[{"data":1,"prerenderedAt":368},["ShallowReactive",2],{"news-not-just-for-lawyers-learning-your-way-into-anti-corruption-2822":3,"news-not-just-for-lawyers-learning-your-way-into-anti-corruption-2822-similar":123,"i-heroicons:arrow-left-20-solid":363},[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":18,"topics":19,"activities":21,"programme":22,"area":22,"websites":22,"language":23,"image":24,"translation_of":22,"countries":34,"tags":35,"authors":103,"images":120,"translations":121,"content":122},10564,"published","2025-07-13T11:42:47.000Z","2026-05-29T22:22:37.000Z","Not just for lawyers: learning your way into anti-corruption","Blog","_Our Senior Communications and External Relations Specialist Monica Guy looks back on how a curious mind paired with diverse learning opportunities and the desire to make an impact can pave the way into anti-corruption. This article is part of a series on careers in fighting financial crime and opportunities to learn and study with the Basel Institute._\n\nOne of the many things I’ve learned at the Basel Institute on Governance is that rewarding jobs in the field of countering financial crime are not just for those who woke up aged 10 and said: “Mummy, I want to be an anti-corruption prosecutor”. Or who studied business and law with the dream of becoming a compliance officer.\n\nMy own journey has been rather zig-zaggy, from caring for Stephen Hawking to managing multilingual content projects for Google and big companies in the travel and shipping industries. And a lot in between.\n\nEducation and continuous learning have been crucial in giving me the flexibility to bounce from one thing to another and hopefully make at least a tiny bit of impact on the way.\n\n### From dusty libraries to blended learning\n\nI didn’t learn much of practical use during my first degree in Classics at Cambridge. But it was a good way to learn to think, read, write and argue with clever people about the world with all its wonders and weirdness. That’s something I have to do a lot in my communications role at the Basel Institute, though thankfully not in ancient Greek.\n\nMy first master’s in interactive communications at Quinnipiac University was one of the earliest “blended learning” degree courses. I.e. hybrid classes and the (then) revolutionary idea that it’s better to learn the theory in advance and use precious class time to practise and discuss.\n\nWhat was in 2010 the cutting edge of communications now looks like stone-age cave paintings. But it did give me the basics to start building websites (early web design = animated cave paintings) and think a bit more strategically about things like audience, purpose and how communications and social media tactics can be used for good or ill. That has been of real practical value in our efforts to build the Basel Institute’s visibility and reputation over the last years.\n\n### Digging deeper (but I wish Basel STUDY had existed then)\n\nYou can’t be successful in communicating if you don’t understand what you’re talking about. So during covid times I took another master’s course, this time in sustainable development at SOAS University of London. I wanted that deeper understanding of topics like poverty, globalisation and environment that are fundamental to the work the Basel Institute does.\n\nThis degree was fully online and designed to fit alongside a full-time job. But I’ll be honest: if our [Basel STUDY](https:\u002F\u002Fbaselgovernance.org\u002Fstudy) courses had existed then, I’d have gladly taken them instead.\n\nBasel STUDY – that's our postgraduate programmes with the University of Basel: they are six months, hands-on, with live classes and in-person meetings, top-notch instructors and a diverse group of other participants with real-world experience. That’s a lot more fun, useful and digestible than a two-year master's degree, plus easier to combine with other modules and qualifications.\n\n### Free or low-cost learning\n\nI absolutely know that I’ve been privileged to be able to study at good universities, with grants and jobs to pay the way.\n\nBut I’ve also learned a lot through MOOCs (Massive Online Open Courses) and other free or low-cost online learning opportunities from organisations like Coursera and the University of Leiden. And of course the crème de la crème of eLearning: our own free [Basel LEARN courses](https:\u002F\u002Flearn.baselgovernance.org\u002F) on countering financial crime.\n\n### A desire to learn\n\nAll this to say that you don’t need to be a “financial crime professional” to play a part in making the world a better place.\n\nJust as you don’t need to be a “communications professional” to communicate effectively about countering corruption, fostering good governance, catalysing asset recovery and all the other difficult but worthwhile things we do here in Basel and around the world.\n\nWhat you do need is a desire to learn – from courses, peers and colleagues.\n\n### Join in\n\nMy “call to action”? Take a look at the opportunities we offer at the Basel Institute for individuals who also burn to learn about countering corruption and financial crime and build practical skills they can apply in their daily work:\n\n*   [Basel LEARN](https:\u002F\u002Flearn.baselgovernance.org\u002F) – our online training and learning hub with free eLearning courses and lots more\n*   [Basel STUDY](https:\u002F\u002Fbaselgovernance.org\u002Fstudy) – our new academic programmes with the University of Basel on anti-corruption and asset recovery\n*   Our forthcoming open course on [Introduction to blockchain: crypto investigation and AML compliance](https:\u002F\u002Fbaselgovernance.org\u002Fcrypto-aml-training)","2025-06-26",[14],"","not-just-for-lawyers-learning-your-way-into-anti-corruption-2822",[17],"Insights",2822,[20],"Corruption Prevention and Public Governance",[17],null,"English",{"id":25,"storage":26,"filename_disk":27,"filename_download":28,"title":9,"type":29,"created_on":7,"modified_on":7,"charset":22,"filesize":30,"width":31,"height":32,"duration":22,"embed":22,"description":22,"location":22,"tags":22,"metadata":33,"focal_point_x":22,"focal_point_y":22,"tus_id":22,"tus_data":22,"uploaded_on":7},"99b2b185-92d4-46cc-8c21-6b0c8f20cf39","local","99b2b185-92d4-46cc-8c21-6b0c8f20cf39.webp","tmp.webp","image\u002Fwebp",21170,800,533,{},[],[36,58,73,88],{"id":37,"news_id":38,"tags_id":55},5553,{"id":5,"status":6,"user_created":39,"date_created":7,"user_updated":40,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":41,"slug":15,"activity":42,"nid":18,"topics":43,"activities":44,"programme":22,"area":22,"websites":22,"translation_of":22,"language":23,"countries":45,"tags":46,"authors":50,"images":52,"translations":53,"content":54},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","3d9ff205-1640-4f34-b5b6-86977f51bbd6",[14],[17],[20],[17],[],[37,47,48,49],5556,5645,5646,[51],1346,[],[],[],{"id":56,"name":57},982,"Anti-corruption",{"id":47,"news_id":59,"tags_id":70},{"id":5,"status":6,"user_created":39,"date_created":7,"user_updated":40,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":60,"slug":15,"activity":61,"nid":18,"topics":62,"activities":63,"programme":22,"area":22,"websites":22,"translation_of":22,"language":23,"countries":64,"tags":65,"authors":66,"images":67,"translations":68,"content":69},[14],[17],[20],[17],[],[37,47,48,49],[51],[],[],[],{"id":71,"name":72},867,"Financial crime",{"id":48,"news_id":74,"tags_id":85},{"id":5,"status":6,"user_created":39,"date_created":7,"user_updated":40,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":75,"slug":15,"activity":76,"nid":18,"topics":77,"activities":78,"programme":22,"area":22,"websites":22,"translation_of":22,"language":23,"countries":79,"tags":80,"authors":81,"images":82,"translations":83,"content":84},[14],[17],[20],[17],[],[37,47,48,49],[51],[],[],[],{"id":86,"name":87},1300,"Education",{"id":49,"news_id":89,"tags_id":100},{"id":5,"status":6,"user_created":39,"date_created":7,"user_updated":40,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":90,"slug":15,"activity":91,"nid":18,"topics":92,"activities":93,"programme":22,"area":22,"websites":22,"translation_of":22,"language":23,"countries":94,"tags":95,"authors":96,"images":97,"translations":98,"content":99},[14],[17],[20],[17],[],[37,47,48,49],[51],[],[],[],{"id":101,"name":102},1372,"Training",[104],{"id":51,"news_id":105,"authors_id":116},{"id":5,"status":6,"user_created":39,"date_created":7,"user_updated":40,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":106,"slug":15,"activity":107,"nid":18,"topics":108,"activities":109,"programme":22,"area":22,"websites":22,"translation_of":22,"language":23,"countries":110,"tags":111,"authors":112,"images":113,"translations":114,"content":115},[14],[17],[20],[17],[],[37,47,48,49],[51],[],[],[],{"id":117,"name":118,"position":22,"image":119},296,"Monica Guy","6d95cf25-5e8f-4eb1-b46a-daca726475db",[],[],[],[124,155,180,208,233,266,291,315,339],{"id":125,"body":126,"status":6,"type":10,"date":127,"slug":128,"title":129,"image":130,"countries":131,"topic":22,"activity":22,"tags":132,"nid":22,"topics":133,"activities":137,"authors":140,"images":142,"websites":143,"area":144,"programme":147,"language":23,"translations":149,"translation_of":22,"user_created":150,"date_created":151,"user_updated":40,"date_updated":152,"content":153,"link":154},10590,"This feature appears in the 2025 Basel AML Index Public Edition report. \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads\">Download the full report and related resources\u003C\u002Fa>.\n\n\u003Cblockquote>\n\u003Ch3>Key takeaways\u003C\u002Fh3>\n\n\u003Cp>\u003Cstrong>Understanding national risks linked to virtual assets is now essential\u003C\u002Fstrong>, as their use has moved from niche to mainstream and is increasingly exploited for financial crime. \u003C\u002Fp>\n\n\u003Cp>\u003Cstrong>Risk assessments are inherently challenging \u003C\u002Fstrong>as (a) virtual assets are borderless by design, (b) large parts of the ecosystem fall outside regulation and (c) reliable national-level data remains limited. \u003C\u002Fp>\n\n\u003Cp>\u003Cstrong>Illicit activity involving virtual assets does not take place in isolation\u003C\u002Fstrong>: offenders exploit the same weaknesses – corruption, fraud, weak supervision and poor enforcement – that already undermine the wider financial system. \u003C\u002Fp>\n\n\u003Cp>\u003Cstrong>The Basel AML Index provides valuable indicators to assess both a jurisdiction’s structural vulnerabilities and its capacity to counter threats \u003C\u002Fstrong>related to financial crimes in general, including those related to virtual assets, even though it does not include a dedicated virtual assets risk indicator. \u003C\u002Fp>\n\u003C\u002Fblockquote>\n\n\u003Cem>Note: in this article we use the term virtual assets in line with the FATF’s \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Fvirtual-assets.html\">definition\u003C\u002Fa> of “any digital representation of value that can be digitally traded, transferred or used for payment”. The terms crypto, cryptoassets, digital assets, digital currencies, etc. form part of this loose family, though they are often defined differently in different contexts – a factor that also complicates risk assessments and data analysis.\u003C\u002Fem>\n\n\u003Ch3>\u003Cstrong>Why assessing risks related to virtual assets matters \u003C\u002Fstrong>\u003C\u002Fh3>\n\nGovernments and private firms alike are under growing pressure to understand the risks associated with virtual assets. What was once a niche is becoming a mainstream part of financial markets and a common feature in all forms of financial crime.\n\nAs the virtual assets industry continues to mature, national authorities that lack a clear understanding of the risks find themselves on the back foot when drafting legislation, supervising market participants or countering financial crime.\n\nFor financial institutions, a clear picture of jurisdiction-level risk is essential for customer due diligence, transaction monitoring, calibrating controls and taking strategic decisions about where or where not to operate. Financial institutions that misjudge these risks leave themselves exposed to illicit finance, reputational harm and potential regulatory action.\n\n\u003Ch3>Why jurisdiction-level risk assessments are difficult\u003C\u002Fh3>\n\n\u003Ch4>1. A borderless system by design\u003C\u002Fh4>\n\nUnlike bank accounts or trust funds, virtual asset wallets or addresses do not have a meaningful jurisdictional location. There is no crypto equivalent of “a bank account in Switzerland”. A wallet can be accessed anywhere and may be controlled by a person or entity whose location is unknown or easily obscured. Large parts of the virtual asset ecosystem also fall outside the boundaries of traditional financial regulation. Self-hosted wallets, peer-to-peer transfers, decentralised finance (DeFi) protocols and informal over-the-counter (OTC) brokers create pockets of activity that are largely invisible. Any jurisdiction-level assessment will inevitably be incomplete.\n\nThe activities of virtual asset service providers (VASPs) further complicate matters. A VASP may be established in one jurisdiction while primarily serving customers in another. In the absence of harmonised legislation or cooperation among supervisors, many operate across numerous markets with minimal physical presence or regulatory engagement.\n\n\u003Ch4>2. Data is limited, patchy and uncertain\u003C\u002Fh4>\n\nReliable quantitative data on financial crime risks related to virtual assets at the national level is scarce. In addition to the issue of contrasting definitions and the technology’s borderless nature, several factors contribute to this lack.\n\nFirst, commercial blockchain analytics providers publish broad indicators of virtual asset adoption and estimates of illicit usage. These can be helpful for spotting trends but require careful interpretation. They rely on estimates and proxies, including web traffic to exchanges or intermediaries, and do not provide precise amounts or reliably distinguish licit from illicit activity.\n\nSecond, it is reasonable to assume that where adoption rises, illicit activity will also increase, simply because criminals use the same infrastructure as legitimate users. However, such relationships cannot be measured with confidence.\n\nThird, at the government level, many jurisdictions still lack a coordinated approach across authorities to collect, share and analyse statistics on money laundering and related financial crimes. In many jurisdictions, data on virtual assets is either not gathered consistently or not collected at all.\n\nWithout reliable data on virtual assets usage and risks, national risk assessments may become detached from real-world threats. The result: regulation and supervision that is either insufficient or unnecessarily burdensome.\n\n### How the Basel AML Index can be used\n\nFor the above reasons, the Basel AML Index does not offer a dedicated indicator for virtual assets. Nevertheless, the Index data is still useful because illicit activity involving virtual assets typically exploits the same underlying weaknesses that enable money laundering, corruption, fraud and other financial crimes in the traditional financial system. Where protections against fraud are weak, for example, where supervision is lacking or where enforcement of regulations is inconsistent or politically compromised, opportunities to misuse virtual assets for illegal purposes tend to expand.\n\n\u003Cblockquote>\n\u003Cstrong>Two components of risk \u003C\u002Fstrong>\n\nIn line with the holistic methodology of the Basel AML Index and most AML\u002FCFT risk assessment frameworks, evaluating jurisdiction-level risk related to virtual assets centres on two elements:\n\n\u003Cp>a) \u003Cem>vulnerability \u003C\u002Fem>to the illicit use of virtual assets; and b) \u003Cem>capacity to mitigate \u003C\u002Fem>and respond to these threats. \u003C\u002Fp>\n\u003C\u002Fblockquote>\n\n### Relevant indicators\n\nThe following graphic highlights indicators of the Basel AML Index that are relevant for assessing either \u003Cem>structural vulnerabilities \u003C\u002Fem>that illicit actors may exploit, or a jurisdiction’s \u003Cem>capacity to counter \u003C\u002Fem>threats. These can be viewed individually in the Expert Edition.\n\n![](https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F7f446525-136f-4018-a322-8a4e8872f23b) *Indicators visible in the Basel AML Index Edition that are particularly relevant to assessing national risks relating to virtual assets.*\n\n\n#### FATF data\n\nUsing the Expert Edition Plus subscription and its quantitative analysis of the latest FATF mutual evaluation and follow-up reports, Basel AML Index users can gain rapid insights into whether a jurisdiction’s AML\u002FCFT framework provides it with the capacity to \u003Cem>counter threats \u003C\u002Fem>related to financial crimes generally, including those involving virtual assets. FATF Recommendations that may be highly relevant for this include:\n\n- R.15 (new technologies)\n- R.16 (payment transparency)\n- R.26 & 27 (regulation and supervision)\n- R.29–31 (law enforcement)\n- R.36–40 (international cooperation)\n\nAn additional useful source of information for jurisdiction-level risk assessments is the FATF’s \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Ftargeted-update-virtual-assets-vasps-2025.html\">\u003Cem>2025 Targeted Update on Implementation of the FATF Standards on Virtual Assets and Virtual Asset Service Providers\u003C\u002Fem>\u003C\u002Fa>. This report summarises progress in implementing FATF Recommendation 15 by FATF members and additional jurisdictions with materially important global virtual asset activity. “Materially important” refers to the presence of large VASPs (accounting for more than 0.25 percent of global trading) and\u002For a large virtual asset user base.\n\n### Where to start\n\nFor jurisdictions at an early stage of assessing national risks related to virtual assets, the World Bank’s \u003Cem>\u003Ca href=\"https:\u002F\u002Fopenknowledge.worldbank.org\u002Fentities\u002Fpublication\u002Fbb5a7475-ac52-4697-afdc-5f618a550623\">AML\u002FCFT National Risk Assessment on Virtual Assets and Virtual Asset Service Providers: Guidance Manual\u003C\u002Fa> \u003C\u002Fem>(published in October 2025) is a strong starting point. It covers both threats and vulnerabilities, as well as the effectiveness of mitigation measures.\n\nAdditional useful resources include:\n- \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002F9crc-crypto-regulation\">\u003Cstrong>Practical recommendations from regulators and supervisors\u003C\u002Fstrong>\u003C\u002Fa>, developed at the 9th Global Conference on Criminal Finances and Cryptoassets, on understanding financial crime risks linked to virtual assets and designing effective regulatory and supervisory frameworks.\n- \u003Cstrong>Structured public–private partnerships\u003C\u002Fstrong>, such as the \u003Ca href=\"https:\u002F\u002Fefippp.eu\u002F\">Europol Financial Intelligence Sharing Public Private Partnership\u003C\u002Fa>, which offer opportunities to learn from peers and obtain early insights into emerging threats and financial crime typologies involving virtual assets.\n","2025-12-08","assessing-national-risks-related-to-virtual-assets","Assessing national risks related to virtual assets","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F78f8a1ec-bf8d-469a-ab92-228e79ddd8f2?width=1000&height=650&format=webp&quality=80",[],[],[134,135,136,20],"Anti-Money Laundering","Asset Recovery and Enforcement","Business Integrity Ethics and Compliance",[138,139],"Basel AML Index","Research",[141],1365,[],[138],[145,146],"Asset Recovery & Enforcement","Business Integrity & Governance",[148],"International Centre for Asset Recovery",[],"545a204d-e41b-4882-afda-481ecf3fd971","2025-12-05T11:43:36.000Z","2026-05-29T22:22:39.000Z",[],"\u002Fresources\u002Fnews\u002Fassessing-national-risks-related-to-virtual-assets",{"id":156,"body":157,"status":6,"type":158,"date":159,"slug":160,"title":161,"image":162,"countries":163,"topic":164,"activity":167,"tags":169,"nid":170,"topics":171,"activities":173,"authors":174,"images":175,"websites":22,"area":22,"programme":22,"language":23,"translations":176,"translation_of":22,"user_created":39,"date_created":177,"user_updated":40,"date_updated":8,"content":178,"link":179},10573,"The Basel Institute’s first international postgraduate programme in anti-corruption has begun. 12 students from 11 countries across Africa, Europe and North America are taking part in the six-month course, led by Basel Institute staff and resulting in a Certificate of Advanced Studies from the University of Basel.\n\nThe course, [Mastering Today’s Anti-Corruption Challenges](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fbasel-study\u002Fcas-anti-corruption), equips mid-career professionals with the tools, skills and networks to address corruption and governance challenges in their work.\n\nLead instructor Dr Claudia Baez Camargo, Director of the Institute’s Prevention, Research and Innovation team, explained:\n\n> Through this programme, participants will not only deepen their understanding of corruption in today’s complex world, but also learn to evaluate the real evidence on what works. Most importantly, they will be empowered to apply these insights with confidence in their own countries and professional contexts, helping to strengthen integrity and good governance where it matters most.\n\n### Shaping the next generation of anti-corruption leaders\n\nThree participants attended the opening event on 26–27 September in person in Basel, while those unable to travel joined the sessions online.\n\nThe first cohort is made up of peers with diverse academic backgrounds – including legal, economic, political and other disciplines – and professional experience in the public, private and civil society sectors, in multilateral organisations and the media.\n\nThey were welcomed by the Basel Institute’s President Peter Maurer and Executive Director Betsy Andersen, together with the Basel STUDY team and instructors.\n\nVisits to the University of Basel and the historic centre gave participants and instructors the chance to bond while exploring Swiss traditions.\n\nThe participants who attended the launch in person described themselves as:\n\n> “excited”, “grateful” and “honoured”.\n\nAsked what she hoped to get out of the course, Tamara Lee, a Business Analyst and Project Manager from Ireland, said:\n\n> I hope I’ll learn to see corruption issues with a sharper, more professional lens. Instead of falling back on the usual buzzwords or the kind of surface-level ideas we see on social media or hear in conversations, I’d like to be able to look at situations in a deeper, more critical way.\n\nDr Ramadhani Marijani, a Senior Lecturer and Researcher at Tanzania’s University of Dodoma, added: \n\n> I hope I can be able to resolve anti-corruption challenges from an African perspective and understand other challenges in the global sphere. I am looking forward to engaging in classes, sharing and learning from other fellow participants from Africa and other countries and from the community of practice fighting the war against corruption globally.\n\nIlinca-Ioana Bīlc, Legal Advisor at a bank in Romania, emphasised her desire to explore a holistic approach to anti-corruption: \n\n> I want to know how I can fight \\[corruption\\] from different angles besides the basic one that everyone expects: you just follow the guidelines and then there will be no corruption. When in fact, the problem is much bigger and we need way more different ways of tackling it. \n\n### Exploring corruption’s links to today’s greatest challenges\n\nSaturday’s classroom sessions with Dr Saba Kassa explored how corruption connects to today’s greatest concerns, from shifting geopolitics and democratic backsliding to migration and climate change. This sets the foundation for modules delivered in live online sessions over the next six months and covering:\n\n*   How corruption and governance impact states, societies and organisations.\n*   The fundamentals of anti-corruption practice, from legal instruments to effective enforcement and prevention.\n*   Novel approaches to anti-corruption, drawing on political and behavioural sciences.\n*   How anti-corruption strategies are implemented internationally – and how they could be made more effective.\n\nStudents will apply their knowledge through a personal study project on a corruption challenge of their choice.\n\n### Scholarship fund opens doors to global talent\n\nSeveral participants benefited from tuition support thanks to generous donors to the [Gretta Fenner Scholarship Fund](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fbasel-study\u002Fscholarship).\n\nThe fund supports applicants from lower-income backgrounds who show strong commitment to anti-corruption, transparency and good governance. It reflects the vision of the Basel Institute’s late Managing Director Gretta Fenner to educate and empower anti-corruption leaders everywhere, regardless of financial means.\n\nOne recipient is Nigerian lawyer Emmanuela OkonkwoAbutu of the Abuja-based African Centre for Governance, Asset Recovery and Sustainable Development. She shared:\n\n> This prestigious study programme... offers a forum to learn from professionals who are influencing the global conversation on anti-corruption… This educational journey would not have been possible without the support of the Gretta Fenner Scholarship Fund.\n\nWe are grateful to The International Academy of Financial Crime Litigators, the Academy’s co-founders Elizabeth Ortega (ECO Strategic Communications), Stéphane Bonifassi (Bonifassi Avocats) and Lincoln Caylor (Bennett Jones), as well as Swiss law firm Kellerhals Carrard for their generous donations to the Fund.\n\n### Expanding opportunities through Basel STUDY\n\n[Basel STUDY](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fbasel-study) – the Basel Institute’s postgraduate programme initiative – is designed to boost the knowledge, skills and careers of professionals committed to countering corruption and financial crime.\n\nIt builds on the Institute’s long-standing capacity-building approach, encouraging peer learning, hands-on practice and real-life cases. The two available Certificate of Advanced Studies programmes combine this practitioner-led spirit with the academic rigour of the University of Basel.\n\nThe second course, [_Combating_ _Financial Crime Through Asset Recovery_](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fbasel-study\u002Fcas-asset-recovery), starts in February 2026. Applications remain open for self-funded or employer-funded participants.\n\n### Learn more\n\n*   Explore other learning opportunities at the Basel Institute, including free eLearning courses on [Basel LEARN](https:\u002F\u002Flearn.baselgovernance.org\u002F), our four-day course on [crypto, financial crime and AML compliance](https:\u002F\u002Fbaselgovernance.org\u002Fcrypto-aml-training), and our flagship [asset recovery training programmes](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) for law enforcement agencies.\n*   Learn about the [Gretta Fenner Scholarship Fund](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fbasel-study\u002Fscholarship) – and consider donating to help change lives and create impact!","News","2025-09-29","global-professionals-begin-new-anti-corruption-studies-2851","Global professionals begin new anti-corruption studies","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fbe4b8143-bba3-4760-8f60-d11dcedc3f7b?width=1000&height=650&format=webp&quality=80",[],[165,166],"Prevention"," Research and Innovation",[168,102],"Courses",[],2851,[20,172],"Prevention Research and Innovation",[168,102],[],[],[],"2025-09-29T16:01:39.000Z",[],"\u002Fresources\u002Fnews\u002Fglobal-professionals-begin-new-anti-corruption-studies-2851",{"id":181,"body":182,"status":6,"type":158,"date":183,"slug":184,"title":185,"image":186,"countries":187,"topic":189,"activity":192,"tags":195,"nid":196,"topics":197,"activities":198,"authors":199,"images":200,"websites":201,"area":22,"programme":22,"language":22,"translations":203,"translation_of":22,"user_created":39,"date_created":204,"user_updated":40,"date_updated":205,"content":206,"link":207},10367,"Business integrity is vital to the health of the vibrant economies of the Asia-Pacific region, as well as of the companies based or seeking to do business in the region. Fostering trust and transparency through [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) between stakeholders – local businesses, foreign investors, governments, civil society – is key to advancing a strong culture of business integrity, levelling the playing field and solving practical challenges that hold back fair business.\n\nBusiness integrity is one of the three pillars of the [Anti-Corruption Initiative for Asia and the Pacific (ACI)](https:\u002F\u002Fevents.development.asia\u002Flearning-events\u002Fanti-corruption-initiative-asia-and-pacific) of the Asian Development Bank (ADB) and Organisation for Economic Co-operation and Development (OECD). The initiative was formed in 1999 to cooperate with governments in the fight against corruption and support national and multilateral efforts to reduce corruption in Asia and the Pacific. The ACI includes two additional pillars: Law Enforcement and Public Integrity.\n\nWe are delighted to have joined the ACI’s Advisory Group, alongside representatives from the Australian Attorney General's Office and Federal Police, Transparency International and UNODC among others. This marks an expansion of our role, building on our [Private Sector team](https:\u002F\u002Fbaselgovernance.org\u002Fprivate-sector)’s ongoing support to the ACI’s Working Group on Business Integrity launched in 2019.\n\n### 11th Regional Conference – exploring Collective Action\n\nThe ACI’s [11th Regional Conference](https:\u002F\u002Fevents.development.asia\u002Flearning-events\u002F11th-regional-conference-pandemic-recovery-building-resilient-economies-through) in Manila, Philippines, from 9–11 May was the first in-person meeting and conference since the Covid-19 pandemic, making it a valuable opportunity to map out pathways for future work. These will follow the Initiative’s mandate to support the 34 member governments in three core areas:\n\n*   Policy dialogue and sharing anti-corruption best practices at the regional meetings and conferences\n*   Policy analysis, including thematic reviews and stocktaking\n*   Corruption prevention and law enforcement capacity development activities\n\nAt a plenary on business integrity moderated by our Head of Private Sector Vanessa Hans, representatives from the Malaysia-based Business Integrity Alliance, Thai Collective Action Against Corruption and National Commission of Supervision of China explored how Collective Action can support prevention efforts in the region. The plenary was followed by a breakout session facilitated by Vanessa Hans in order to identify Collective Action initiatives in the region and share best practices.\n\nEmphasising the importance of the ACI due to its scope, reach and the involvement of so many motivated and knowledgeable professionals, Vanessa Hans said:\n\n> The ACI is a great platform for peer learning and showcasing of best practices in the anti-corruption community within Asia and the Pacific. Topics of business integrity and the benefits of anti-corruption Collective Action have been central to the discussions during the conference. We at the Basel Institute are honoured to be able to support this initiative. \n\n### Looking back\n\nOur support to the ACI’s Advisory Group looks back to the former role of our Managing Director Gretta Fenner as the founding Programme Manager of the ACI in 1999\u002F2000.\n\nAt that time, the group endorsed the first ever regional collaborative framework to combat corruption in the Asia-Pacific region (the Anti-Corruption Action Plan for Asia-Pacific). The group continued to lead innovation in the fight against corruption, for example in the immediate aftermath of the 2004 Indian Ocean tsunami, when the ACI swiftly brought together governments, the private sector and civil society to address urgent corruption risks and prevention mechanisms in the tsunami reconstruction process. \n\nThis was a pioneering approach at a time when multistakeholder collaboration through Collective Action was still a novel concept.\n\n### Looking ahead\n\nWe look forward to continuing to support the ACI through the Advisory Group as we increase our anti-corruption work and partnerships in the region.\n\nSave the date, among other things, for our regional Collective Action Forum in the Philippines on 25 September 2023. This will follow a similar format to our [Southern Africa Collective Action Forum](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fevents) on 31 May 2023 and include a regional [award](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fawards) for an outstanding anti-corruption Collective Action initiative.\n\nQuestions? Ask our [Collective Action Helpdesk](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fhelpdesk).","2023-05-30","fostering-anti-corruption-in-asiapacific-through-collective-action-2456","Fostering anti-corruption in Asia–Pacific through Collective Action","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F83af013f-7599-4d69-bc8e-2ddadbe40481?width=1000&height=650&format=webp&quality=80",[188],7182,[190,191],"Collective Action","Private Sector",[193,194],"Events","International cooperation",[],2456,[190,191,20],[193,194],[],[],[202,190],"Main page",[],"2023-05-30T16:01:25.000Z","2026-05-29T22:22:26.000Z",[],"\u002Fresources\u002Fnews\u002Ffostering-anti-corruption-in-asiapacific-through-collective-action-2456",{"id":209,"body":210,"status":6,"type":10,"date":211,"slug":212,"title":213,"image":214,"countries":215,"topic":216,"activity":218,"tags":220,"nid":221,"topics":222,"activities":223,"authors":224,"images":226,"websites":227,"area":22,"programme":22,"language":22,"translations":228,"translation_of":22,"user_created":39,"date_created":229,"user_updated":40,"date_updated":230,"content":231,"link":232},9595,"_During SDC Governance Week, a cross-agency learning event for staff and partners of the Governance network of the Swiss Agency for Development and Cooperation (SDC), the Basel Institute’s Public Governance team will speak about its support to the agency’s development of new strategic anti-corruption guidelines. The process of updating the guidelines aims to reflect evolving risks, emerging understandings of corruption and fresh evidence about effective approaches to anti-corruption interventions._ _In this quick guide, Claudia Baez Camargo, Head of the Basel Institute’s Public Governance team, explains the purpose, focus and value of strategic anti-corruption guidelines for development agencies:_\n\n### In what context do development agencies face corruption issues?\n\nIn their efforts to promote sustainable development around the world, development agencies and their country offices face a variety of corruption risks. Some risks directly threaten funded projects, for example if money intended to finance a new hospital is embezzled, or the building contract is given to the friend of a local politician and at an inflated value. Other corruption risks more indirectly, or at least less visibly, impact the ability of development agencies to achieve their project goals. For instance, if sextortion – the coercive extraction of sexual favours – is prevalent, it will undermine programmes aimed at promoting gender equality. And when corruption is a systemic issue, it hampers sustainable development directly and in multiple ways. Development agencies may therefore consider addressing systemic corruption issues strategically through a dedicated anti-corruption programme.\n\n### What is a “strategic” approach to anti-corruption?\n\nThe above three types of corruption risk that development agencies face often overlap and spring from the same underlying factors. These factors, or drivers, include the political economy and prevailing power relations in a country or community, as well as the social norms that influence people’s behaviour. A strategic approach to anti-corruption in a specific context will therefore always start with a good diagnosis that covers two broad areas:\n\n*   First, the major corruption issues in that country or context that are hindering sustainable development. For example, widespread petty corruption in the health sector or a flawed procurement system that sees inflated contracts going to political cronies.\n*   Second, the underlying drivers of those problems, such as social norms around the need to give “gifts” to health workers, or state capture through powerful networks of elites.\n\nStrategic approaches to anti-corruption will be based on this diagnosis and design projects that are – at the very least – relevant, feasible, sustainable and mindful of risks or unintended consequences.\n\n### Setting out an anti-corruption strategy in black and white – why?\n\nNot all development agencies have written guidelines setting out their strategic approach to anti-corruption. But they have multiple benefits. Their main purpose is to support the development of evidence-based and effective anti-corruption programming decisions. This makes targeted anti-corruption interventions more likely to succeed in their goals, to help the beneficiary communities in tangible ways and to be a good use of taxpayers’ money. By setting out their strategic anti-corruption approach in black and white, the agency leadership clearly signals which areas are important to focus on and how to go about it. This clear messaging is extremely useful for staff in country offices who face the task of identifying which programmes to fund and how best to design them. New staff joining the country office can quickly grasp not only which projects are being implemented and how, but also – very importantly – why. The consistent underlying approach also provides a solid base for learning from the experiences of peers in other country offices.\n\n### Developing the guidelines – a valuable collaborative exercise\n\nLike all strategic documents, the value is not only in the final product but in the process of developing it. What helps tremendously when developing anti-corruption guidelines is to convene a series of discussion groups that bring people from multiple units, disciplines and levels of hierarchy around the table. This is because corruption is a transversal issue, cutting across almost all other thematic areas and professional specialisms. It is not just a topic for the anti-corruption department and external anti-corruption experts, but needs to include the experiences, views and concerns of those working on the ground. Getting a broad range of inputs helps to make the guidelines more robust and reflective of the real challenges that country offices and programme managers face. The process also helps to get buy-in, which is crucial when it comes to implementation. An agile approach with multiple rounds is probably needed. At the Basel Institute, we typically also find it valuable for a partner anti-corruption organisation or expert to sense-check and challenge the drafts. It is worth taking this time to get the strategic guidelines right. This is because unlike hands-on operational guidance documents and tools that may evolve more rapidly, the strategic guidelines are approved at the highest levels of the agency and need to be built to last.\n\n### Turning strategy into practice – implementing the guidelines\n\nStrategic guidelines are not a recipe for what you should do, but a recipe for how you should think and what you should consider. How best can a development agency help staff turn that knowledge into practical action and avoid it getting lost in the heaps of paperwork that country offices inevitably have to deal with? A must-have is an operational guidance document that translates the guidelines into practical resources and tools. Additional short explainers on particular topics, like how to set up a useful monitoring and evaluation system on anti-corruption, are often helpful. But however user-friendly these documents are, they are the basis for discussion and not a substitute for it. Some ideas to encourage dialogue and active implementation are:\n\n*   Short training interventions, in which country staff have the opportunity to raise questions about their specific issues.\n*   Peer learning events on anti-corruption, to share experiences with colleagues and learn what’s working elsewhere.\n*   An on-demand support function for country staff to bounce ideas around and discuss doubts and concerns relating to anti-corruption.\n\n### Learn more\n\n*   Find out more about the [Public Governance](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance) team and its research, training and technical assistance services.\n*   See the team’s dedicated resource site on [informal governance](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance\u002Fresearch-projects\u002Finformal-governance) and its implications for the fight against corruption.\n*   [Download this quick guide as a PDF](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-21-strategic-anti-corruption-guidelines-development-agencies) and [view all quick guides](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428).","2021-06-08","quick-guide-to-strategic-anti-corruption-guidelines-for-development-agencies-2030","Quick guide to strategic anti-corruption guidelines for development agencies","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fa0fa0dd2-78e0-4f03-8a88-be27e982eb93?width=1000&height=650&format=webp&quality=80",[],[217],"Public Governance",[139,219],"Anti-corruption interventions",[],2030,[20],[139,219],[225],807,[],[202],[],"2022-05-26T22:53:01.000Z","2026-05-29T22:21:45.000Z",[],"\u002Fresources\u002Fnews\u002Fquick-guide-to-strategic-anti-corruption-guidelines-for-development-agencies-2030",{"id":234,"body":235,"status":6,"type":10,"date":236,"slug":237,"title":238,"image":239,"countries":240,"topic":242,"activity":244,"tags":245,"nid":254,"topics":255,"activities":256,"authors":257,"images":259,"websites":260,"area":22,"programme":22,"language":22,"translations":261,"translation_of":22,"user_created":39,"date_created":262,"user_updated":40,"date_updated":263,"content":264,"link":265},9812,"High-profile law enforcement operations against illegal wildlife trade (IWT), such as Interpol’s [Operation Thunderball](https:\u002F\u002Fwww.interpol.int\u002Fen\u002FNews-and-Events\u002FNews\u002F2019\u002FWildlife-trafficking-organized-crime-hit-hard-by-joint-INTERPOL-WCO-global-enforcement-operation) in July 2019 and the arrest of notorious trafficker [Moazu Kromah](https:\u002F\u002Fwww.cbsnews.com\u002Fnews\u002Fwildlife-heroin-trafficking-ring-africa-bust-southern-district-new-york-fish-and-wildlife\u002F) in Uganda in June, have drawn welcome attention to IWT as a financial and organised crime and not only a conservation issue. Yet in working to strengthen legal frameworks and law enforcement capacity in countries that suffer from high levels of IWT, we must not forget the social drivers and facilitators behind wildlife trafficking – factors that laws alone are powerless to change. This quick guide draws on a recent Basel Institute Working Paper on [Corruption and wildlife trafficking](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fnew-working-paper-corruption-and-illegal-wildlife-trade-east-africa), published in the context of a multi-disciplinary programme of work focused on financial crime in IWT.\n\n### Wildlife trafficking is a lucrative crime…\n\nIWT is sometimes described as a low-risk, high-reward business. In many source and transit countries in Southern and Eastern Africa, for example, rates of detection and arrests are low, prosecutions are rare and penalties are weak even for those caught red-handed. These low risks are offset against the high prices that traffickers can obtain by selling valuable illegal wildlife products such as ivory, rhino horn and pangolin scales to black markets mainly in Asia.\n\n### …yet it’s not just about money and the law\n\nA growing body of research supports the idea that behaviour is driven by a complex array of social, cultural and other behavioural factors. Illicit behaviour is thus not only the result of a cost-benefit analysis by individuals seeking personal economic gain. Nor, therefore, will it be solved by laws and law enforcement alone. International agreements such as [CITES](https:\u002F\u002Fcites.org\u002F), which regulates the global trade in wildlife, along with national efforts to strengthen the enforcement of formal regulations, are necessary but not sufficient. This is because they do not address the underlying social context that motivates individuals to engage in trafficking in the first place. With a better understanding of these factors, we will be better equipped to design effective interventions that influence the attitudes and behaviours of people directly involved in the early stages of IWT, as well as those who are indifferent or directly support them.\n\n### What drives people to engage in wildlife trafficking?\n\nBeyond purely economic factors, our preliminary research indicates three main beliefs that drive and justify individuals’ decisions to engage in wildlife crime. Firstly, that trafficking engenders wealth and status. The financial rewards of IWT allow poachers and traders to acquire more wealth than they can access through relying on the formal economy. The money trickles down through social and family networks to benefit the rest of the community. This raises their prestige and status in the community and simultaneously helps to legitimise the illegal behaviour. Secondly, there is often a belief that wildlife trafficking is a victimless crime. In many countries where humans and wild animals live in close proximity, animals are viewed as either sources of food or nuisances that destroy crops and threaten personal security. Widespread human-wildlife conflict can drive people to consider wildlife products as any other kind of commodity. This legitimises behaviours such as actively engaging in trafficking (on the side of the citizens) or facilitating trafficking by turning a blind eye (on the side of public officials). Thirdly, members of a community may consider they have a moral right to appropriate wildlife. Communities that have lost land to newly created (or colonial-era) safari parks and protected environmental zones may resist legislation protecting wildlife on the grounds that it criminalises a generations-old right to access and use wildlife.\n\n### How do socio-economic and political factors play a role?\n\nCommunities along the major wildlife trafficking routes in Africa generally suffer from poverty and limited employment opportunities. The constrained socio-economic context can drive otherwise law-abiding individuals, be it members of the community or local public officials, to assist in activities such as moving contraband from point A to point B. Poverty therefore sets the stage for both poaching and the trafficking of commodities across cities and countries. A thriving supply of illegal wildlife products is the result. Ironically, in demand countries on the other side of the globe, it is the increasing wealth of the middle and upper classes that is helping fuel the demand for these in the first place. The political context is also key to explaining how wildlife trafficking can take place with impunity. Poor governance, endemic corruption and constrained public institutions in source and transit countries are important facilitators of IWT. Even more worryingly, there are countless examples of militants and terrorist groups engaging in poaching and wildlife trafficking to fund their operations, from the Lord’s Resistance Army to the Janjaweed Arab militia of Sudan.\n\n### Drivers and facilitators are intertwined – and we need to understand both\n\nThe socio-economic and political context in which IWT takes place increases and facilitates the propensity for individuals to engage in trafficking. Social norms and beliefs help explain the underlying motivations and justifications individuals may adopt to actually engage in trafficking. We need to understand both a lot better if we want laws and law enforcement to stand a chance of effectively taking down the trafficking networks threatening our endangered animals and global biodiversity.\n\n### Learn more\n\n*   Learn more about the Basel Institute’s [social norms research](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublic-governance\u002Fresearch-projects\u002Fsocial-norms).\n*   Read about how insights into social norms can be applied to prevent [bribery in the Tanzanian health sector](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fclaudia-baez-camargos-quick-guide-social-norms-and-corruption).\n*   Download the full Working Paper 30: [Corruption and wildlife trafficking: exploring drivers, facilitators and networks behind illegal wildlife trade in East Africa](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fnew-working-paper-corruption-and-illegal-wildlife-trade-east-africa).\n*   Read about the Basel Institute’s programme of work focused on [intelligence-led action against financial crime in IWT](https:\u002F\u002Fwww.baselgovernance.org\u002Fillegal-wildlife-trade).\n*   [Download a PDF of this quick guide.](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-08\u002Fqg11_drivers_iwt.pdf)","2019-09-06","saba-kassas-quick-guide-to-drivers-and-facilitators-of-wildlife-trafficking-997","Saba Kassa’s quick guide to drivers and facilitators of wildlife trafficking","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F712e0be9-042c-4216-8b3b-d5ea91cb6c48?width=1000&height=650&format=webp&quality=80",[241],6527,[243,217],"Green Corruption",[139,17],[246,250],{"tags_id":247},{"id":248,"name":249},1303,"Environment",{"tags_id":251},{"id":252,"name":253},848,"Behavioural science",997,[243,20],[139,17],[258],881,[],[202],[],"2022-05-26T22:56:01.000Z","2026-05-29T22:21:57.000Z",[],"\u002Fresources\u002Fnews\u002Fsaba-kassas-quick-guide-to-drivers-and-facilitators-of-wildlife-trafficking-997",{"id":267,"body":268,"status":6,"type":10,"date":269,"slug":270,"title":271,"image":272,"countries":273,"topic":275,"activity":276,"tags":277,"nid":280,"topics":281,"activities":282,"authors":283,"images":285,"websites":286,"area":22,"programme":22,"language":22,"translations":287,"translation_of":22,"user_created":39,"date_created":288,"user_updated":40,"date_updated":263,"content":289,"link":290},9813,"_This quick guide draws on a [more comprehensive blog](https:\u002F\u002Fwww.globalintegrity.org\u002F2019\u002F09\u002F04\u002Fsocialnorms\u002F) by Claudia Baez Camargo published on the website of the Global Integrity Anti-Corruption Evidence (GI-ACE) research programme._ _Find more details on the GI-ACE anti-corruption research projects led by Dr Baez Camargo’s team at the Basel Institute on Governance, as well as other pioneering research on social norms and implications for anti-corruption practice, at the end of this guide._\n\n### What is a social norm?\n\nLike many abstract concepts it is slippery, but a good definition is that of Church and Chigas (2019): social norms are “mutual expectations held by members of a group about the right way to behave in a particular situation”. For an everyday example, think of your workplace. You and your colleagues expect each other to behave in a certain way in shared office spaces, at meetings, during joint projects, etc. These unspoken expectations are social norms, and you may not even realise that they exist – until somebody breaks them.\n\n### How do social norms drive and perpetuate corrupt behaviour?\n\nIf most people believe acts of corruption are accepted and expected by those around them, it is not difficult to see why corruption persists. Say you grew up and live in a community where public officials routinely demand bribes and your family and friends routinely pay them without questioning whether it is right or wrong to do so.  You would probably find it hard to even recognise that this behaviour might be corrupt and unfair, never mind stand up against it.\n\n### The case of health facilities in East Africa\n\nIn a [recent research project](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fcorruption-social-norms-and-behaviours-comparative-assessment-rwanda-tanzania-and) in East Africa, we found that users of public health facilities often offer unsolicited bribes and gifts in order to create a relationship with the provider. The expectation is that having a “provider friend” helps facilitate access to treatment. This is perhaps no surprise when you think about the queues, waiting times and shortage of essential medicines and medical supplies at many of these public health facilities. Now comes the first interesting question: is a social norm underpinning this behaviour?\n\n### How to identify social norms that drive corrupt behaviour\n\nFirst, let’s distinguish between four related concepts:*   Personal attitudes: What an individual believes is appropriate behaviour in a particular situation, e.g. a health worker believes that it is wrong to accept a gift from a patient.\n*   Descriptive social norms: Beliefs about what others do, e.g. the health worker believes that her colleagues routinely accept gifts from patients.\n*   Injunctive social norms: Beliefs about what behaviours others approve or disapprove of, e.g. the health worker believes that most of her colleagues think it is fine to accept gifts from patients.\n*   Behaviours: What people actually do when confronted with that situation, e.g. the health worker accepts or rejects a gift from a patient.\nYou can see that social norms (2 and 3) are different from both personal attitudes (1) and from actual behaviours (4). Which makes them difficult to measure. The trick is to look for an informal _enforcement_ component – i.e. when people who behave in a particular way are rewarded (e.g. reputation, friendships, smiles) and those who break the norm are punished (e.g. social isolation, gossiping, frowns). Back to our research project in East Africa: during field research in Tanzania, we found that bribery and gift-giving is widespread, expected and accepted in public health facilities by both patients and providers. Those who refuse to give or accept bribes and gifts suffer social costs such as gossiping and bad-mouthing. The exchange of gifts and bribes at public health facilities in Tanzania is therefore a social norm.\n\n### What are the implications for anti-corruption practice?\n\nIf social norms are driving corrupt behaviour, then anti-corruption measures that only target individual incentives and behaviours are unlikely to work. They ignore the overpowering social pressures generated by these collective beliefs. And they ignore the fact that social norms are often unconscious and not a result of deliberate cost-benefit calculations. The implications for anti-corruption practice are therefore huge.\n\n### The million-dollar question\n\n…is of course, how to design anti-corruption interventions to identify social norms that fuel and perpetuate corruption, measure them and tackle them. This is exactly what we are doing in the GI-ACE-funded project, [Addressing Bribery in the Tanzanian Health Sector: A Behavioural Approach](https:\u002F\u002Fwww.globalintegrity.org\u002Fproject\u002Fgi-ace-basel\u002F), together with co-investigators Dr. Richard Sambaiga (University of Dar es Salaam), Prof. Tobias Stark (University of Utrecht) and Ms Ruth Persian (UK Behavioural Insights Team). We hope that the results of our pilot intervention in Tanzania will be valuable in informing anti-corruption interventions in public health sectors worldwide. As well as – why not! – all cases of corrupt behaviour where social norms have a major role to play.\n\n### Find out more\n\n*   View Claudia Baez Camargo’s blog on the GI-ACE website: [_Working with social norms to develop effective anti-corruption interventions_](https:\u002F\u002Fwww.globalintegrity.org\u002F2019\u002F09\u002F04\u002Fsocialnorms\u002F)\n*   Learn about the Basel Institute’s recent [research projects and findings](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublic-governance\u002Fresearch-projects).\n*   See current projects and publications on [social norms and corruption](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublic-governance\u002Fresearch-projects\u002Fsocial-norms).\n*   Read about a separate GI-ACE research project led by the Basel Institute on [Harnessing Informality: Designing Anti-Corruption Network Interventions and Strategic Use of Legal Instruments](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fharnessing-informality-promote-integrity-and-design-better-anti-corruption-programmes-new).\n*   [Download a PDF of this quick guide.](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-08\u002Fqg10_social_norms.pdf)","2019-09-04","claudia-baez-camargos-quick-guide-to-social-norms-and-corruption-996","Claudia Baez Camargo’s quick guide to social norms and corruption","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Ff63ef44a-3aa7-4488-8ce4-ca57a40bbfd5?width=1000&height=650&format=webp&quality=80",[274],6528,[217],[139,17,219],[278],{"tags_id":279},{"id":252,"name":253},996,[20],[139,17,219],[284],882,[],[202],[],"2022-05-26T22:56:02.000Z",[],"\u002Fresources\u002Fnews\u002Fclaudia-baez-camargos-quick-guide-to-social-norms-and-corruption-996",{"id":292,"body":293,"status":6,"type":10,"date":294,"slug":295,"title":296,"image":297,"countries":298,"topic":299,"activity":301,"tags":302,"nid":303,"topics":304,"activities":305,"authors":306,"images":308,"websites":309,"area":22,"programme":22,"language":22,"translations":310,"translation_of":22,"user_created":39,"date_created":311,"user_updated":40,"date_updated":312,"content":313,"link":314},9858,"Social network analysis (SNA) can help us to better understand and tackle the transnational organised crime and dark networks that sustain corruption, money laundering and illicit trafficking.  In my work for the Basel Institute’s Public Governance team, I am currently focused on using SNA to support research into the organised crime networks behind the multibillion-dollar global trade in illegal wildlife products. But the methodology and techniques are just as powerful when applied to any major trafficking network – people, drugs and weapons – as well as gambling, match-fixing and other organised crimes.  SNA is also useful to understand other types of social networks that are linked to many different patterns of corruption. For example, networks of political and business elites often collude to get away with grand corruption schemes in procurement for public infrastructure projects. Social networks sustain and perpetuate practices of bribery and favouritism in the provision of public services.\n\n### What is it in a nutshell? \n\nSocial network analysis is a set of theories, methods, techniques and software to study social relational structures. In other words, networks created by social interactions between individuals and groups.  SNA allows us to capture the structural and functional characteristics of each network. This includes the role of each actor, the dynamics, mechanisms and rules behind the network’s establishment and evolution, and how all the different elements – nodes – are linked together.\n\n### What can SNA tell us? \n\nSNA can help us answer questions like this:\n\n*   How dense, or closely connected is the network?\n*   Is it highly centralised or is there a lot of activity at the periphery?\n*   What kind of clusters and sub-groups exist?\n*   Which are the most powerful nodes, or “hubs”? \n*   Which nodes are acting as “brokers”, mediating between other elements?\n*   Which nodes are supplying information, advice or professional services to the illicit networks, staying mostly invisible on the periphery?\n*   How is the network evolving over time?\n*   And ultimately – which nodes must we target to disrupt the network and break it down permanently?\n\nIt's also valuable to look at how criminal networks interact with each other.\n\n### What goes into the analysis?\n\nSocial network analysts and researchers use publicly available information such as judicial documents, institutional reports and newspaper articles, along with interviews, questionnaires and focus groups. The more information we have, the more clearly we can highlight the main structural characteristics of the criminal and dark networks. Applying different models also deepens the analytical potential. An exponential random graph model, for example, identifies sociometric determinants – age, place of birth, nationality, profession, ethnic group, religion, etc. – that affect the probability of a link existing between two nodes. This is because, as the English saying goes, _birds of a feather flock together_ – people with similar social characteristics are more likely to develop a connection. This and other specific models can illuminate how a criminal network functions while at the same time supplying useful insights into the nature and origin of the criminal links.\n\n### How can SNA help law enforcement authorities and policymakers?\n\nTraffickers necessarily operate across borders, exploiting transnational criminal organisations, global dark markets and the growing possibilities offered by technology. Understanding how these networks of traffickers and criminals work, and how the networks interact with other networks, is essential to planning how to target the key players and act efficiently to dismember the networks. More importantly, SNA is essential to planning how to prevent criminal networks and trafficking rings from – like snakes or worms – re-growing and regaining their strength even after they are dismembered.\n\n### Learn more\n\n*   Find out more about the Basel Institute's [research into social networks](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublic-governance\u002Fresearch-projects\u002Fsocial-networks) and current projects in this area.\n*   [Download a PDF of this quick guide.](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-08\u002Fqg4_sna.pdf)","2019-05-16","jacopo-costas-quick-guide-to-social-network-analysis-in-combating-organised-crime-and-trafficking-919","Jacopo Costa’s quick guide to social network analysis in combating organised crime and trafficking","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F9debb168-dfb7-4d06-9296-a54d9b7c3ce3?width=1000&height=650&format=webp&quality=80",[],[134,300,243,217],"Asset Recovery",[139],[],919,[134,135,243,20],[139],[307],902,[],[202],[],"2022-05-26T22:56:42.000Z","2026-05-29T22:22:00.000Z",[],"\u002Fresources\u002Fnews\u002Fjacopo-costas-quick-guide-to-social-network-analysis-in-combating-organised-crime-and-trafficking-919",{"id":316,"body":317,"status":6,"type":10,"date":318,"slug":319,"title":320,"image":321,"countries":322,"topic":323,"activity":324,"tags":326,"nid":327,"topics":328,"activities":329,"authors":330,"images":332,"websites":333,"area":22,"programme":22,"language":22,"translations":334,"translation_of":22,"user_created":39,"date_created":335,"user_updated":40,"date_updated":336,"content":337,"link":338},9838,"Someone once said that the more knowledge is freely shared, the more it grows. Our [free eLearning courses](https:\u002F\u002Flearn.baselgovernance.org\u002F) on asset tracing, intelligence gathering and financial analysis exemplify this idea. Here are some of the benefits of online courses for financial investigators, analysts and others who need to acquire and practise these complex skills.\n\n### The flexibility of eLearning\n\nAny manager will tell you how difficult it is to arrange an onsite training course that everyone in the team can attend. People are on holiday, unexpectedly sick or called away for an urgent meeting, working from home, travelling for business… eLearning solves all of these issues. Online courses can be taken at any time and from any place with a computer and an internet connection. Moreover, some staff need to keep working while their colleagues are being trained. For both employers and employees, it is therefore far easier to reserve shorter timeslots split up over a longer period of time. Our eLearning courses are split into sessions that take 15–30 minutes each to complete. Alongside the benefits for scheduling and time management, [studies](https:\u002F\u002Fwww.forbes.com\u002Fsites\u002Fnickmorrison\u002F2016\u002F05\u002F30\u002Fthe-secret-of-effective-learning-may-be-less-study-not-more\u002F#54e9527818c7) indicate the effectiveness of shorter periods of learning over a longer time. Particularly in the age of digital distractions and short attention spans.\n\n### Cost is no longer a barrier to learning\n\nOnsite courses have high fixed costs, especially if they are high-quality, tailored courses with experienced trainers. Rooms, refreshments and travel have to be booked and paid for. And the more courses you have, the more it costs. With eLearning, it’s the opposite. Once a course has been developed, 10, 100, 1,000 or 1 million people can take it without adding to the cost. This is an essential point for public institutions with limited funds for training and relatively high rates of staff turnover. It is even more crucial in developing and transition countries, where lack of funds is a barrier to building long-term capacity.\n\n### Open access to knowledge and skills\n\nIn the case of our eLearning courses, individuals don’t need to be part of an organisation to take the course and benefit from it. They are freely open to all. In fact, we originally designed the courses – some in collaboration with the [Egmont Group](https:\u002F\u002Fwww.egmontgroup.org\u002F) of Financial Intelligence Units (FIUs) – with the public sector in mind. Yet we seeing more and more use by individuals and the private sector, including lawyers, bank staff, tax advisors and AML consultants around the world. eLearning courses can fairly easily be translated into different languages, overcoming the language barrier more easily than onsite courses. Our core [Operational Analysis](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=3) course, for example, is available in English, Spanish, French, Russian and Latvian, with more languages on the way.\n\n### Self-paced learning for different levels\n\nThink back to a recent training course you attended, or even to your school days. How often were you bored and frustrated by the slow place of the class? Or overwhelmed because the topic was over your head? Everyone has different levels of experience and learns at different speeds. eLearning courses allow participants to take control over their learning experience. They can take breaks at any time, skip quickly over parts they are already familiar with, and repeat parts that are new or challenging. eLearning also gets over the fact that some people are shy in larger groups and tempted to hide behind others during an onsite training.\n\n### Streamlining internal coaching and mentoring\n\nIn many organisations, new staff learn through one-to-one coaching by colleagues or a senior staff member. This takes time – which many senior staff don’t have – as financial investigations are complex procedures that require _doing_, not just reading and nodding. It also risks leaving important gaps in knowledge. eLearning can streamline this internal mentoring and coaching process. If staff members all take the same eLearning course, they gain the same baseline knowledge and skills. Coaching and mentoring can then focus on the organisation- or country-specific aspects.\n\n### How to develop an (effective) eLearning course\n\nI can tell you how to develop an _ineffective_ eLearning course: just upload a PDF or video to the internet and add some multiple-choice questions. Our eLearning courses are not like that. We work with subject matter experts from our [International Centre for Asset Recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery) (ICAR) and Egmont Group of FIUs to make the course content as relevant as possible to the work of the participants. And while the eLearning courses are based on our successful [onsite training programmes](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes), they are transformed by eLearning specialists to make them engaging and easy to use. The focus is on practising skills by doing interactive exercises that closely resemble the task in real life. For example, in our Operational Analysis course, participants conduct a real analysis of a fictional case. They have to plan a strategy to collect the information, collect the information from various sources, then evaluate and collate it. They then have to do the analysis, write a report and disseminate it. It mirrors exactly what financial investigators and analysts need to do in real life. Benjamin Franklin once said: _“Tell me and I forget. Teach me and I remember. Involve me and I learn”._ No doubt he would have approved of the concept behind the eLearning courses.\n\n### What is “blended learning” and how does it work in practice?\n\nThe benefits of eLearning are clear, but it is true that eLearning cannot take the place of a high-quality onsite training course with experienced and knowledgeable trainers. (Our Head of Training ICAR, Phyllis Atkinson, explains what makes an [effective onsite training course](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fphyllis-atkinsons-quick-guide-effective-training-financial-investigations) in her own quick guide.) We have seen positive results from our [Advanced Onsite Operational Analysis](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes\u002Fadvanced-site-training-operational-analysis) course, which “blends” modules from the eLearning course with a customised onsite component.\n\n### LEARN more\n\nThe Basel Institute’s [LEARN platform](https:\u002F\u002Flearn.baselgovernance.org\u002F) offers a suite of self-paced eLearning courses and other practical guidelines on asset tracing, intelligence gathering and financial analysis. All of our self-paced courses and guidelines are freely accessible – simply register and start learning. Courses include:\n\n*   [Operational analysis](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=3) and the intelligence cycle. This course was co-developed with the Egmont Group.\n*   [Financial analysis using Excel](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=9)\n*   How to [visualise cases and flows of money](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=16) using the free software yEd\n*   The [Source and Application technique](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=17) for gathering financial information to calculate the potentially illegal income of a suspect\n*   A course on Terrorist Financing co-developed with the Egmont Group later in 2020.\n\nPractical guidelines include:\n\n*   [Guidelines for the efficient recovery of stolen assets](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=20#section-1), co-developed with the Stolen Asset Recovery Initiative of the World Bank\u002FUNODC in the context of the Lausanne Seminars\n*   [Guide to the role of civil society organisations in asset recovery](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=14), co-developed with partners in the context of the Arab Forum on Asset Recovery (AFAR)\n\nThe LEARN platform is also used for online delivery of some our instructor-led training programmes, including those offered by our [ICAR training team](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes). [Download a PDF of this quick guide.](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-8-elearning-asset-tracing-and-financial-analysis)","2019-07-15","peter-huppertzs-quick-guide-to-elearning-for-asset-tracing-and-financial-analysis-950","Peter Huppertz’s quick guide to eLearning for asset tracing and financial analysis","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F2dda1b14-1776-4553-a406-c337cc5aac53?width=1000&height=650&format=webp&quality=80",[],[134,300],[102,325],"eLearning",[],950,[134,135],[102,325],[331],897,[],[202],[],"2022-05-26T22:56:24.000Z","2026-05-29T22:21:58.000Z",[],"\u002Fresources\u002Fnews\u002Fpeter-huppertzs-quick-guide-to-elearning-for-asset-tracing-and-financial-analysis-950",{"id":340,"body":341,"status":6,"type":10,"date":342,"slug":343,"title":344,"image":345,"countries":346,"topic":348,"activity":349,"tags":350,"nid":351,"topics":352,"activities":353,"authors":354,"images":356,"websites":357,"area":22,"programme":22,"language":22,"translations":358,"translation_of":22,"user_created":39,"date_created":359,"user_updated":40,"date_updated":360,"content":361,"link":362},9734,"Before joining the Basel Institute’s International Centre for Asset Recovery, [Tom Walugembe](https:\u002F\u002Fwww.baselgovernance.org\u002Fabout\u002Fpeople\u002Ftom-walugembe-0) was a Senior State Attorney at Uganda’s Office of the Director of Public Prosecutions. In this role, he secured the first ever money laundering conviction in Uganda in the case of _Uganda v Serwamba David Musoke and 6 Others_.\n\nThis landmark case blazes a trail not just for Uganda but for other countries to prosecute cases of money laundering and recover illicit assets.\n\nAs part of ICAR's efforts to encourage innovation and peer learning in the anti-corruption and asset recovery communities, we would like to share Tom's reflections on the case. His article raises considerations about what other anti-corruption practitioners and policymakers, especially in Africa, can take forward from it.\n\nThe short history of money laundering prosecutions in Uganda\n------------------------------------------------------------\n\nMoney laundering is the process of making large amounts of money generated through criminal activity appear to come from a legitimate source. In most countries, the conversion or transfer of proceeds of crime to disguise or conceal its illicit origin is criminalised as the offence of money laundering.\n\nIn 2013, Uganda passed the Anti-Money Laundering Act (AML Act). Prior to this, the offence of money laundering was not criminalised under Ugandan law. Uganda’s Financial Intelligence Authority (FIA) was only established in July 2014. There was very little knowledge about money laundering among police detectives, prosecutors and even judicial officers.\n\nAt the Office of the Director of Public Prosecutions, we quickly realised that the new AML Act could give us impetus in fighting organised crimes like corruption, terrorism, drug trafficking and human trafficking. However, for the first year no prosecutor dared to try it.\n\nIt was not until May 2015 that we decided to test the provisions of the Act in the case of _Uganda Versus Serwamba David Musoke and 6 Others_.\n\nAbout the case\n--------------\n\nThe complainant (Equity Bank Uganda Ltd) is a commercial bank in Uganda with subsidiaries throughout the East African region. The prime suspect, Serwamba David Musoke, was the operations manager of Equity Bank Oasis Mall Branch in Kampala.\n\nOn 28 and 29 March 2015, Serwamba colluded with various other conspirators to embezzle USD 1,450,000 from the accounts of two Southern Sudanese nationals. The money was withdrawn in three instalments using fake withdrawal slips by fraudsters who impersonated the real account holders and presented fake passports. Serwamba, the architect of the fraud, did not conduct biometric verification on the imposters before approving the withdrawal of the money, which the conspirators divided amongst themselves.\n\nOn 29 March 2015, some of the conspirators posted a video on WhatsApp with them posing with bundles of US dollars in their apartment. This video would later go viral and lead to the arrest of some of the conspirators. The fraud came to the Bank’s attention on 1 April 2015 when one of the real account holders in South Sudan went to transact at the Juba branch, and uncovered strange transactions on his bank account. The matter was immediately reported to the police in Kampala.\n\nA financial investigation was conducted to follow the money and recover the illicit assets. The financial investigation revealed the purchase of various assets:\n\n*   On 31 March 2015, one of the conspirators bought a Mercedes Benz 4matic 500 for USD 25,000 in cash, leaving it registered in the names of the seller.\n*   On 31 March 2015, the same conspirator purchased a plot of land in Buziga (a suburb of Kampala) for about UGX 100,000,000 (about USD 30,000) in cash. The sale agreement indicated the names of his mother as the purchaser.\n*   In mid-April 2015, the main conspirator, Serwamba, purchased a plot of land in Wakiso for UGX 110,000,000 (about USD 32,000) in cash. The sale agreement indicated the name of his girlfriend’s mother as the purchaser.\n*   In April 2015, Serwamba purchased a Mercedes Benz 4matic valued at UGX 80,000,000 (about USD 23,000), leaving it registered in the names of the seller.\n*   In the same month, Serwamba used UGX 8,000,000 (about USD 2,300) to clear taxes on a Toyota Corona. His girlfriend had imported the car for about UGX 16,000,000 (about USD 4,600) before the crime was committed.  \n*   In April 2015, Serwamba kept cash UGX 255,000,000 (about USD 73,000) in a closet at his brother’s home. The money was recovered during a police search. \n*   Investigations revealed that two of the conspirators went on holiday to Dubai in mid-April 2015, where they spent luxuriously.\n\nMost of the stolen money was not recovered.\n\nIn May 2017, seven of the conspirators were convicted for the offences of embezzlement, causing financial loss, forgery, conspiracy to defraud and money laundering. They were sentenced to varying prison terms between five to 12 years. The recovered properties were confiscated and forfeited to the complaint bank.\n\nThe accused were also ordered to compensate the complainant bank severally and jointly in an amount of USD 1,250,000,000. They appealed to the Court of Appeal, which appeal is yet to be fixed for hearing.\n\nLessons learned\n---------------\n\n### A prosecution-led strategy ensured meticulous investigation and correct procedures\n\nAs soon as the case was reported, the police quickly realised that it was essential to seek the advice of prosecutors from the onset. The Serwamba case, therefore, became a prosecution-led investigation case.\n\nThroughout the investigation, regular case management meetings were held between the police investigation team and prosecutors. At the meetings, evidence gathered would be reviewed, new investigation leads identified, and further investigation actions agreed upon. On occasion, police detectives would consult prosecutors by mobile phone calls for urgent advice.\n\nThe decision to adopt a prosecution-led investigation strategy ensured that the case was meticulously investigated; gathering all the relevant evidence while quickly discarding irrelevant information. It also ensured that police detectives did not ignore crucial legal procedures like securing search warrants and restraining orders against recovered properties.\n\n### A parallel investigation strategy enabled more targeted investigations into predicate offences and stolen assets\n\nAnother critical decision was to adopt a parallel investigation strategy. The investigation team was divided into two teams:\n\n*   One team was tasked to focus on investigating the predicate offences like embezzlement, causing financial loss and forgery.  \n*   The second team was tasked to simultaneously conduct a financial investigation with a view to following the money to identify the proceeds of crime for seizure and restraint.\n\nThis strategy was crucial to the recovery of a decent amount of illicit assets, and ultimately securing the money laundering conviction.\n\n### Having a large prosecution team helped to overcome challenges of long timescales and vast documentation\n\nBecause of their intricate nature, money laundering cases are bound to involve a vast quantity of documents and require a long time to prosecute. The Serwamba case took us at least two years to prosecute. It involved seven accused persons and about 10 defence lawyers. \n\nBecause the court had many other cases to try, it was inevitable that there were several adjournments. Even small details like determining hearing dates were problematic. During the hearing, the prosecution had to deal with an array of objections from the defence team.\n\nIn order to ensure that the prosecution did not become overwhelmed, we realised we needed to have a sizeable prosecution team. Accordingly, three prosecutors were assigned to handle this case. This also helped ensure continuity in case one of the prosecutors became unavailable.\n\n### The evidence of accomplices acting as prosecution witnesses was crucial\n\nCriminals will go to great lengths to prevent law enforcement authorities from recovering their illicit wealth. Inevitably, money laundering schemes involve a large number of conspirators. It is essential, therefore, for the prosecution to win over some of the conspirators to its side to achieve success.\n\nIn the Serwamba case, the prosecution made an informal agreement not to prosecute two of the participants on condition that they would testify as prosecution witnesses. The two accomplices had appeared in the WhatsApp video while posing with bundles of US dollar bills. They had also helped one of the prime suspects in identifying assets like vehicles and land for purchase.\n\nShortly before the trial, the prosecution also agreed to drop the charges against three other suspects on condition that they would testify against their co-conspirators. The use of accomplices was fundamental to the successful outcome of the case.\n\nThe use of accomplice evidence inevitably meets stiff resistance from defence lawyers. In the Serwamba case, the defence team ferociously attacked the credibility of the accomplice witnesses and contended that they were giving false testimony to avoid being prosecuted. However, it is up to the presiding judge to determine the reliability and relevance of the evidence of an accomplice.\n\n### Informal cooperation was valuable where formal mutual legal assistance (MLA) was not possible\n\nThe Serwamba case had a transnational dimension, considering that the money was withdrawn from accounts belonging to Southern Sudanese citizens, and domiciled in the Equity Bank Juba branch. It was necessary to interview the two account holders and some of the key staff at the Juba branch.\n\nThrough police-to-police cooperation, the assistance of the Southern Sudan Police was sought to record statements of the account holders. Although the two account holders confirmed that money had been fraudulently withdrawn from their accounts, they declined to record statements. Nevertheless, the Southern Sudan Police recorded statements from two bank employees at the Juba branch.\n\nDuring the trial, the testimony of these bank staffers could not be secured through formal MLA as neither Southern Sudan nor Uganda had any regulations or the technological capacity to allow video link testimonies at the time. (Uganda has since passed regulations to allow video link witness testimonies, and acquired the necessary technology in some of its courts.)\n\nFortunately, Equity Bank, using its resources, met the cost of flying the two bank employees to Kampala to testify during the trial. There is no doubt that in future cases, both informal and formal MLA will be critical.\n\nHow we overcame the challenges of asset management\n--------------------------------------------------\n\nIn most developing countries, asset management of proceeds of crime will be a significant challenge to the criminal justice system. In the Serwamba case, three major types of assets were recovered, namely cash, vehicles and land. Here is what we did and what we learned.\n\n### Cash\n\nUGX 255,000,000 (about USD 73,000) was recovered in a closet in the house of a brother of the main suspect, Serwamba. As soon as this recovery was made, the lead investigating officer contacted the prosecution on how to keep this exhibit. The fear was that it was too tempting to keep such a large amount of cash within the police station as poorly paid police officers could easily steal it.\n\nIt was decided that the money would be kept in a specially provided vault at the Bank of Uganda. In this case, the money was not only a recovered asset but also an exhibit. The money was photographed and kept in the same bag in which it had been recovered. The chain of custody was proved by producing all the correspondence concerning the storage of the money in the Central Bank. \n\nBased on this experience, we believe that if countries do not yet have guidelines concerning the safe custody of large amounts of cash recovered in money laundering cases, they should consider drafting them.\n\n### Vehicles\n\nFour motor vehicles were recovered in the Serwamba case. The storage of these vehicles was a challenge, as the police do not have a warehouse for that purpose. Consequently, the cars were driven to the Anti-Corruption Court parking yard where they spent about one and a half years.\n\nThe prosecution at some point contemplated selling the vehicles and keeping the proceeds on an escrow account pending the finding of the court. However, the cars were at the same time exhibits which needed to be produced before the court. There was also the risk of being sued by the accused persons if they were acquitted. Ultimately, the vehicles were forfeited to the complainant Bank, but their value had depreciated substantially.\n\nThis demonstrates that countries should consider establishing asset management facilities like warehouses where recovered properties such as vehicles can be safely stored. It is also advisable to adopt asset management guidelines, which may, among others, provide for the sale of such items before the conclusion of the trial to avoid their depreciation.\n\n### Land\n\nThe two pieces of land that were recovered in the Serwamba case were easier to manage since they were undeveloped. The prosecution secured restraint orders against the said plots and proceeded to place caveats on their titles. The plots were eventually confiscated and forfeited to the complainant Bank.\n\nHowever, managing other real estate properties like farms, commercial buildings, homes etc. is more challenging. Again, it is advisable for African countries to adopt guidelines to streamline their management.\n\n### Commingled assets\n\nOne of the vehicles in the Serwamba case had been imported at approximately UGX 16,000,000 (about USD 4,600) before the crime was committed. Serwamba then used UGX 8,000,000 (about USD 2,300) of the proceeds of crime to clear taxes for the vehicle, thus raising the complex issue of commingled assets.\n\nThe prosecution took the approach that the entire vehicle amounted to proceeds of crime while the defence argued that only the UGX 8,000,000 used to clear taxes on the vehicle was recoverable. The court, in this case, treated the entire car as proceeds of crime and ordered its confiscation.\n\nHow to handle commingled assets will depend on the facts of each case and the laws of each country in this regard.\n\nWider considerations for money laundering cases in Africa\n---------------------------------------------------------\n\n### Witness protection\n\nIn the Sewamba case, the prosecution had to rely on about five accomplices as prosecution witnesses. However, Uganda does not have a witness protection law or programme. The arrangement with these accomplices was therefore based on a “gentleman’s agreement”. The security of such witnesses is potentially at risk before and after the trial.\n\nThe use of accomplices as prosecution witnesses inevitably continues to be a common feature in money laundering prosecutions in Africa. However, only a few countries on the continent have witness protection laws and fully-fledged witness protection programmes.\n\nIf witness protection measures do not yet exist in a country, policy makers in that country should consider establishing them. Witness prosecution is an essential requirement for the successful prosecution of money laundering cases. \n\n### Digital forensics\n\nThe majority of money laundering cases inevitably make use of digital devices like mobile phones and laptops. The Serwamba case, for instance, involved a WhatsApp video with some of the conspirators posing with the recently stolen bundles of US dollars. It also involved a forged email purportedly sent by the Juba branch manager to Serwamba indicating that the two account holders were to make transactions in Kampala.\n\nThese aspects of the evidence were not subjected to digital forensics analysis. The digital forensics capacity of most African countries is still very low. It is important that African countries enhance their digital forensics capacity, as this will be an essential aspect in the successful prosecution of money laundering cases.\n\n### Regulation of cash purchases\n\nIn many African countries, it is still possible to purchase expensive commercial buildings or vehicles using cash. In the Serwamba case, the suspects paid for the plots of land and vehicles in cash. The use of cash to purchase such assets makes the investigation more complicated since it is difficult to follow the money trail.\n\nPolicy makers should consider establishing laws that require the purchase of assets like real estate and vehicles to be made through bank payments. Accordingly, the due diligence conducted by financial institutions before accepting such cash to be banked would be the first layer of protection.\n\nCriminals would therefore find it more difficult to launder their ill-gotten money, and following up the proceeds of crime would be easier.\n\n### Financial investigations training\n\nMoney laundering is still a relatively new concept to many stakeholders in the criminal justice system in Africa, an observation borne out during numerous ICAR training workshops. Moreover, effective financial investigations require the involvement of detectives with a broad skillset and the necessary training in financial investigations.\n\nTraining police detectives, prosecutors and judicial officers in asset recovery and financial investigations should be a recurrent activity.\n\nFind out more\n-------------\n\n*   View the full court judgement in the case of _[Uganda v Serwamba David Musoke and 6 Others](https:\u002F\u002Fulii.org\u002Fug\u002Fjudgment\u002Fhc-criminal-division\u002F2017\u002F100)_.\n*   View the [Ugandan Anti-Money Laundering Act 2013](https:\u002F\u002Fulii.org\u002Fsystem\u002Ffiles\u002Flegislation\u002Fact\u002F2013\u002F2013\u002FThe-Anti-money-Laundering-Act-2013.pdf).\n*   Find out more about the work of the [International Centre for Asset Recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery) and the [ICAR training team](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes), of which Tom Walugembe is now a member.","2020-05-27","breaking-new-ground-prosecuting-the-first-money-laundering-case-in-uganda-1754","Breaking new ground: prosecuting the first money laundering case in Uganda","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F590cac34-405f-4b4f-8e1e-e900e0b11558?width=1000&height=650&format=webp&quality=80",[347],7419,[134,300],[17],[],1754,[134,135],[17],[355],1230,[],[202],[],"2022-05-26T22:54:56.000Z","2026-05-29T22:21:52.000Z",[],"\u002Fresources\u002Fnews\u002Fbreaking-new-ground-prosecuting-the-first-money-laundering-case-in-uganda-1754",{"left":364,"top":364,"width":365,"height":365,"rotate":364,"vFlip":366,"hFlip":366,"body":367},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>",1780676512141]