[{"data":1,"prerenderedAt":282},["ShallowReactive",2],{"news-new-training-on-illicit-enrichment-rolled-out-in-malawi-2670":3,"news-new-training-on-illicit-enrichment-rolled-out-in-malawi-2670-similar":41,"i-heroicons:arrow-left-20-solid":277},[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":35,"tags":36,"authors":37,"images":38,"translations":39,"content":40},10478,"published","2024-08-29T10:01:36.000Z","2026-05-08T21:11:11.000Z","New training on illicit enrichment rolled out in Malawi","News","Our International Centre for Asset Recovery (ICAR) has launched a new [training programme](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) on illicit enrichment.\n\nDelivered for the first time in Malawi to 33 practitioners from a range of government agencies, the programme is designed to help practitioners gain the knowledge and skills to investigate and prosecute cases of unexplained wealth in line with local legislation and to recover any unjustified assets.\n\nOur training team designed the new programme in response to the introduction of illicit enrichment legislation in various countries as a valuable tool in the fight against corruption. The programme builds on the Basel Institute’s extensive research on this topic – see our [free book on Illicit Enrichment](https:\u002F\u002Fillicitenrichment.baselgovernance.org\u002F) by Andrew Dornbierer – and on the hands-on experiences of our ICAR staff working with law enforcement practitioners around the world.\n\n### Illicit enrichment offences: great potential...\n\nIllicit enrichment offences (also known as the possession of unexplained or unjustified wealth) typically target public officials who cannot reasonably justify the maintenance of a lifestyle or the possession of property which is incommensurate with their lawful income.\n\nA major rationale for targeting unexplained wealth is that corruption offences such as bribery are often difficult to prove beyond reasonable doubt and\u002For to link directly to particular assets. Although laws vary widely between countries, illicit enrichment legislation has the benefit that it generally does not require proof of specific underlying criminal conduct to establish that the offence of illicit enrichment has been committed.\n\nInstead, courts only need to be satisfied that a person is enjoying an amount of wealth that is not justified by reference to their legal income. As a result, it is a powerful enforcement tool. It also enables the recovery of assets arising from corruption.\n\n### … but underutilised\n\nThierry Ravalomanda, Head of Training ICAR, explains that:\n\n> Despite its clear potential, the offence of illicit enrichment remains largely underutilised. Reasons for this include legal challenges, such as concerns about infringing upon the presumption of innocence and the right to a fair trial, and the difficulties of international cooperation, particularly when meeting dual criminality requirements. These complexities have made many jurisdictions hesitant to fully enforce this offence.\n\nFor example, although Malawi criminalised illicit enrichment in 2004, and although the law has been tested in court and generated some jurisprudence, it remains underutilised. Thierry emphasises that:\n\n> Continued training and strategic support will help to ensure that illicit enrichment legislation is utilised more effectively in Malawi and in other jurisdictions.\n\nThe strategic support includes hands-on mentoring of Malawian officials by ICAR’s financial investigation and asset recovery specialists.\n\n### Trainings respond to enforcement challenges\n\nThe first edition of this new programme brought together practitioners from Malawi's Anti-Corruption Bureau, Financial Intelligence Authority, Malawi Revenue Authority, Police, Judiciary, Office of the Director of Public Prosecutions and Office of the Director of Public Officers’ Declarations.\n\nParticipants worked together in cross-agency task teams to enhance their knowledge of the illicit enrichment offence as it appears in Malawi’s anti-bribery legislation. They also improved their technical skills in conducting source and application of funds analysis and net worth analysis as alternative ways to calculate unjustified income – skills that they and others can practise in our [free eLearning course](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=17).\n\nParticipants gave positive feedback, with one stating that:\n\n> “The training has exceeded my expectations and enhanced my analytical and investigation skills. Going forward, I believe I will produce fact-based reports that will help when dealing with unexplained wealth\u002Fillicit enrichment investigations.\n\nThe value of peer learning was also raised, with the hope that:\n\n> future training involve participants from several countries so that we can learn and exchange experiences from different jurisdictions.\n\nThe training was funded by the UK Foreign, Commonwealth and Development Office as part of our long-running programme of technical assistance to Malawi on anti-corruption and asset recovery.","2024-08-29",[14],"","new-training-on-illicit-enrichment-rolled-out-in-malawi-2670",[14],2670,[],[],null,[22],"Main page",{"id":24,"storage":25,"filename_disk":26,"filename_download":27,"title":9,"type":28,"created_on":29,"modified_on":30,"charset":20,"filesize":31,"width":32,"height":33,"duration":20,"embed":20,"description":20,"location":20,"tags":20,"metadata":34,"focal_point_x":20,"focal_point_y":20,"tus_id":20,"tus_data":20,"uploaded_on":30},"83670fe7-10e5-43b3-b255-3acad59a6ad8","local","83670fe7-10e5-43b3-b255-3acad59a6ad8.webp","Insight Creations-2.webp","image\u002Fwebp","2025-05-12T21:10:32.000Z","2026-05-06T07:35:26.000Z",66238,1600,1068,{},[],[],[],[],[],[],[42,74,99,123,151,174,197,221,248],{"id":43,"body":44,"status":6,"type":10,"date":45,"slug":46,"title":47,"image":48,"countries":49,"topic":51,"activity":53,"tags":55,"nid":60,"topics":61,"activities":63,"authors":64,"images":65,"websites":66,"area":20,"programme":20,"language":20,"translations":67,"translation_of":20,"user_created":68,"date_created":69,"user_updated":70,"date_updated":71,"content":72,"link":73},9510,"Kosovan financial investigators, police, prosecutors and judges have completed the first phase of an intensive Train-the-Trainer (TTT) programme on financial investigations and asset recovery.\n\nLed by our International Centre for Asset Recovery (ICAR) [training team](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) in conjunction with UNDP and the Kosovo Judicial Academy, the five-phase TTT programme aims to result in four or five ICAR Certified Trainers while simultaneously training other local participants in the process.\n\nFollowing their certification, the Kosovan trainers will go on to deliver the training to their counterparts as a formal part of Kosovo’s judicial training programme.\n\n### Supporting Kosovo’s anti-corruption efforts\n\nThe five-day training workshop, which took place in Prizren, Kosovo from 16–20 May 2022, was part of the Support to Anti-Corruption Efforts in Kosovo ([SAEK III](https:\u002F\u002Fwww.undp.org\u002Fkosovo\u002Fpress-releases\u002Flaunch-third-phase-undp%E2%80%99s-support-anti-corruption-efforts-kosovo-saek-project-2020-2024)) project of UNDP Kosovo.\n\nThe Basel Institute is an implementing partner of the project, which seeks to reduce corruption in Kosovo by strengthening monitoring and oversight mechanisms of institutions to perform in an efficient, transparent, accountable and gender-sensitive manner. It is funded  by the Swiss Agency for Development and Cooperation (SDC) office in Kosovo and the Swedish International Development Cooperation Agency (SIDA).\n\nThe TTT programme is an integral part of our efforts to sustainably enhance the capacity of investigators and prosecutors in Kosovo to successfully investigate and prosecute corruption and money laundering cases, and recover assets. It follows a [February 2020 training programme](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fkosovan-anti-corruption-officials-explore-new-asset-confiscation-law-during-icar-training) on the same topic, in which the 25 participants were specifically challenged to make use of Kosovo’s recent Law of Extended Powers on Confiscation of Assets.\n\n### Why financial investigations training?\n\nA financial investigation is an important tool in detecting money laundering, terrorist financing and other serious crimes, as well as in enabling the freezing, seizure and confiscation of the proceeds of crime. Financial investigation in complex corruption and money laundering cases requires specialist skills and techniques in intelligence gathering, prosecution strategies and asset tracing, among others.\n\nOf these techniques, one of the judges at the May 2022 training was particularly complimentary about [Source and Application analysis](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-22-analysing-suspects-financial-affairs-corruption-case), a method to organise and present financial evidence gathered during an investigation in a way that highlights or identifies illicit or unknown income.\n\nPutting such skills and techniques into practice requires a thorough knowledge of relevant Kosovan legislation, and a deep understanding of the legal and practical processes and procedures for recovering assets abroad.\n\nTo tie these elements together, the centrepiece of the ICAR training programme is an extensive hands-on practical exercise in which the participants actually conduct a Kosovo-specific simulated investigation.\n\n### Learn more\n\n*   Find out about our [ICAR training team](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) and unique methodology, and download the current brochure in English, Spanish, French and Portuguese.\n*   Learn more about the Basel Institute’s [cooperation with the Office of the Chief Prosecutor of Kosovo](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fnew-cooperation-kosovos-office-chief-prosecutor-asset-recovery-undp-support) under the SAEK programme.\n*   For a brief introduction to Source and Application analysis, see this [Quick guide to analysing a suspect’s financial affairs in a corruption case](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-22-analysing-suspects-financial-affairs-corruption-case). More in-depth guidance is in the step-by-step [Guide to proving illicit enrichment using financial investigation and Source and Application of Funds analysis](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fproving-illicit-enrichment-using-financial-investigation-and-source-and-application) and our self-paced [eLearning course on Source and Application of Funds analysis](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=17), available in English and Ukrainian.","2022-05-24","train-the-trainer-programme-on-financial-investigations-and-asset-recovery-gets-underway-in-kosovo-2225","Train-the-Trainer programme on financial investigations and asset recovery gets underway in Kosovo ","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fab8d1282-05c1-4b78-8255-81f49269ad92?width=1000&height=650&format=webp&quality=80",[50],7255,[52],"Asset Recovery",[54],"Training",[56],{"tags_id":57},{"id":58,"name":59},1193,"Financial investigations",2225,[62],"Asset Recovery and Enforcement",[54],[],[],[22],[],"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","2022-05-26T22:51:45.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-29T22:21:38.000Z",[],"\u002Fresources\u002Fnews\u002Ftrain-the-trainer-programme-on-financial-investigations-and-asset-recovery-gets-underway-in-kosovo-2225",{"id":75,"body":76,"status":6,"type":14,"date":77,"slug":78,"title":79,"image":80,"countries":81,"topic":82,"activity":84,"tags":87,"nid":88,"topics":89,"activities":90,"authors":91,"images":92,"websites":93,"area":20,"programme":20,"language":20,"translations":94,"translation_of":20,"user_created":68,"date_created":95,"user_updated":70,"date_updated":96,"content":97,"link":98},9976,"On 15 and 16 January 2018, more than 60 financial investigators, lawyers, regulators and other specialists in anti-money laundering, cybercrime and financial intelligence took part in an expert workshop on Cryptocurrencies and Money Laundering jointly organised by the Basel Institute on Governance, Europol and INTERPOL in Basel, Switzerland.\n\nThe workshop is the fourth of a series of annual such gatherings hosted by the Working Group on Digital Currencies established in September 2016 by the co-organisers in order to gather and analyse information on the use of digital currencies by criminals and to develop strategies for the investigation and recovery of digital criminal proceeds\n\nA series of case presentations allowed to tease out successes and challenges in relation to the investigation of money laundering through cryptocurrencies and other forms of criminal misuse of those new payment methods. Mixing such insights into law enforcement practice with inputs provided by non-law enforcement participants, for example Citibank’s presentation on their work in the field of blockchain technologies and its approaches to tracing transactions, made for a varied and inspiring discussion.\n\nDay 2 of the workshop saw the first delivery of a new training module developed by the Basel Institute to help investigators and other interested specialists analyse blockchains, follow transactions through virtual currency, address exchanges based in foreign jurisdictions, and identify and seize cryptocurrency.  \n\nAt the end of the workshop a series of conclusions were endorsed, including:\n\n*   Countries should increase information sharing through INTERPOL, Europol, the Egmont Group and FIU channels;\n*   Training opportunities for regulators, prosecutors, judges, FIU experts, investigators and other relevant partners should be offered by the three co-organisers and other external sources;\n*   Cryptocurrencies Exchangers and Wallet Providers should be regulated under existing Anti Money Laundering and Counter Terrorism Financing Legislation;\n*   Action must be taken against services such as Mixers or Tumblers which are exclusively designed to anonymise transactions and make it impossible for law enforcement to detect and trace suspicious transactions; and\n*   Consider the creation of the offence of illicit enrichment to support money laundering investigations, convictions and confiscations.\n\nThe three host organisations will continue fostering good practices and expert exchanges in order to contribute to global efforts to prevent the misuse of blockchain technology and virtual currency by criminals, and financial crime in particular. The Basel Institute’s contribution to these efforts will include the development of additional and advanced training modules for financial investigators, financial institutions and other interested stakeholders along the lines of similar those regularly delivered by the training team of the Basel Institute’s International Centre for Asset Recovery (ICAR) or on the ICAR e-learning campus.","2018-01-26","investigating-crimes-linked-to-cryptocurrencies-98","Investigating crimes linked to cryptocurrencies","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fcc99de9d-fec8-4287-8f9b-34cf4aaa769a?width=1000&height=650&format=webp&quality=80",[],[83,52],"Anti-Money Laundering",[85,86],"Events","International cooperation",[],98,[83,62],[85,86],[],[],[22],[],"2022-05-26T22:57:59.000Z","2026-05-29T22:22:06.000Z",[],"\u002Fresources\u002Fnews\u002Finvestigating-crimes-linked-to-cryptocurrencies-98",{"id":100,"body":101,"status":6,"type":102,"date":103,"slug":104,"title":105,"image":106,"countries":107,"topic":108,"activity":109,"tags":110,"nid":111,"topics":112,"activities":113,"authors":114,"images":116,"websites":117,"area":20,"programme":20,"language":20,"translations":118,"translation_of":20,"user_created":68,"date_created":119,"user_updated":70,"date_updated":120,"content":121,"link":122},9585,"_How investigators and prosecutors can use Source and Application of Funds analysis to inform corruption and money laundering investigations and prosecutions and to generate evidence for use in court. A quick guide by the [Training team](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) of the International Centre for Asset Recovery._\n\n### If it looks and smells like corruption…\n\n“How could he afford that car on his salary?” “Where did she get the money to buy those expensive clothes?” “How is that public official able to stay in a luxury beachside property when he only earns enough for a small house in the suburbs?” These simple questions are often the starting point for investigations into suspected corruption, including under laws targeting unexplained wealth. Answering them, and proving in court that the money has been obtained illicitly and should therefore be subject to recovery, is a lot trickier.\n\n### … that’s still not enough for a court\n\nCorruption is a particularly difficult crime to investigate and prove beyond reasonable doubt. Why? Because it usually takes place behind closed doors between two or more willing parties who are unlikely to report the matter to the police or cooperate in an investigation. These days, technologies such as digital transfers, mobile money and cryptocurrencies make it far easier for illicitly obtained money to change hands. Stolen funds disappear across borders and into secret accounts in a click. Many corrupt officials seeking to launder money also hire unscrupulous corporate service providers, accountants and lawyers. These professionals help them to create complex financial structures in offshore jurisdictions to conceal the true ownership of their assets, as explained in our quick guide to [offshore structures and beneficial ownership](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-19-offshore-structures-and-beneficial-ownership). These factors combine to thwart the attempts of investigators to follow the trail of the money.\n\n### Caught red-handed? Not often\n\nThe increasing sophistication of criminals means it is rare to find direct evidence of corruption or other financial crimes, such as an eyewitness, a video or audio recording, or a bank transfer from a company to a public official who can be proved to have performed a particular corrupt action in return. Moreover, even such evidence is not conclusive. Witness accounts may be flawed, and documents, videos and audio recordings are nowadays easily forged. This is why it is vital for anti-corruption officers to be able to build financial profiles of individuals suspected of corruption and money laundering. Systematically calculating the amount of money that a suspect has accumulated and spent during a particular period, compared to their legal and known income, is a powerful means to demonstrate, or provide corroborative evidence in respect of, their illicit activity even in the absence of a smoking gun.\n\n### Source and Application: a common-sense calculation\n\nOne particularly effective tool for building such a financial profile of a suspect is the Source and Application analysis. It is a simple formula to calculate the difference between two figures over a specific period of time selected by the investigator and based on allegations or suspicions of corrupt activity: For example: If a suspect can be shown to have spent or accumulated $500,000 in 2020 but only had $250,000 legally available to her during this time according to official records and other relevant evidence, she has enjoyed $250,000 of unexplained income. This amount may or may not be the proceeds of corruption, but unless she can explain the source of the additional money it is strong circumstantial evidence of illicit behaviour. This financial evidence can be used in court to support a traditional corruption, fraud or money laundering case in a criminal context. In countries with illicit enrichment laws, it can also be used as direct evidence and as a basis for recovering the unexplained wealth. (For more on illicit enrichment, see our open-access book and its Annex II guidance on Source and Application of Funds analysis at [illicitenrichment.baselgovernance.org](https:\u002F\u002Fillicitenrichment.baselgovernance.org\u002F).)\n\n### Gathering the information – a valuable exercise in itself\n\nIn addition to generating crucial financial evidence of illicit activity, the process of conducting a Source and Application analysis is a useful investigative tool. This is because it offers a systematic framework for investigators to gather all documentary and other relevant evidence that relates to the suspect’s use of funds vs the funds legally available to him or her during a specific period of interest. The Source and Application computation sheet in itself is not evidence per se but merely a method to organise and present financial evidence gathered during the investigation in a way that highlights or identifies illicit or unknown income. Examples of legal sources of income are salary payments, declared income from property rentals or company shareholdings, sales of assets, inheritances or loans. This category also includes the suspect’s bank balances at the start of the period, since the money contained in these accounts was available for him or her to spend. In terms of applications, investigators will use bank or mobile money statements, invoices and other documents to gather information about the suspect’s use of funds during that period. This includes, for example, purchasing assets, paying property rentals or bills, repaying loans, employing staff or taking holidays. It also includes the suspect’s bank balances at the end of the selected period, as this reflects money he had not yet spent but still had available to spend. Other applications may involve the purchase of crypto assets which can be kept in a self-custody wallet or with a third party such as a cryptocurrency exchange. All of these documents and other relevant evidence can contain vital clues that assist in tracing illicit flows of money and reveal further suspects in the individual’s corrupt network.\n\n### No silver bullet, but a useful tool\n\nThere are challenges to using the Source and Application analysis, of course. One arises in countries with large informal and cash-based economies, which makes it harder to obtain documents and records to prove either the source or the application of a suspect’s funds. Good old-fashioned detective work can help to overcome this, such as surveillance, speaking to neighbours and knowing the market prices of goods that a person claims to have sold. Furthermore, this tool is not meant to be used in each and every corruption case but rather when it appears that the suspect is enjoying a lifestyle that is not commensurate with his\u002Fher legal and known income. Another difficulty is finding hidden assets, bank accounts, mobile money accounts or cryptocurrency wallets, especially when the suspect refuses to cooperate or the information is held abroad or protected by banking secrecy laws. Our quick guide to [fundamental skills in tracing assets](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-14-fundamental-skills-tracing-assets) gives investigators some tips on uncovering new leads, again through good old-fashioned detective work. Meanwhile our guide to [international cooperation](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-9-international-cooperation-asset-recovery) explains how investigators may obtain such information from foreign jurisdictions, and our quick guide to [cryptocurrencies and money laundering](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-1-cryptocurrencies-and-money-laundering) reveals how it is possible for law enforcement to “follow the virtual money”. In court, it may be that magistrates and judges are unaware of this method or unwilling to accept the final computation as financial evidence. We do believe, though, that it is much simpler to explain a Source and Application calculation than alternative methods of financial profiling such as Net Worth analysis, as explored in our free [eLearning course on Source and Application of Funds analysis](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=17). There is no silver bullet or magic tool to calculate illicit funds in a corruption case and generate rock solid financial evidence of wrongdoing. But the analysis is often a crucial piece in a complex puzzle that can prove, or corroborate evidence of, the possession of illicit assets and point to related criminal activity. In our experience conducting training programmes around the world, we see time and again how the Source and Application analysis resonates with investigators and prosecutors as both a useful tool in investigating corruption and money laundering cases and generating evidence of these crimes for use in court. [Download this quick guide as a PDF](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-22-analysing-suspects-financial-affairs-corruption-case). See all quick guides on our [Basel LEARN](https:\u002F\u002Flearn.baselgovernance.org\u002F#cat_20) virtual platform, many in multiple languages.","Blog","2021-07-05","quick-guide-to-analysing-a-suspects-financial-affairs-in-a-corruption-case-2045","Quick guide to analysing a suspect’s financial affairs in a corruption case","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F48c26ea3-f2d4-4d82-9fd3-4673247fe781?width=1000&height=650&format=webp&quality=80",[],[52],[54],[],2045,[62],[54],[115],803,[],[22],[],"2022-05-26T22:52:52.000Z","2026-05-29T22:21:44.000Z",[],"\u002Fresources\u002Fnews\u002Fquick-guide-to-analysing-a-suspects-financial-affairs-in-a-corruption-case-2045",{"id":124,"body":125,"status":6,"type":102,"date":126,"slug":127,"title":128,"image":129,"countries":130,"topic":131,"activity":132,"tags":134,"nid":139,"topics":140,"activities":141,"authors":142,"images":144,"websites":145,"area":20,"programme":20,"language":20,"translations":146,"translation_of":20,"user_created":68,"date_created":147,"user_updated":70,"date_updated":148,"content":149,"link":150},9653,"Financial investigations are critical to proving crimes such as corruption, fraud and trafficking in humans or illicit goods. They are also central to confiscating illegally obtained assets from criminals – so that crime doesn’t pay. Yet there is often confusion about who performs financial investigations, how, when and why, as well as their relationship to criminal investigations. All of these questions are further complicated by the fact that different countries have different legal systems, different laws and different terminology. This quick guide explores the main ideas and trends in financial investigation in the context of financial crime and asset recovery cases, based on my experience in these areas in Portugal and Mozambique. Practitioners will need to talk openly and proactively to each other, both within their countries and across borders, to untangle some of the more challenging knots.\n\n### What does a financial investigation involve?\n\nIn its [_Operational Issues – Financial Investigations Guidance_](https:\u002F\u002Fwww.fatf-gafi.org\u002Fpublications\u002Fmethodsandtrends\u002Fdocuments\u002Foperationalissues-financialinvestigationsguidance.html), the Financial Action Task Force (FATF) defines financial investigation as _“an enquiry into the financial affairs related to criminal conduct. The major goal of a financial investigation is to identify and document the movement of money during the course of criminal activity.”_  To do this, investigators need to collect, process and analyse information about a person’s financial affairs, such as bank accounts, Bitcoin transactions or property ownership. The result can include both the documentary evidence (such as a bank statement or property title) and expert analytical reports (such as a visualisation of financial transactions).\n\n### How financial investigations support criminal cases\n\nIn its _Financial Investigations Guidance_, the FATF sets out two purposes of financial investigation in a criminal case. First, to assist “in the prosecution of crime” by providing (financial) evidence to help convict the suspect. As the FATF explains, _“The link between the origins of the money, beneficiaries, when the money is received and where it is stored or deposited can provide information about and proof of criminal activity.”_ Other evidence may come from surveillance, undercover operations, wiretapping, contracts, witnesses or expert evidence, for example on procurement processes. Second, to assist “in the deprivation of the proceeds and instrumentalities of crime”. In other words, financial investigations help to locate illegally obtained money and other assets in order to confiscate them. The most obvious assets to be recovered are those relating to a specific crime. These can be _instrumentalities_ (used to commit the crime, such as forged documents in a corruption case) or _proceeds_ arising directly or indirectly from the crime (such as money from bribes or embezzlement, or the profits from investing the stolen money).\n\n### Extending beyond criminal investigations\n\nFor many years, efforts to recover criminal assets typically focused only on those assets related to a specific crime and conviction. But there’s a problem with this. Imagine Mrs. X has amassed several million dollars over several years through corruption or organised crime. She is caught and convicted of one crime, pays a fine or goes to prison for a short period, and forfeits the proceeds of that specific crime. Afterwards, she and her family are free to enjoy her illegally obtained millions. This is why many countries, in cases of serious financial and organised crimes and in accordance with international conventions, have introduced alternative mechanisms of forfeiture\u002Fconfiscation. The purpose is to identify money or other assets that, on the balance of probability, are the result of criminal conduct and should be confiscated. This applies even if the assets cannot be related beyond reasonable doubt to a specific crime. The aim: when Mrs. X emerges from prison, she is _not_ able to enjoy the fruits of her criminal career. In Mozambique, financial investigations for “extended confiscation” (_perda alargada_) typically determine the financial value of a person’s assets. This is compared with their income according to their tax returns. If a particular sum of money incompatible with their lawful income results, then prosecutors seize specific assets which, after conviction, will be confiscated, up to that amount. These financial investigations do not form part of the criminal investigation and can go back several years before the commission of the crime. Financial investigations are central to other powerful and increasingly widespread legal mechanisms to confiscate and recover illegally obtained assets. These include various forms of non-conviction based confiscation and [illicit enrichment](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-5-illicit-enrichment).\n\n### Who performs financial investigations?\n\nFinancial investigators need highly specialised skills and experience in understanding financial flows, corporate structures, banking systems and money laundering schemes, as well as using analytical software. They may have a background in accounting, financial auditing or other technical areas, with additional training on criminal law and processes. In a criminal investigation, the reports of such technical specialists are considered impartial and have the value of evidence. In Mozambique, for cases of “extended confiscation”, they may be criminal investigators with an aptitude for financial analysis and specific additional training. In addition to technical abilities, financial investigators need great attention to detail, self-motivation and communication skills. Some countries’ law enforcement authorities have specialised units of financial investigators dedicated to supporting criminal cases. Others must appoint external consultants if they lack the in-house expertise.\n\n### Parallel financial investigations, the gold standard\n\nThe FATF recommends _parallel financial investigation,_ i.e. focusing simultaneously on the crime and on the related money laundering charges. What happens if you don’t launch a parallel financial investigation at the start of a criminal investigation?\n\n*   The criminal may take advantage of this extra time to hide his or her money or destroy paperwork.\n*   Evidence that may be useful to the prosecution may never be found. This might result in the case failing in court, or the criminal being convicted of a lesser crime.\n*   The investigation may fail to identify other suspects, witnesses or victims.\n*   Money or other assets considered irrelevant to the specific crime in question may be ignored, missing out on a chance to confiscate them.\n\nThat is why, in contrast to standard practice in many countries until now, parallel financial investigations are the gold standard.\n\n### Common challenges in financial investigations\n\nWeaknesses and loopholes vary hugely across countries and legal systems, but some common difficulties that we are working to overcome include:\n\n#### Access to financial information \n\nMany countries have no central database of bank accounts and other financial assets. Such a database, like the Accounts Database introduced in Portugal in 2010, allows investigators with the relevant judicial authorisation to request information about all financial assets and relationships that Mr. Y has in the country. Without this centralised information source, the investigator must contact every financial institution operating in the country separately to ask whether Mr. Y holds assets at that institution. As well as the huge time and costs involved, there is also the security risk of disclosing that an investigation is being conducted into Mr. Y.\n\n#### Format of information – paper, really?\n\nEach case involves huge amounts of financial data, with transactions often reaching thousands of records per year. For an investigation going back five years, you can multiply that by five. Now imagine that volume of data on paper. Some financial institutions still provide the information in paper format, claiming security risks in the transmission and storage of digital files. Paper information has to be manually converted into a spreadsheet for processing and analysis, hugely increasing time, tedium and risk of errors.\n\n#### Skills and experience \n\nTraining is vital to gain the analytical and IT skills and knowledge needed to conduct a relevant and accurate financial investigation. But these skills and knowledge can only fully be gained through hands-on experience in complex cases, which may take years. On-the-job mentoring on cases helps build this experience quickly and solidly, supporting both those cases and the learning curve.\n\n#### International cooperation \n\nInvestigations can sometimes be compromised by a lack of cooperation when evidence is sought from other jurisdictions or by delayed cooperation where the evidence comes too late. On this, please see my colleague Shane Nainappan’s [quick guide to international cooperation in asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-9-international-cooperation-asset-recovery). Internal informal cooperation is also a big challenge and a big opportunity. All parts of the criminal justice system – including new elements such as specialised asset recovery teams – must work together, understanding each other’s roles and being willing to share the information that each side needs to achieve their goals. Ultimately, mutual understanding and trust are the foundations of success in recovering illegal assets, and thereby deterring criminals and the corrupt. [Download this guide as a PDF](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-20-financial-investigations-and-asset-recovery) and [view all our quick guides on LEARN](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Findex.php?categoryid=20).","2020-11-24","carla-monteiros-quick-guide-to-financial-investigations-and-asset-recovery-1923","Carla Monteiro’s quick guide to financial investigations and asset recovery","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fdee8ed71-a3d6-49af-b54d-391d6fe3da85?width=1000&height=650&format=webp&quality=80",[],[52],[133],"Insights",[135],{"tags_id":136},{"id":137,"name":138},843,"Asset recovery",1923,[62],[133],[143],817,[],[22],[],"2022-05-26T22:53:50.000Z","2026-05-29T22:21:48.000Z",[],"\u002Fresources\u002Fnews\u002Fcarla-monteiros-quick-guide-to-financial-investigations-and-asset-recovery-1923",{"id":152,"body":153,"status":6,"type":10,"date":154,"slug":155,"title":156,"image":157,"countries":158,"topic":159,"activity":160,"tags":161,"nid":162,"topics":163,"activities":164,"authors":165,"images":166,"websites":167,"area":20,"programme":20,"language":20,"translations":168,"translation_of":20,"user_created":68,"date_created":169,"user_updated":170,"date_updated":171,"content":172,"link":173},9780,"The Basel Institute is looking forward to seeing many of our partners in the fight against corruption at the [8th Session of the Conference of the States Parties](https:\u002F\u002Fwww.unodc.org\u002Funodc\u002Fen\u002Fcorruption\u002FCOSP\u002Fsession8.html) to the UNCAC (COSP) in Abu Dhabi from 16–20 December.\n\nIf you're at CoSP, here are some events for your calendar:\n\n*   Friday 20 December, 9am-10am: Our International Centre for Asset Recovery is hosting a side event on [Living up to the spirit of articles 43 and 46 UNCAC](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fcosp-side-event-living-spirit-articles-43-and-46-uncac). The panel, organised by the Basel Institute's International Centre for Asset Recovery (ICAR) and chaired by Oscar Solórzano, will explore how principles of Articles 43 (international cooperation) and 46 (mutual legal assistance) of the UNCAC can provide answers to countries that are victims of corruption and seeking to recover assets through non-conviction-based confiscation. See [full details and the concept note here](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fcosp-side-event-living-spirit-articles-43-and-46-uncac).\n*   Tuesday 17 December, 9am-10am: Our Managing Director Gretta Fenner will be a discussant in the Stolen Asset Recovery Initiative (StAR) Day – Opening & High-Level Conversation on Asset Recovery: achievements, challenges and the road ahead.\n*   Thursday, 19 December, 5pm-6pm: Gretta Fenner is a panellist in a side event on \"Utilization of recovered asset for the realisation of SDG 16.4\".\n\nAll three events are in conference room CR1.\n\nCome and visit us at the booth to speak to our delegation and pick up some of our latest publications. Or – if you're not attending – you can download them here:\n\nVirtual booth – free publications on anti-corruption and governance\n-------------------------------------------------------------------\n\n*   [Annual Report 2018](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fannual-report-2018)\n\n### Digital tools - flyers\n\n*   [Basel AML Index](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-12\u002Fbasel_aml_index_flyer.pdf)\n*   [Basel Open Intelligence](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-12\u002Fboi_flyer.pdf)\n*   [eLearning courses](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-12\u002Felearning_flyer.pdf)\n*   [Corruption prevention training](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-12\u002F191106_flyer-digital-tools_08_all_4-training.pdf)\n\n### Research \n\n*   [Hidden agendas, social norms and why we need to re-think anti-corruption](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-22-hidden-agendas-social-norms-and-why-we-need-re-think-anti-corruption)\n*   [Can a behavioural approach help fight corruption?](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fpolicy-brief-1-can-behavioural-approach-help-fight-corruption)\n*   [Harnessing the power of communities against corruption](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fharnessing-power-communities-against-corruption) (U4 brief)\n*   [Addressing bribery in the Tanzanian health sector](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-12\u002Fgi-ace_1.pdf) - a behavioural approach (GI-ACE project description) \n*   [Harnessing informality:](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-12\u002Fgi-ace_2.pdf) designing anti-corruption network interventions and strategic use of legal instruments (GI-ACE project description)\n\n### Asset recovery and anti-money laundering\n\n*   [Recovering assets in support of the SDGs – from soft to hard assets for development](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-29-recovering-assets-support-sdgs-soft-hard-assets-development)\n*   [It takes two to tango. Decision-making processes on asset return](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-24-it-takes-two-tango-decision-making-processes-asset-return)\n*   [Tracing illegal assets - a practitioners' guide](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Ftracing-illegal-assets-practitioners-guide) (available in English, Spanish, Ukrainian and Bulgarian)\n*   [Regulating cryptocurrencies: challenges and considerations](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-28-regulating-cryptocurrencies-challenges-and-considerations)\n*   [ICAR training programmes](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-02\u002FICAR_Training_Programmes_2017.pdf) (brochure)\n\n### Collective Action and compliance\n\n*   [High Level Reporting Mechanisms: A comparative analysis](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-25-high-level-reporting-mechanisms-comparative-analysis)\n*   [Anti-Corruption Collective Action: Success factors, sustainability and strategies](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-27-anti-corruption-collective-action-success-factors-sustainability-and)\n*   [New perspectives in e-government and the prevention of corruption](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-23-new-perspectives-e-government-and-prevention-corruption)\n\n### Illegal wildlife trade\n\n*   [Corruption and wildlife trafficking](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-30-corruption-and-wildlife-trafficking-exploring-drivers-facilitators): exploring drivers, facilitators and networks behind illegal wildlife trade in East Africa\n\n### Quick guides\n\n*   [Cryptocurrencies and money laundering](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Ffederico-paesanos-quick-guide-cryptocurrencies-and-money-laundering)\n*   [Intelligence](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fmanuel-medinas-quick-guide-intelligence)\n*   [Integrity and anti-corruption compliance for SMEs](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fgemma-aiolfis-quick-guide-integrity-and-anti-corruption-compliance-smes)\n*   [Social network analysis in combating organised crime and trafficking](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fjacopo-costas-quick-guide-social-network-analysis-combating-organised-crime-and-trafficking)\n*   [Illicit enrichment](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fandrew-dornbierers-quick-guide-illicit-enrichment)\n*   [Social norms and corruption](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fclaudia-baez-camargos-quick-guide-social-norms-and-corruption)\n*   [Effective training on financial investigations](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fphyllis-atkinsons-quick-guide-effective-training-financial-investigations)\n*   [The role of FIUs in asset recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fthierry-ravalomandas-quick-guide-role-fius-asset-recovery)\n*   [eLearning for asset tracing and financial analysis](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fpeter-huppertzs-quick-guide-elearning-asset-tracing-and-financial-analysis)\n*   [International cooperation in asset recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fshane-nainappans-quick-guide-international-cooperation-asset-recovery)\n*   [Drivers and facilitators of wildlife trafficking](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fsaba-kassas-quick-guide-drivers-and-facilitators-wildlife-trafficking)\n*   [The role of business in tackling illegal wildlife trade](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fscarlet-wannenwetschs-quick-guide-role-business-tackling-illegal-wildlife-trade)\n*   [Financial crime in illegal wildlife trade](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fgretta-fenners-quick-guide-financial-crime-illegal-wildlife-trade)\n*   [Fundamental skills in tracing assets](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fphill-joness-quick-guide-fundamental-skills-tracing-assets)","2019-12-16","visit-us-at-the-conference-of-the-states-parties-in-abu-dhabi-1033","Visit us at the Conference of the States Parties in Abu Dhabi","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc59a836e-d631-43c5-a572-377f5bffce37?width=1000&height=650&format=webp&quality=80",[],[14],[85],[],1033,[],[85],[],[],[22],[],"2022-05-26T22:55:35.000Z","b0662e2a-864d-4888-a1b7-4342b7570b30","2025-08-31T23:14:59.000Z",[],"\u002Fresources\u002Fnews\u002Fvisit-us-at-the-conference-of-the-states-parties-in-abu-dhabi-1033",{"id":175,"body":176,"status":6,"type":102,"date":177,"slug":178,"title":179,"image":180,"countries":181,"topic":182,"activity":183,"tags":184,"nid":185,"topics":186,"activities":187,"authors":188,"images":190,"websites":191,"area":20,"programme":20,"language":20,"translations":192,"translation_of":20,"user_created":68,"date_created":193,"user_updated":70,"date_updated":194,"content":195,"link":196},9789,"Recovering criminals’ ill-gotten assets, i.e. confiscating property, cars, yachts, cash and other funds gained through corruption or other acquisitive crimes, is a big topic in law enforcement. Among other benefits, asset recovery acts as a deterrent against crime and makes a clear public statement that illicit wealth will be targeted and returned to the public treasury. There is much discussion and numerous publications about how we recover illegally gained wealth through a legal process in the court system. How to find the assets in the first place gets less attention.  Unlike the recovery process, the tracing of assets has no set structure. Providing an investigator uses tactics and techniques that are legal in their jurisdiction, they are free to use as much flair and imagination as they like.  In our desire to be innovative and modern, however, we mustn’t overlook some fundamental investigative skills that will help us trace even the most cleverly hidden assets. This quick guide looks at a few of these and explains why they’re important to keep in mind.\n\n### Intelligence: the key to unlock information\n\nBasic information to trace assets often comes from so-called “closed sources” such as company records, land registries, vehicle licensing departments and credit reference agencies. They are “closed” because databases containing this type of information, where they exist, are restricted by data protection laws.  To gain access, we need specific intelligence that suggests there is data relating to our subject in a particular database. Requesting access to data without specific intelligence is commonly referred to as a fishing expedition. For example, if we don’t hold any information that suggests our suspect has travelled overseas or crossed any national border, then we are not justified in accessing information held by the immigration or border control services.  So, asset tracing is not only about finding assets, but finding information that can unlock these closed sources and lead us to other assets that may be more carefully hidden.  And in jurisdictions where these closed sources don’t exist, we still need basic information to trace the asset itself.\n\n### Does digital data hold the key?\n\nIt is now common for investigators to download mobile phone data and copy (“ghost”) computer hard drives. Many also trawl through open-source websites and social media platforms for photographs and hints to gain a better understanding of the suspect’s lifestyle and assets. This is all well and good. It’s amazing how often even clever criminals give themselves away by publicly posting photos of themselves on Facebook or Instagram. But a persistent investigator will not stop at the digital search.\n\n### Searching: going that step further\n\nYou would be excused for thinking that the purpose of undertaking searches of a suspect’s property is to locate assets like jewellery, cars, bank account details, etc, and where necessary seize or restrain the property in order to minimise the risk of dissipation. But an investigator should also apply their best detective skills and look at the search as a gateway to obtain information that leads us to the less obvious acquisitions. What kind of information? Well, for example, an individual holding Bitcoins will need to remember a 64-digit passcode called a “private key” or, if they are using a more sophisticated wallet, the 12 or 24 words used to generate the wallet. Any sensible person will write down these codes and keep them in a secure place, like at home, work or on a mobile phone.  Car keys are often left behind in searches unless they unlock a brand-new Lamborghini parked outside the door. True, the keys to a 20-year old rust bucket may not be of interest as an asset, but what is inside? Perhaps cash, banking documents and even purchase receipts that not only provide us with knowledge of the suspect’s lifestyle and expenditure, but also place them in a particular place at a particular time.  Other keys may reveal the existence of further properties or storage that should also be located and searched, for the same reason.\n\n### Revisiting witnesses and suspects\n\nMany jurisdictions recover assets through a civil hearing that follows a criminal conviction. The time between the two hearings can be several months. This provides a window of opportunity to revisit witnesses without risking any suggestion of interference with the criminal prosecution case. Although the first purpose of witnesses is to secure evidence of the criminal offence, they may also hold valuable knowledge of a suspect’s lifestyle and assets. With little or no understanding of the asset recovery process, they may not think this knowledge is relevant. A good financial investigator will ask them the right questions to elicit the information. It’s not just witnesses that can provide useful information during this window of opportunity, but sometimes the convicted individuals themselves. Many want to make a clean start and will disclose the existence of assets out of fear that the case may be revisited if undisclosed assets are identified later. A visit or even a letter to convicted persons can easily yield dividends.\n\n### Communicating widely\n\nOne final forgotten skill is that of communication. Outside the confines of the legal system, there is no restriction on any individual to speak to any person at any time.  Investigators need to get out from behind their desks and make contacts outside their sphere of operations, be it socially at the gym, in a club or in the workplace. Making themselves available to any potential whistle-blowers, informants or witnesses, or even making steps to identify such individuals, will often lead to them striking lucky.  It’s worth remembering that somebody knows somebody, who knows somebody, that knows something… and that something could be the key to successfully tracing a criminal’s hidden wealth. \n\n### Find out more\n\n*   Learn about the Basel Institute’s [International Centre for Recovery](\u002Fnode\u002F25) (ICAR), which provides training, technical assistance and legal\u002Fpolicy advice on financial investigation and asset recovery.\n*   See related quick guides to [intelligence](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fmanuel-medinas-quick-guide-intelligence), [international cooperation in asset recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fshane-nainappans-quick-guide-international-cooperation-asset-recovery), [illicit enrichment](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fandrew-dornbierers-quick-guide-illicit-enrichment) and [effective training on financial investigations](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fphyllis-atkinsons-quick-guide-effective-training-financial-investigations).\n*   For more on the wider benefits of asset recovery, read the Basel Institute [Working Paper 29: Recovering assets in support of the SDGs – from soft to hard assets for development](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fworking-paper-29-recovering-assets-support-sdgs-soft-hard-assets-development).\n*   [Download a PDF of this quick guide.](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-08\u002Fqg14_tracing_assets.pdf)","2019-11-27","phill-joness-quick-guide-to-fundamental-skills-in-tracing-assets-1029","Phill Jones’s quick guide to fundamental skills in tracing assets","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F557d8f9a-9a9a-4592-9e1d-cf9490b7216e?width=1000&height=650&format=webp&quality=80",[],[52],[133],[],1029,[62],[133],[189],872,[],[22],[],"2022-05-26T22:55:42.000Z","2026-05-29T22:21:55.000Z",[],"\u002Fresources\u002Fnews\u002Fphill-joness-quick-guide-to-fundamental-skills-in-tracing-assets-1029",{"id":198,"body":199,"status":6,"type":10,"date":200,"slug":201,"title":202,"image":203,"countries":204,"topic":206,"activity":207,"tags":209,"nid":210,"topics":211,"activities":212,"authors":213,"images":214,"websites":215,"area":20,"programme":20,"language":20,"translations":216,"translation_of":20,"user_created":68,"date_created":217,"user_updated":70,"date_updated":218,"content":219,"link":220},9713,"We are delighted to announce that our International Centre for Asset Recovery (ICAR)’s support to the Prevention and Combating of Corruption Bureau in Tanzania is entering an ambitious second phase.\n\nThis follows a successful first phase of our technical assistance programme, which was launched in 2016 and [extended](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Ftanzanias-anti-corruption-authority-approves-extension-basel-institutes-asset-recovery) in 2019. Over these five years, the PCCB has made significant strides in its capacity to investigate and prosecute cases of corruption and recover stolen assets both domestically and internationally.\n\n### Innovation and international cooperation\n\nIn the next phase of the programme, our team of two embedded field staff plus HQ-based experts and trainers will help the PCCB build on its achievements to date.\n\nA major aim is to embed innovative techniques for asset recovery more thoroughly into standard working processes for greater sustainability. An example is the use of Tanzania’s [illicit enrichment legislation](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fandrew-dornbierers-quick-guide-illicit-enrichment), which was employed for the first time last year with the initiation of four ground-breaking prosecutions. An ICAR-developed Manual for Unexplained Wealth Investigations focused on Tanzania has been published and widely disseminated among PCCB staff.\n\nThe scope of technical assistance also includes [international cooperation](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fshane-nainappans-quick-guide-international-cooperation-asset-recovery), which is a major hurdle for many anti-corruption authorities seeking to recover stolen assets from abroad.\n\n### Targeted capacity building\n\nThe second phase will enable the ICAR team to help address specific challenges that still remain in the asset recovery process in Tanzania.\n\nIn addition to on-the-job coaching and training programmes by our HQ-based ICAR training team on topics such as [corruption in infrastructure projects](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Ftanzania-builds-capacity-and-cooperation-build-anti-corruption-success), [money laundering using Bitcoin](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Ftanzania-builds-capacity-and-cooperation-build-anti-corruption-success) and [interviewing skills](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fboosting-interviewing-skills-financial-investigations-tanzania), ICAR-certified local trainers have delivered intensive workshops on financial investigations and asset recovery to a [record 300+ Tanzanian officials](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fsustainable-capacity-building-tanzania-thanks-icar-certified-local-trainers-look-back-2019). This highlights the success of our Train-the-Trainer programme in Tanzania, which is designed to make capacity building for anti-corruption officials more sustainable and expand its impact.\n\n### Priorities looking forward\n\nWorking under the new leadership of Brig General John J Mbung'o with an expanded group of officials from the Investigations Directorate, Legal Services Directorate and Intelligence Directorate, the team will focus their efforts on supporting the PCCB in:\n\n*   the use of intelligence to inform and strengthen corruption investigations and asset recovery efforts;\n*   the conduct and management of corruption investigations with an asset recovery aspect;\n*   acquiring court orders related to proceeds of crime and prosecuting corruption cases with an asset recovery aspect;\n*   engagement and interaction with other institutions in the wider anti-corruption process.\n\nThe Intelligence Directorate was set up in 2019 with close ICAR support and is already receiving and analysing crucial financial intelligence from around the country. Intelligence staff have already benefitted from a week-long training course delivered by the Basel Institute’s Public Governance team, in which they worked together with their colleagues in the Corruption Prevention Directorate to learn how to [translate corruption research and data info actionable insights](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fturning-corruption-research-anti-corruption-insights-tanzania).\n\n### Sustained support and funding\n\nThe [Swiss Agency for Development and Cooperation](https:\u002F\u002Fwww.eda.admin.ch\u002Fsdc) (SDC) will continue to fund Tanzania’s technical assistance programme as it enters the next phase.\n\nThe SDC is a core donor to ICAR, along with the UK Department for International Development (DFID), Principality of Liechtenstein, Government of Jersey and Norwegian Agency for Development Cooperation (Norad).\n\nThe sustained support of the SDC and other ICAR core donors is essential to the success of anti-corruption and asset recovery programmes, which need time, trust and dedication to bear fruit.\n\nFind out more about [ICAR’s work and approach](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery) or see our [FAQs](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ffaqs-asset-recovery).","2020-07-08","whats-next-in-tanzanias-efforts-to-tackle-corruption-and-recover-stolen-assets-1806","What’s next in Tanzania’s efforts to tackle corruption and recover stolen assets?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F72585b3a-5de8-41ef-b8e8-fb688d073709?width=1000&height=650&format=webp&quality=80",[205],7413,[52],[54,208,86],"Partnerships",[],1806,[62],[54,208,86],[],[],[22],[],"2022-05-26T22:54:40.000Z","2026-05-29T22:21:51.000Z",[],"\u002Fresources\u002Fnews\u002Fwhats-next-in-tanzanias-efforts-to-tackle-corruption-and-recover-stolen-assets-1806",{"id":222,"body":223,"status":6,"type":102,"date":224,"slug":225,"title":226,"image":227,"countries":228,"topic":230,"activity":231,"tags":232,"nid":237,"topics":238,"activities":239,"authors":240,"images":242,"websites":243,"area":20,"programme":20,"language":20,"translations":244,"translation_of":20,"user_created":68,"date_created":245,"user_updated":70,"date_updated":148,"content":246,"link":247},9657,"On 28 October 2020, Uganda registered a landmark judgment in the case of Uganda v Geoffrey Kazinda. Although there have been a couple of other previously prosecuted illicit enrichment cases, the Kazinda case is the most significant because of the vast sum of money involved: a total of UGX 4,630,195,258 (over USD 1,252,600).\n\nKazinda, a former Principal Accountant in the Office of the Prime Minister, was convicted on three counts of illicit enrichment contrary to section 31 of the Anti-Corruption Act, 2009. He has previously been prosecuted for other corruption-related offences. The case, which was investigated and prosecuted by the Inspectorate of Government, paves the way for development of the offence of illicit enrichment in Uganda.\n\n### Incompatible standard of living\n\nIn the first count, the court found that between 2009 and 2012, the accused maintained a standard of living that was not commensurate with his known sources of income. The evidence showed that between 2010 and 2012, the accused had rented a suite at Sheraton Hotel, Kampala for over six months. The accused spent UGX 210,364,011 (USD 56,910) on this expense. The accused had stated in his Asset Declaration Forms that, for the period in issue, he had no other sources of income other than his salary and allowances, which totalled UGX 83,754,655 (USD 22,658).\n\nTo disassociate this expense from himself, the accused obtained a credit facility at the hotel in the name of an accomplice. The accomplice denied having occupied the suite in his evidence. Also, expert evidence on handwriting showed that the accused had signed the invoices of the bills incurred. He also made part payments in cheques in his own name. Oral evidence from hotel staff also proved that it was the accused who occupied the suite at the time.\n\n### A mansion and plots of land in Kampala\n\nIn the second count, the court found that between 2010 and 2012, the accused was in control and possession of three plots of land in Bukoto, Kampala worth a total value of UGX 3,657,747,500 (USD 989,540), which was disproportionate to his known sources of income. On a part of this land sat the accused’s spectacular mansion.\n\nInterestingly, the accused had tried to disassociate himself from these properties by transferring them as a gift to the registered trustees of a local Christian monks’ group.  Three witnesses from the monks’ group testified that their society did not, in fact, own these properties. Their acquisition was not reflected in their Annual General Meeting reports of the years in question. Neither were they reflected in their inventory of properties.\n\nSo, though the accused had purported to have transferred these properties by way of a gift to the monks, evidence showed that he remained in possession and control of these properties. He also retained the land titles. The fact that the accused did not declare these properties in his Asset Declarations led to an inference that he had obtained them illicitly.\n\n### Luxury cars\n\nIn the third count, the court found that between 2010 and 2012, the accused was in control and possession of four motor vehicles worth a total value of UGX 769,473,835 (208,145 USD), which was disproportionate to his known sources of income. One of these vehicles was a Mercedes Benz worth a whopping UGX 544,594,287 (USD 147,315).  \n\nStrangely, the accused registered this luxurious vehicle in the name of a Christian monk who was his family friend. The other three vehicles were also registered in the names of accomplices. However, the court established that the accused owned and was in control of the said vehicles.\n\n### Asset Declaration – untrue, incomplete and incorrect\n\nThe court noted that the requirement for public servants to make Asset Declarations under the Leadership Code Act is not a mere formality but a legal requirement. Those who make the declarations undertake that the information they give is true, complete and correct. Any property or source of income that is not included in the asset declaration is therefore viewed with suspicion, and its omission must be sufficiently explained by the accused. \n\nThe court rejected the accused’s defence that he could have afforded this lifestyle since he had worked for 18 years in various positions. The court noted that even if his income were aggregated for all those years and even if he had not spent anything in all that time, the assets he was holding would still be hugely disproportionate to his known sources of income.\n\nThe accused was sentenced to suffer a total of 15 years’ imprisonment.  The court also issued confiscation orders against the three plots of land and the four motor vehicles described above. The accused was also disqualified from public office for a period of ten years. Prosecutors at the Inspectorate of Government will now work hard to ensure that the confiscation orders are executed and that the properties are realised.\n\n### Paving the way for illicit enrichment prosecutions in Uganda\n\nAt the time of writing, it was not clear whether the accused had exercised his right to appeal. Nevertheless, this case has set an excellent foundation for jurisprudence to be developed on the offence of illicit enrichment in Uganda. It is hoped that similar charges will be brought against other public servants in Uganda who have illicitly acquired enormous wealth, thereby deterring others from attempting the same.\n\nFor this to happen, it is essential to build strong capacity to investigate and prosecute cases of illicit enrichment. Through its International Centre for Asset Recovery, the Basel Institute on Governance has conducted high-impact [Financial Investigations and Asset Recovery training](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) in Uganda and many other African countries. Specifically covered in these training programmes is the “Source and Application Analysis of Funds” method of calculating the illicit wealth of an individual, elements of which appear to have been considered during this prosecution together with additional supporting evidence.\n\nThe Basel Institute also offers a practical introduction to the [Source and Application](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=17) method as a free eLearning module on its LEARN virtual learning website.\n\n### Further reading\n\n*   [Full judgment of the Uganda vs. Geoffrey Kazinda case (HCT-AC\u002FCO NO. 004\u002F2016)](https:\u002F\u002Fulii.org\u002Fug\u002Fjudgment\u002Fhc-anti-corruption-division-uganda\u002F2020\u002F3)\n*   See also Tom Walugembe’s description of [Uganda’s first successful money laundering prosecution](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fbreaking-new-ground-prosecuting-first-money-laundering-case-uganda) and its implications for the country’s fight against corruption and money laundering.\n*   Andrew Dornbierer's quick guide to illicit enrichment gives a brief overview into this legal mechanism for non-specialists. It's available in [English](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28), [French](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28&lang=fr), [Spanish](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28&lang=es) and [Portuguese](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28&lang=pt) on the Basel Institute's LEARN platform.","2020-11-18","uganda-achieves-landmark-victory-in-usd-125-million-illicit-enrichment-case-1916","Uganda achieves landmark victory in USD 1.25 million illicit enrichment case","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F7911f6da-6b25-4363-9e77-1cf9431a7a88?width=1000&height=650&format=webp&quality=80",[229],7380,[52],[54],[233],{"tags_id":234},{"id":235,"name":236},1215,"Illicit financial flows",1916,[62],[54],[241],1205,[],[22],[],"2022-05-26T22:53:53.000Z",[],"\u002Fresources\u002Fnews\u002Fuganda-achieves-landmark-victory-in-usd-125-million-illicit-enrichment-case-1916",{"id":249,"body":250,"status":6,"type":10,"date":251,"slug":252,"title":253,"image":254,"countries":255,"topic":257,"activity":258,"tags":259,"nid":266,"topics":267,"activities":268,"authors":269,"images":270,"websites":271,"area":20,"programme":20,"language":20,"translations":272,"translation_of":20,"user_created":68,"date_created":273,"user_updated":70,"date_updated":274,"content":275,"link":276},9573,"This case study examines a 2021 unexplained wealth (illicit enrichment) case in Kenya involving a former Chief Accountant at the Treasury, Patrick Ochieno Abachi.\n\nThe case is related to Kenya’s so-called Anglo Leasing scandal, in which 18 high-value government security contracts were allegedly awarded to fictitious companies in the early 2000s. It illustrates one set of circumstances in which civil unexplained wealth (or civil illicit enrichment) legislation can be an extremely useful tool to target assets stolen through corruption.\n\nThe series of judgments has provided some valuable insights into Kenya’s law targeting unexplained assets, specifically:\n\n*   its key features and how they are applied;\n*   the evidentiary importance of asset declaration forms;\n*   how to prove assets are “unexplained” through financial analysis of a suspect’s income and assets; and\n*   common legal challenges to illicit enrichment.\n\nPhillip Kagucia, Assistant Director at Kenya’s [Ethics and Anti-Corruption Commission](https:\u002F\u002Feacc.go.ke\u002Fdefault\u002F) (EACC), which is leading the case, spoke to Andrew Dornbierer, Asset Recovery Specialist and author of the recent open-access book [_Illicit Enrichment: A Guide to Laws Targeting Unexplained Wealth_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fillicit-enrichment-guide-laws-targeting-unexplained-wealth). Chapter 5 of book contains a contribution by Kagucia on Kenya’s law and its application.\n\nThe Basel Institute’s International Centre for Asset Recovery ([ICAR](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery)) has been supporting the EACC with case mentoring and capacity building since 2013.\n\n### About the case: the accumulation of unexplained assets through corrupt procurement contracts\n\nPatrick Ochieno Abachi was a Chief Accountant at the Kenyan Treasury at the time of the [Anglo Leasing scandal](https:\u002F\u002Fwww.ft.com\u002Fcontent\u002Fbf75a7ee-c7f9-11e4-8210-00144feab7de), which involved a suite of government procurement contracts allegedly being awarded at inflated values to phantom companies.\n\nAbachi is not among the 20 former politicians and businesspeople charged with criminal offences in relation to the scandal. Yet in [March 2021](http:\u002F\u002Fkenyalaw.org\u002Fcaselaw\u002Fcases\u002Fview\u002F210192\u002F), the High Court of Kenya found that Abachi had used his position as Chief Accountant to acquire unexplained assets around the time the Anglo Leasing contracts were awarded, in accordance with [Section 55 of Kenya’s Anti-Corruption and Economic Crimes Act 2003](https:\u002F\u002Flearn.baselgovernance.org\u002Fmod\u002Fdata\u002Fview.php?d=5&rid=112&filter=1) (ACECA).\n\nAbachi’s sudden increase in wealth during this time could not be justified by reference to his lawful income as a public servant, which was below USD 1,000 a month.\n\nThe court ordered the confiscation of several bank accounts, KES 1.9 million (USD 17,000) in cash, five luxury vehicles, five properties and nine plots of land from Abachi. Some of these were registered in the names of Abachi’s wife, children and companies associated with him. \n\nAlthough Abachi applied for a stay pending appeal, claiming he would suffer losses if the State were to forfeit the assets, the High Court [quashed the application in July 2021](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-08\u002FRuling%20Abachi%20Stay%20Dismissed.pdf) because there was no demonstrable loss in respect of assets the same court had declared to be unexplained.\n\nFurther appeal opportunities exist, but there is a definite chance that the case will finally be determined in favour of the EACC. The properties and vehicles would then be liquidated and the money ultimately forfeited to the public treasury.\n\n### Legal strategy: Why target unexplained assets through civil action?\n\nKenya’s ACECA provision targeting \"unexplained assets\" is a form of qualified civil illicit enrichment law, meaning that proceedings under this provision take place in civil courts rather than criminal courts. This is useful in cases where a criminal conviction for corruption or abuse of office is not possible, but where there is still strong evidence that the public official has inexplicably accumulated an amount of wealth that cannot be justified by reference to their legal income.\n\nAfter examining the facts in Abachi’s case, the EACC deemed it would be difficult to obtain the direct evidence of specific corrupt behaviour that is necessary to bring a criminal case. On the other hand, there was clear evidence that Abachi had amassed a large amount of unexplained wealth during the period in which the corruption scheme took place, and Kenya’s ACECA provisions still provided the EACC with an avenue to target these assets.\n\nThe characteristics of the case also meant that there was a strong chance of success in an unexplained assets claim. Specifically, there was:  \n\n*   A clear time period for the investigation (2002 to 2007 – the time during which the fictitious Anglo Leasing contracts were approved and payments were made);\n*   A reasonable suspicion of corruption or economic crime (due to Abachi’s role as Chief Accountant at the Treasury responsible for making or overseeing payments, including the alleged illicit payments to the phantom companies);\n*   Assets whose value were provably disproportionate to the official’s known sources of income during that period (which they significantly were, given his modest salary and the amounts declared on his asset declaration form); and\n*   No clear satisfactory explanation for the disproportionate assets (as Abachi was not able to provide this during the investigation)\n\n### How the EACC established that Abachi’s assets were \"unexplained\"\n\nThe investigators performed detailed financial analysis to demonstrate that Abachi’s assets were vastly disproportionate to his legal sources of income during the period from 2002 to 2007.\n\nDuring the period, the EACC was able to establish that Abachi was making regular significant deposits to bank accounts and had acquired properties worth around KES 80 million (USD 736,000), despite his modest salary and lack of pre-existing wealth.\n\nA key piece of evidence was the biennial Declaration of Income, Assets and Liabilities that Kenyan officials must submit when they enter public service. This document is generally quite important in such actions. It can be used to establish the suspect’s declared wealth at the start of the period under investigation, and provides a good foundation for analysis.\n\nAdditionally, for obvious reasons, corrupt officials will often deliberately avoid declaring stolen money on this form – and proof that certain assets were undeclared can also add weight to arguments that they were not acquired legitimately.\n\n### Challenges, delays and appeals\n\nWhile the action to date has been successful (pending appeal), the process has been a long one – or as Judge Mumbi Ngugi noted in her March 2021 decision itself: “This matter has had a rather long sojourn in our courts.\"\n\nThe unexplained assets law in Kenya is still in its early days of development, however, so these delays were somewhat expected.\n\nOne reason for an initial delay was a lack of clarity regarding the court process itself. Due to the presence of land among the assets, the case was first referred to the court’s specialist land division, where it struggled to proceed. Following the establishment of a specialised Anti-Corruption and Economic Crimes division of the High Court, the case was transferred accordingly and made progress.\n\nA second reason for the length of proceedings to date has been the significant number of legal challenges made to the law – or in the words of the Judge Ngugi, since the original summons was issued, “a series of suits, petitions and applications have derailed the hearing”. This, too, was not wholly unexpected – as mentioned above, the law is still somewhat in its infancy in Kenya and a number of legal questions regarding it still need to be considered.\n\n### Beneficial ownership: what about assets under another’s name?\n\nA particular challenge for the EACC in the Abachi case related to beneficial ownership, since many of the assets were registered in the names of his wife, children or companies that he controlled.\n\nThese parties were listed as defendants in the court judgement, which is possible in Kenya because the illicit enrichment law applies to any legal or natural person. (In other jurisdictions, it sometimes applies narrowly to public officials.)\n\nEvidence from the EACC’s financial investigation showed clearly the flows of money, proving that the assets were bought with money that came into Abachi’s possession and that he was in fact their beneficial owner. The fact that these parties did not make any significant effort to defend their ownership of the relevant properties also somewhat convinced the judge that it was Abachi himself who was the true owner.\n\nBeneficial ownership is fairly new territory in Kenya, setting a precedent that persons accused of illicit enrichment will no longer be able to hide their assets behind companies, relatives or friends. Assets that have been illicitly obtained remain illicit, no matter how many transactions or transfers of ownership they undergo.\n\n### The road ahead for illicit enrichment legislation in Kenya\n\nAlthough the law was introduced in 2003 in Kenya, it was first applied only in 2008 in long-running but ultimately successful cases against James Mwathethe Mulewa (former head of Kenya’s Port Authority) and [Stanley Mombo Amuti](http:\u002F\u002Fkenyalaw.org\u002Fcaselaw\u002Fcases\u002Fview\u002F172924\u002F) (former National Water Conservation and Pipeline Corporation Finance Manager). The decision in the Court of Appeal over the Amuti case set the precedent for unexplained wealth cases in Kenya.\n\nSince then, the EACC has seen a 100 percent success rate in subsequent cases, with several million USD recovered in total.\n\nMany more cases are under investigation currently or going through the courts. It is hoped that cases will be resolved more speedily as prosecutors and judges at the Anti-Corruption and Economic Crimes division of the High Court become more familiar with the law, and as investigators gain skills in obtaining evidence of illicit enrichment through financial investigation and techniques such as Source and Application analysis.\n\nThe slow start-up phase of Kenya’s law is common among jurisdictions that have illicit enrichment legislation of one form or another, since it is a relatively novel area of law. Yet as Kenya’s EACC (and corrupt politicians and officials) are discovering, it is a powerful tool in the country’s fight against corruption. Plus, alongside its strong civil forfeiture mechanism, it can also play a key role in the recovery of criminal proceeds.\n\n### Learn more\n\nTo learn more about illicit enrichment and how different jurisdictions are introducing laws targeting unexplained wealth, see:\n\n*   [_Illicit Enrichment: A Guide to Laws Targeting Unexplained Wealth_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fillicit-enrichment-guide-laws-targeting-unexplained-wealth) by Andrew Dornbierer. The book is freely available online to view or download at [illicitenrichment.baselgovernance.org](https:\u002F\u002Fillicitenrichment.baselgovernance.org\u002F), along with a database of laws.\n*   For a brief introduction, see our [quick guide to illicit enrichment,](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-5-illicit-enrichment) also available in French, Spanish and Portuguese.\n\nSource and Application of Funds analysis is a method for investigators and prosecutors to calculate and obtain evidence of unexplained assets in cases such as the one described in this study. See:\n\n*   [Quick guide to analysing a suspect’s financial affairs in a corruption case](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-22-analysing-suspects-financial-affairs-corruption-case) by the ICAR training team\n*   Technical guidance for investigators and prosecutors: [Proving illicit enrichment using financial investigation and Source and Application of Funds analysis](https:\u002F\u002Flearn.baselgovernance.org\u002Fpluginfile.php\u002F59289\u002Fmod_resource\u002Fcontent\u002F1\u002FIllicit_Enrichment_Annex_2-PAGES.pdf) (Annex II of _Illicit Enrichment_)\n*   A [free eLearning course on Source and Application analysis](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=17) on the Basel LEARN virtual learning platform.","2021-08-12","case-study-upholding-an-unexplained-wealth-judgement-in-kenyas-anglo-leasing-affair-2072","Case study: Upholding an unexplained wealth judgement in Kenya’s Anglo Leasing affair","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F0812f116-d225-4f8a-a141-417b7aa801b6?width=1000&height=650&format=webp&quality=80",[256],7310,[52],[133],[260,264],{"tags_id":261},{"id":262,"name":263},821,"Unexplained wealth",{"tags_id":265},{"id":235,"name":236},2072,[62],[133],[],[],[22],[],"2022-05-26T22:52:41.000Z","2026-05-29T22:21:43.000Z",[],"\u002Fresources\u002Fnews\u002Fcase-study-upholding-an-unexplained-wealth-judgement-in-kenyas-anglo-leasing-affair-2072",{"left":278,"top":278,"width":279,"height":279,"rotate":278,"vFlip":280,"hFlip":280,"body":281},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>",1780676500010]