evidence suggests that this selective co-optation of useful and strategic individuals into the trafficking network – alongside elaborate concealment techniques – facilitates the trafficking of large volumes of wildlife products into, through and out of Uganda.\n\nThe research evidence is not strong enough to establish how widespread such bribery practices are. However, indications that trafficking networks strategically target and co-opt key public officials through bribes shed light on some of the factors undermining the effectiveness of important enforcement measures in place to fight wildlife trafficking. Trafficking networks therefore capitalise on a governance context with high levels of corruption that offers opportunities for illegal activities to flourish.\n\nAs the image in this post illustrates, the law enforcement system offers many entry points to opportunistically corrupt public officials and thereby cripple its operation along the trafficking route.\n\n### Systematic corruption to evade law enforcement at every step\n\nCorruption therefore undermines a crucial first step to fighting wildlife trafficking, namely, the detection of wildlife animal trafficking. According to the research findings, the reasons why those with monitoring powers might turn a blind eye are varied. They might have been bribed to do so but they might also decide not to seize illicit or suspect shipments if they believe that a powerful figure is involved. \n\nSuch elements can impact the entire law enforcement chain, from border police, wildlife authority staff, customs officials and prosecutors to judges. Furthermore, without detection, there is no investigation, arrest, prosecution or sanctioning. \n\nIn sum, the strategic use of corruption to evade the law enforcement framework and facilitate the trafficking of high volumes of wildlife products make Uganda, in the words of many research participants, the “path of least resistance”. \n\n### Learn more\n\n*   [Download the full policy brief here.](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpolicy-brief-5-curbing-wildlife-trafficking-uganda-lessons-practitioners)\n*   Read [Working Paper 33: A worm’s-eye view of wildlife trafficking in Uganda – the path of least resistance.](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fworking-paper-33-worms-eye-view-wildlife-trafficking-uganda-path-least-resistance)\n*   Find out more about our [Public Governance team](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance) and their current [research projects](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance\u002Fresearch-projects).\n*   Learn more about the [Basel Institute's Green Corruption programme](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption), including our two-year PMI Impact-funded project to prevent corruption from fuelling illegal wildlife trade along the East Africa - South East Asia route. We are grateful to PMI Impact for funding this valuable research.","2020-11-18","how-organised-crime-networks-and-corruption-facilitate-illegal-wildlife-trade-in-uganda-1908","How organised crime networks and corruption facilitate illegal wildlife trade in Uganda","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Feb52492b-e59e-4e9d-981d-d211da60e6d6?width=1000&height=650&format=webp&quality=80",[236],7381,[238,174,175],"Green Corruption",[17,18],[241],{"tags_id":242},{"id":243,"name":244},1303,"Environment",1908,[238,190],[17,18],[249],1206,[],[25],[],"2022-05-26T22:53:54.000Z","2026-05-07T21:29:43.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-organised-crime-networks-and-corruption-facilitate-illegal-wildlife-trade-in-uganda-1908",{"id":258,"body":259,"status":6,"type":260,"date":261,"slug":262,"title":263,"image":264,"countries":265,"topic":266,"activity":267,"tags":268,"nid":269,"topics":270,"activities":271,"authors":272,"images":273,"websites":274,"area":23,"programme":23,"language":23,"translations":275,"translation_of":23,"user_created":41,"date_created":276,"user_updated":277,"date_updated":278,"content":279,"link":280},9686,"A new case study from our compliance team shows how tailored support for anti-corruption compliance can help innovative small businesses succeed even in challenging markets.\n\nIt describes the Basel Institute's compliance guidance to Vero Power, a small UK company that designs, builds, owns and operates renewable-based energy systems in rural locations in Southern Africa. Vero Power's low-cost systems have the potential to provide countless communities with crucial access to clean, reliable energy for the first time. Yet there are potentially corruption risks involved in some of the business opportunities that the company is considering.\n\nSee the [Vero Power case study](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-09\u002FVero%20compliance%20case%20study.pdf) to understand how the company leadership approached the need to develop a compliance programme and the guidance and support that our compliance advisors were able to offer.\n\nChief Operating Officer Paul Chester commented:\n\n> The training and advice provided by the Basel Institute on Governance has been first class. As a small UK business working in the energy access space on the other side of the world it is imperative that we, and our partners, conduct ourselves in an ethical manner at all times. The support provided by Gemma Aiolfi and team at the Basel Institute has laid the foundations for Vero Power to deliver more projects that have a truly transformational impact for the communities that they serve.\n\nThe guidance was provided with financial support from the UK Business Integrity Initiative. This programme has now come to an end, but the Basel Institute continues to offer tailored guidance and training on anti-corruption compliance, bribery prevention and Collective Action to SMEs.\n\n### Learn more\n\n*   Read about the Basel Institute's [compliance guidance services for SMEs](http:\u002F\u002Fwww.baselgovernance.org\u002Fcompliance\u002Fsme-guidance-services) and how to apply.\n*   Search packages on [Basel Open Intelligence](https:\u002F\u002Fwww.baselgovernance.org\u002Fbasel-open-intelligence), a tool that helps compliance officers with open-source research and due diligence, are half price for SMEs and public\u002Fnon-profit organisations.","News","2020-09-07","how-anti-corruption-compliance-boosts-business-opportunities-for-a-small-renewable-energy-company-1843","How anti-corruption compliance boosts business opportunities for a small renewable energy company","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fa707ae7e-7ba3-411f-9234-3ce926748137?width=1000&height=650&format=webp&quality=80",[],[93],[14],[],1843,[93],[],[],[],[25],[],"2022-05-26T22:54:18.000Z","dfef11db-1bc6-47e9-a61d-93443995484b","2026-05-08T21:11:04.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-anti-corruption-compliance-boosts-business-opportunities-for-a-small-renewable-energy-company-1843",{"id":282,"body":283,"status":6,"type":260,"date":284,"slug":285,"title":286,"image":287,"countries":288,"topic":289,"activity":291,"tags":293,"nid":294,"topics":295,"activities":297,"authors":298,"images":299,"websites":300,"area":23,"programme":23,"language":23,"translations":301,"translation_of":23,"user_created":41,"date_created":302,"user_updated":198,"date_updated":303,"content":304,"link":305},9688,"Basel Institute on Governance Managing Director Gretta Fenner moderated a discussion on _Finding stolen assets – the role of transparency and proactive measures in developed countries_ at the new Global Forum on Illicit Financial Flows and Sustainable Development series. Hosted by Germany and Norway, the event takes place over two days starting 2 September 2020.\n\nSpeakers from the World Bank \u002F UNODC Stolen Asset Recovery Initiative, Germany and Tunisia explored what needs to be done in countries that serve as transition or destination countries of stolen assets. How are these countries able to contribute more to global asset recovery efforts?\n\n### Key points\n\n1\\. Anti-money laundering and counter financing of terrorism (AML\u002FCFT) frameworks in financial centres around the world are still much too weak.\n\nThis is both in terms of effective enforcement and underlying regulations\u002Finstitutional set-ups. These weaknesses provide criminals with excellent “get-away cars” in the form of opportunities to launder, hide and re-invest their assets with little risk of being detected.\n\nIn order to enhance the capacity of law enforcement to better detect and trace stolen assets, it was recommended that domestic AML\u002FCFT regulations need to address the challenges arising from legal professional privilege on the one hand, and corporate secrecy on the other hand.\n\nThis is because both act as effective veils to financial crime. We are seeing some momentum regarding corporate secrecy around the establishment of beneficial ownership registries. However, the crux of the matter, namely how to verify whether the information in the registries is correct, is still not resolved. Lawyer groups are so far very successful in lobbying against any changes to their professional privileges.\n\n2\\. AML\u002FCFT regimes and investigation tools do not sufficiently take into account the fact that methods for detecting stolen assets vary depending on the role of a jurisdiction in the laundering process. \n\nOne such weakness identified during the panel was that so-called “destination jurisdictions”, i.e. where laundered assets are ultimately placed, do not always have or effectively use centralised registries for key placement opportunities, such as real estate or corporations. This relates to the above point on beneficial ownership. This weakness severely restricts the capacity for proactive investigation, which could provide key information for detecting and recovering stolen assets in requesting and requested states alike.\n\n3\\. Financial centres need to do more to proactively identify and investigate stolen assets located in their jurisdictions. \n\nThe discrepancy between assets that are stolen and assets that are found is far too large for it to be credible that such small amounts of assets are effectively found in major financial centres. This is true even if we deduct stolen assets that may have already been spent and re-invested.\n\nFinancial centres often do not prioritise international corruption and money laundering cases because they are considered too complex and time consuming. Meanwhile, prosecuting services in most countries are overwhelmed with work. It is therefore imperative that financial centres invest more in relevant law enforcement capacity. This needs to be coupled with strong messaging from the highest level of political leadership that tackling illicit financial flows is a top priority. In addition, law enforcement in financial centres would benefit from additional legal tools, such as the introduction of the reversal of the burden of proof for a specific set of crimes.\n\nMore resources will also lead to more responsiveness of financial centres in the context of international cooperation, which is still insufficient and far too slow to tackle a 21st-century crime. Challenges for requesting states to tackle complex international cases include:\n\n*   disparities between legal systems and legislative frameworks governing international cooperation;\n*   limited experience in tracing assets in most countries, even those with advanced enforcement systems;\n*   human rights thresholds for executing mutual legal assistance (MLA) requests and maintaining freeze orders.\n\nGreater efforts are also needed to further harmonise the legislative framework governing international cooperation. Requesting states are overwhelmed when having to deal with multiple jurisdictions in parallel. \n\n4\\. The management of restrained assets is a concern.\n\nParticipants suggested analysing whether development banks or centrally managed escrow accounts could be used to ensure that such assets are protected and well managed.\n\n### About the Global Forum on IFF and Sustainable Development\n\nToday’s event was the first in a new series hosted by the [German Federal Ministry for Economic Cooperation and Development](https:\u002F\u002Fwww.bmz.de\u002Fen\u002F) (BMZ) and the [Norwegian Ministry of Foreign Affairs](https:\u002F\u002Fwww.regjeringen.no\u002Fen\u002Fdep\u002Fud\u002Fid833\u002F) and organised by the [Deutsche Gesellschaft für Internationale Zusammenarbeit](https:\u002F\u002Fwww.giz.de\u002Fen\u002Fhtml\u002Findex.html) (GIZ).\n\nThe aim of the Forum is to establish dialogue across stakeholders, countries, regions and sectors on the following question: _How can measures and policies to combat illicit financial flows can have the greatest possible impact on the advancement of SDG 16.4 without adversely affecting other goals of the sustainable development agenda?_\n\n### Further reading\n\n*   See a description of a 2019-2022 programme on [Combating Illicit Financial Flows](https:\u002F\u002Fwww.giz.de\u002Fen\u002Fworldwide\u002F39748.html) commissioned by the BMZ and Norwegian Ministry of Foreign Affairs.\n*   View a study on [Stolen Asset Recovery Between Germany and Developing Countries](https:\u002F\u002Fcifar.eu\u002Fwp-content\u002Fuploads\u002F2019\u002F06\u002F1.-English-Report-2019-Asset-recovery-Germany.pdf) commissioned by BMZ and GIZ and published in 2019 by the Civil Forum for Asset Recovery (CiFAR).","2020-09-03","how-developed-countries-can-support-asset-recovery-for-sustainable-development-1841","How developed countries can support asset recovery for sustainable development ","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fbd1ee675-4772-4b18-9c07-1e4c164e636d?width=1000&height=650&format=webp&quality=80",[],[123,290],"Asset Recovery",[151,178,152,292],"International cooperation",[],1841,[123,296],"Asset Recovery and Enforcement",[151,178,152,292],[],[],[25],[],"2022-05-26T22:54:19.000Z","2026-05-29T22:21:49.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-developed-countries-can-support-asset-recovery-for-sustainable-development-1841",{"id":307,"body":308,"status":6,"type":10,"date":309,"slug":310,"title":311,"image":312,"countries":313,"topic":314,"activity":315,"tags":316,"nid":317,"topics":318,"activities":319,"authors":320,"images":322,"websites":323,"area":23,"programme":23,"language":23,"translations":324,"translation_of":23,"user_created":41,"date_created":325,"user_updated":198,"date_updated":326,"content":327,"link":328},9715,"In the third article in our series of perspectives on illegal wildlife trade (IWT) and financial crime, produced in collaboration with the [International Academy of Financial Crime Litigators](https:\u002F\u002Fwww.financialcrimelitigators.org\u002F), Gretta Fenner explores the role of asset recovery in combating wildlife trafficking.\n\nShe asks: Should assets recovered from corrupt practices linked to wildlife trafficking be channelled into conservation and counter-IWT enforcement efforts? What are the pros and cons, and have there been any examples of this type of strategy?\n\nGretta Fenner is a Founding Fellow of the International Academy of Financial Crime Litigators and the Basel Institute acts as its Secretariat.\n\nCan asset recovery support the fight against illegal wildlife trade?\n====================================================================\n\n### The short answer: yes\n\nIt seems fair to use assets recovered from convicted criminals to benefit the victims of their crimes. This helps make up for the damage they suffered. It also makes sense to use recovered assets to prevent similar crimes from occurring in the future.\n\nSo yes, assets recovered from corrupt practices linked to wildlife trafficking should in many cases – though of course not all – be channeled into conservation and counter-IWT enforcement efforts.\n\n### Putting recovered funds to good use\n\nThere are precedents in other areas of asset recovery. For example, money stolen from Peru and recovered from bank accounts in Luxembourg and Switzerland is now being used to strengthen Peru’s asset recovery system. That stolen money is paying for investments in electronic case management systems and in building a strong asset recovery team – both of which will help the country investigate and prosecute cases of grand corruption in the future.\n\nTranslated into the world of illegal wildlife trade (IWT), this means using recovered assets to empower IWT enforcement agencies. We would put a strong emphasis not only on anti-poaching measures but on developing their financial investigation skills and ability to bring money laundering cases against the highest-level traffickers and facilitators. Hitting these criminals where it hurts most – in their finances – is a [powerful tool to interrupt illegal trade](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fgretta-fenners-quick-guide-financial-crime-illegal-wildlife-trade).\n\n### Stolen assets for sustainable development\n\nRecovered assets could also be used to invest in socio-economic development of communities exposed to IWT. For example, building tourism and agricultural infrastructure in these areas will give more poachers a viable and legitimate way to provide for their families – because as our research team is uncovering, the [reasons why people turn to poaching and trafficking](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fsaba-kassas-quick-guide-drivers-and-facilitators-wildlife-trafficking) are not as simple as they seem.\n\nIn any case, it is critical that recovered assets from IWT or other crimes don’t just disappear into the black hole of public coffers. They should be used in such a way that people see a tangible value in fighting the crime both on the ground and in the financial sphere, where the high-level criminals and corrupt actors lurk.\n\n_To view the alternative perspective on this topic by_ _Keith Oliver, Head of International at Peters & Peters Solicitors LLP together with his colleague Amalia Neenan, Legal Researcher,_ _see [The Academy's website](https:\u002F\u002Fwww.financialcrimelitigators.org\u002Fnode\u002F156) or [download the PDF](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-06\u002FPerspectives3_AssetRecoveryandIWT.pdf)._ _Keith Oliver is a Founding Fellow of The International Academy of Financial Crime Litigators._","2020-06-30","how-asset-recovery-can-support-the-fight-against-wildlife-trafficking-1789","How asset recovery can support the fight against wildlife trafficking","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F4255df79-6c59-4dd6-acb9-ab2d5b25a63f?width=1000&height=650&format=webp&quality=80",[],[290,238],[19],[],1789,[296,238],[19],[321],1224,[],[25],[],"2022-05-26T22:54:42.000Z","2026-05-29T22:21:51.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-asset-recovery-can-support-the-fight-against-wildlife-trafficking-1789",{"left":330,"top":330,"width":331,"height":331,"rotate":330,"vFlip":332,"hFlip":332,"body":333},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>",1780676502572]