[{"data":1,"prerenderedAt":302},["ShallowReactive",2],{"news-operational-credibility-is-a-strategic-asset-in-the-defence-industry-what-does-that-mean-for-ukraine-and-its-partners-2965":3,"news-operational-credibility-is-a-strategic-asset-in-the-defence-industry-what-does-that-mean-for-ukraine-and-its-partners-2965-similar":74,"i-heroicons:arrow-left-20-solid":297},[4],{"id":5,"status":6,"date_created":7,"date_updated":7,"title":8,"type":9,"body":10,"date":11,"topic":12,"slug":14,"activity":15,"nid":17,"topics":18,"activities":19,"programme":20,"area":20,"websites":20,"language":21,"image":22,"translation_of":20,"countries":32,"tags":54,"authors":55,"images":71,"translations":72,"content":73},10618,"published","2026-06-04T21:13:47.000Z","Operational credibility is a strategic asset in the defence industry. What does that mean for Ukraine and its partners?","Blog","_Europe’s defence sector is changing fast. More money, political attention and international partnerships are flowing into the industry. At the same time, defence companies face growing pressure to show not just what they produce, but how they operate._ \n\n_In this blog, Yuliia Brusko explores why transparency and operational credibility are becoming more important – especially for Ukraine’s wartime-built defence industry. The article builds on the Basel Institute’s ongoing work in Ukraine, including with defence-sector stakeholders on governance, integrity and operational resilience under wartime conditions._ \n\n### Defence companies are entering a new era of scrutiny\n\nEuropean defence companies are attracting unprecedented levels of capital, political attention and strategic relevance. Yet alongside this growth comes a level of external scrutiny many firms were never built for.\n\nA recent public dispute involving Czech defence company Czechoslovak Group (CSG) illustrates this shift. A [report](https:\u002F\u002Fhntrbrk.com\u002Fcsg\u002F) published by Hunterbrook Media questioned aspects of CSG’s production claims, business model and corporate structure. Among other issues, the report raised questions about the transparency of certain ownership and subsidiary structures, the company’s reliance on intermediary and external procurement arrangements, and the extent to which publicly communicated production and business claims could be independently substantiated by external actors. \n\nWhile the company strongly [rejected](https:\u002F\u002Fcsg.com\u002Fen\u002Fnews\u002Fcsg-sets-the-record-straight-in-response-to-short-seller-allegations) the allegations, the case reveals a broader structural change: the increasing demand for operational verifiability.\n\nIn the booming defence industry, investors, procurement actors and international partners are no longer relying on growth narratives or high-level political positioning. Increasingly, they are trying to independently verify how companies actually operate, including: \n\n*   Where key dependencies sit\n*   How production is organised\n*   Whether public claims align with realities\n\nThis shift is partly driven by the changing structure of the defence market itself. Alongside traditional defence primes, the sector now includes rapidly scaling private manufacturers, drone producers and venture-backed technology firms. \n\nMany are entering international financing and export ecosystems that expect a level of operational accountability historically uncommon in parts of the defence sector.\n\n### Bridging wartime pragmatism and market expectations in Ukraine\n\nThis demand for clarity creates a unique challenge for Ukraine’s defence industry. Developed under wartime conditions, Ukrainian companies have prioritised speed, adaptability and survivability over externally defensible corporate structures. \n\nDistributed manufacturing, fragmented supply chains and parallel operational entities are practical wartime adaptations, not signs of weak governance.\n\nHowever, as the sector seeks deeper integration with European partners, these same features can create friction. Documentation and traceability systems built under the urgency of survival often struggle to meet the requirements of international financing and export ecosystems.\n\nThe problem is not necessarily the complexity or the inherent opacity of these arrangements; it is the inability to credibly explain and defend them to external stakeholders who can no longer rely on informal trust alone.\n\n### Operational credibility is becoming a strategic requirement\n\nAs scrutiny becomes more operational, companies are increasingly assessed not only on what they produce, but on whether their operational realities can withstand external examination. When structures are too opaque to confidently assess, perceived risk can outweigh strategic value.\n\nThis creates pressure not only for Ukrainian manufacturers, but also for European defence companies navigating a rapidly changing market. For those seeking long-term integration into international financing, procurement and partnership ecosystems, the ability to defend operational realities is becoming a core business capability.\n\n### A shift from trust-based networks to verifiable systems\n\nThe transition from relatively closed government and industry networks toward a more financialised and internationally interconnected market is reshaping how defence companies are assessed. Shifting to this next step is crucial as deftech companies move from niche producers to systemically important security providers. As their technology increasingly moves independently from the large defense primes, the obvious question arises of “going it alone.” While technologically, the choice is obvious, providing sufficient assurance for direct competitive government procurements will require solid systems. \n\nThe challenge is not eliminating operational complexity or wartime opacity. In many cases, these are unavoidable features of how modern defence industries function under pressure. The challenge is whether companies can credibly explain and defend those realities once they enter ecosystems built around external review, institutional accountability and sophisticated due diligence.\n\nFor many defence companies, this will require the ability to clearly explain aspects like: \n\n*   How production is organised\n*   How supplier and partnership structures operate in practice\n*   How key decisions are documented under wartime conditions\n*   How public production claims can be substantiated when questioned by investors, procurement actors or international partners. \n\nThis is likely to require more structured approaches to documentation, traceability and internal oversight – not to replicate peacetime bureaucracy, but to ensure that wartime realities can be credibly defended when scrutiny arises.\n\n### Adaptability alone will no longer be enough\n\nIn this environment, the ability to combine wartime adaptability with institutional credibility may increasingly determine which companies are able to scale, attract financing and secure long-term positions within international markets.\n\nThis increases the importance of building credible systems for transparency, documentation, internal oversight and operational accountability in individual companies and across the defence ecosystem. \n\nAchieving this is no easy task. It will require sustained cooperation between Ukrainian defence companies, international partners, investors, procurement actors and policymakers – indeed, any actor keen to see Ukraine’s phenomenal defence capabilities more deeply integrated into international markets and partnerships. \n\nAt the Basel Institute, we are increasingly working directly with Ukrainian defence companies and their associations to strengthen compliance on an individual or collective basis and welcome new partners. \n\n_The Basel Institute's work on Ukraine's defence integrity is supported by Norway. This blog represents the views of the author only._","2026-05-13",[13],"","operational-credibility-is-a-strategic-asset-in-the-defence-industry-what-does-that-mean-for-ukraine-and-its-partners-2965",[16],"Insights",2965,[],[16],null,"English",{"id":23,"storage":24,"filename_disk":25,"filename_download":26,"title":8,"type":27,"created_on":7,"modified_on":7,"charset":20,"filesize":28,"width":29,"height":30,"duration":20,"embed":20,"description":20,"location":20,"tags":20,"metadata":31,"focal_point_x":20,"focal_point_y":20,"tus_id":20,"tus_data":20,"uploaded_on":7},"6e5fbb34-c87f-4281-94cb-55f2cd75b3a0","local","6e5fbb34-c87f-4281-94cb-55f2cd75b3a0.webp","tmp.webp","image\u002Fwebp",50746,800,533,{},[33],{"id":34,"news_id":35,"countries_id":48},7816,{"id":5,"status":6,"user_created":36,"date_created":7,"user_updated":36,"date_updated":7,"title":8,"type":9,"body":10,"image":23,"date":11,"topic":37,"slug":14,"activity":38,"nid":17,"topics":39,"activities":40,"programme":20,"area":20,"websites":20,"translation_of":20,"language":21,"countries":41,"tags":42,"authors":43,"images":45,"translations":46,"content":47},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6",[13],[16],[],[16],[34],[],[44],1374,[],[],[],{"id":49,"name":50,"code":51,"latitude":52,"longitude":53},225,"Ukraine","UA",48.37943,31.16558,[],[56],{"id":44,"news_id":57,"authors_id":68},{"id":5,"status":6,"user_created":36,"date_created":7,"user_updated":36,"date_updated":7,"title":8,"type":9,"body":10,"image":23,"date":11,"topic":58,"slug":14,"activity":59,"nid":17,"topics":60,"activities":61,"programme":20,"area":20,"websites":20,"translation_of":20,"language":21,"countries":62,"tags":63,"authors":64,"images":65,"translations":66,"content":67},[13],[16],[],[16],[34],[],[44],[],[],[],{"id":69,"name":70,"position":20,"image":20},593,"Yuliia Brusko",[],[],[],[75,102,128,152,174,199,222,245,276],{"id":76,"body":77,"status":6,"type":9,"date":78,"slug":79,"title":80,"image":81,"countries":82,"topic":83,"activity":87,"tags":88,"nid":89,"topics":90,"activities":91,"authors":92,"images":93,"websites":94,"area":20,"programme":20,"language":21,"translations":96,"translation_of":20,"user_created":36,"date_created":97,"user_updated":98,"date_updated":99,"content":100,"link":101},10538,"J. Edward “Ned” Conway became Executive Secretary of the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) on 1 November 2024, succeeding Alan Ketley. With its 12 member banks, the Wolfsberg Group is a globally respected source of expertise on financial crime risk management, setting industry standards and building bridges between financial institutions and other stakeholders. The Basel Institute serves as Secretariat to the Group, which is now in its 25th year.\n\nIn this Q&A, Ned challenges us to consider how we can make the fight against financial crimes more effective. He also highlights the value that the Wolfsberg Group can provide to the financial services industry, policymakers and law enforcement, with its global reach and technical knowledge of the financial crime landscape and financial industry.\n\n### What drives your career in countering financial crime?\n\nYou can read my [bio here](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F77\u002F), but I can highlight a couple of things that motivate me.\n\nFirst, my experiences working for the US Department of Defence in Iraq, in a unit focused on analysing and disrupting the financing of terrorist groups and insurgent networks. Most of the old-school ideas and methods we were trying were just not working. That made us ask: What are we _ultimately_ trying to achieve by countering threat finance? What plan or strategy will get us there more effectively?\n\nAs financial crime evolves, it remains vital to keep questioning our goals and the effectiveness of the measures we are using to achieve them. It’s a fascinating, ever-changing field.\n\nSecond, I’m an analyst at heart and love digging into data, so finance is a natural field. But I also relish personal interactions and am fascinated by psychology and behaviour, especially decision-making.\n\nAfter leaving the Department of Defence I studied for a PhD in international relations. During my field work in Central Asia, I saw the real-life impacts of corruption and financial crime on ordinary people and businesses. It was clear that financial crime compliance and risk management are not only interesting fields in themselves. They are also a chance to put the structural pressures in place to incentivise good behaviour, to make it easier for those in power to “do the right thing” and for ordinary people to feel the benefits.\n\nAnd third, properly managing financial crime risks can also have a positive impact on the environment, another area of focus I have been passionate about from a young age. Take illegal logging, illegal mining and wildlife trafficking in places like the Amazon. If financial institutions and law enforcement can do more to disrupt the finances of the organised crime groups profiting from these crimes, the impact on their operations will be significant. That’s positive for biodiversity and for the climate, as well as for local people.\n\n### What drew you to the Wolfsberg Group?\n\nFirst and foremost, it’s the people. It’s exhilarating to work with a group of individuals who are highly knowledgeable about the technical side of countering financial crime and just as passionate about doing it as me.\n\nSo who are we exactly? Our members represent 12 global banks. When you consider their correspondent banking networks, the majority of the US dollar, euro and pound sterling financial system relies on our member banks to process transactions. And these 12 banks collectively have hundreds of millions of customers in their own right, from individuals to large corporations across the world.\n\nPrimary delegates to the Group are usually the heads of the banks’ financial crime compliance divisions, and the secondary delegates are their deputies. Other senior bank staff specialised in, for example, complex investigations, fraud, virtual assets or sanctions form subject-matter expert working groups.\n\nWe also engage with external stakeholders like law enforcement, financial intelligence units, regulators and supervisors, and civil society, depending on the topic.\n\nIt’s safe to say that all of us see the importance and value of our work and want to get it right. That’s vital to our reputation as a trusted source of technical expertise on financial crime risk management.\n\nI pay tribute to Alan Ketley, Tracy Paradise, Hans-Peter Bauer, John Cusack, and other previous secretaries, chairs and members for developing this committed group not just of financial institutions but of people.\n\n### What does the Group do?\n\nIn essence, we act as a bridge between financial institutions and the needs and goals of policymakers and law enforcement.\n\nOn the policy side, we can contribute to shaping more effective laws, regulatory guidance and measures against financial crime. For example, if the EU is thinking of developing new regulations on payment transparency, we can provide constructive feedback on proposed measures and drafts. We can also help regulators and supervisors to responsibly cut red tape and foresee the consequences of deregulation.\n\nOn the law enforcement side, we exchange on investigative techniques, trends and typologies in financial crime. This helps financial institutions to hone their financial crime risk management and reporting frameworks. It also helps law enforcement and FIUs to understand how they can use banks’ information and capabilities more effectively.\n\n### How does your work translate to practical guidance?\n\nWe provide [practical frameworks and guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources?type=cbddq-fccq) for the financial services industry as a whole.\n\nA prime example is the [Correspondent Banking Due Diligence Questionnaire](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F36) or CBDDQ. This is an industry standard for conducting reasonable due diligence before agreeing correspondent banking relationships. We have translated the related Guidance, Glossary and FAQs into various languages to make it more accessible.\n\nOther examples include a recent [Statement on Monitoring for Suspicious Activity](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F69). That line of work essentially outlines the responsible framework for innovation in a highly regulated sector, applying artificial and machine learning to improve our ability to support law enforcement and meet supervisory expectations.\n\n### How does the Group work?\n\nOur approach is to build trust and provide constructive feedback based on our technical expertise and deep understanding of the global financial services industry.\n\nWe are a consensus-based group and we do what we say. When our member banks agree on a document, like a statement or a set of guidance, we collectively commit to doing what we recommend in the document. That’s a very powerful statement. And building, finding, and maintaining that consensus takes constant care and management.\n\nOne area I’m keen on advancing is how we can better move from strategic alignment – high-level agreement on financial crime goals and measures – to operational gains, i.e. more effective systems in practice.\n\nFor example, it’s easy to say we should use artificial intelligence to improve systems for monitoring and reporting suspicious activities to the authorities. In practice, doing so will need things like testing, validation, analysing results, explaining how algorithms are working… technical steps that don’t make headlines but that are essential to making progress and doing so responsibly.\n\nWe’ll be doing more workshops and face-to-face interactions to advance those technical steps. That will also help us to tease out areas where there are legitimate differences of opinion between parties, and we can then focus our efforts on addressing those concerns.\n\n### What are the Group’s priorities?\n\nThematically, we continue to take a deep look at:\n\n*   Suspicious activity monitoring. As an industry, we put a huge amount of resources into monitoring and reporting suspicious activities to the competent authorities. But it is broadly recognised that the system is not achieving the desired results.\n*   How we assess risk. This includes applying a risk-based approach to financial crime compliance to avoid detrimental impacts on the underbanked, including non-profit organisations, improving financial inclusion while simultaneously prioritising resources to address clear financial crime risk.\n*   Fraud, especially “confidence scams”, where victims are convinced they are investing in an opportunity or relationship that turns to be completely false.\n\nWe are also very interested in better ways to measure and assess the effectiveness of our financial crime compliance efforts in general. We work with key regulatory authorities in the US, UK EU and other countries and regions as regulation is reformed.\n\n### What bridges do you see with the Basel Institute’s work?\n\n[Like the Basel Institute](https:\u002F\u002Fbaselgovernance.org\u002Fabout), we are primarily focused on technical competence and building bridges between stakeholders, not advocacy in support of narrow interests.\n\nIn fact, the Wolfsberg Group is an early example of [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) – bringing together different stakeholders in a sustained engagement to improve business integrity, or in our case, the management of financial crime risks. The Basel Institute has huge credibility in this space and contributed to the Group’s foundation 25 years ago.\n\nAnd beyond our alignment with the goals of the Basel Institute’s [asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002F) and [Green Corruption](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption) workstreams, a clear point of interest is the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F). This tool for country-based financial crime risk assessments is a core aspect of any financial institution’s risk management process. Most banks use the Basel AML Index in their risk models.","2025-03-10","making-financial-crime-risk-management-work-for-all-insights-from-the-wolfsberg-group-2779","Making financial crime risk management work for all: Insights from the Wolfsberg Group","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Facf339c5-225b-42b7-bd8a-8a6ef363264f?width=1000&height=650&format=webp&quality=80",[],[84,85,86],"Anti-Money Laundering","Collective Action","Private Sector",[16],[],2779,[84,85,86],[16],[],[],[95,85],"Main page",[],"2025-03-10T11:01:36.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-04-27T21:01:58.000Z",[],"\u002Fresources\u002Fnews\u002Fmaking-financial-crime-risk-management-work-for-all-insights-from-the-wolfsberg-group-2779",{"id":103,"body":104,"status":6,"type":9,"date":105,"slug":106,"title":107,"image":108,"countries":109,"topic":111,"activity":113,"tags":114,"nid":115,"topics":116,"activities":118,"authors":119,"images":121,"websites":122,"area":20,"programme":20,"language":20,"translations":123,"translation_of":20,"user_created":36,"date_created":124,"user_updated":98,"date_updated":125,"content":126,"link":127},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",[110],7419,[84,112],"Asset Recovery",[16],[],1754,[84,117],"Asset Recovery and Enforcement",[16],[120],1230,[],[95],[],"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",{"id":129,"body":130,"status":6,"type":9,"date":131,"slug":132,"title":133,"image":134,"countries":135,"topic":136,"activity":137,"tags":138,"nid":139,"topics":140,"activities":141,"authors":142,"images":144,"websites":145,"area":20,"programme":20,"language":20,"translations":146,"translation_of":20,"user_created":36,"date_created":147,"user_updated":148,"date_updated":149,"content":150,"link":151},10128,"_A version of this blog post initially appeared in the Summer 2015 edition of [Ethical Boardroom Magazine.](https:\u002F\u002Fethicalboardroom.com\u002F)_\n\nMany companies recognise the importance of high-level management commitment in the development and implementation of an effective compliance programme, as evidenced by the repeated emphasis on establishing the ‘tone from the top’. Without clear demonstration of CEO and board-level dedication to promoting a culture of integrity within the firm, the statements and procedures communicated in a code of conduct or internal policies will bear little resonance among employees, external stakeholders – or law enforcement and regulatory agencies, in the case of a breach.\n\nDespite the widespread and increasing enactment of anti-corruption compliance and ethics programmes however, firms continue to face corruption challenges that can severely hamper their operations in certain markets.  It is in this context that anti-corruption Collective Action has emerged. By working with competitors and other stakeholders in civil society, government or even other industries, Collective Action takes compliance and ethical business practices beyond a firm’s own internal policies and procedures, and instead seeks to raise standards among all market participants.\n\nForward-thinking CEOs and boards are encouraged to adopt this clear shift towards business driven integrity. For, as in the case of an anti-corruption compliance programme, strong leadership is a vital component towards the success of Collective Action.\n\nAnti-corruption Collective Action\n---------------------------------\n\nDefined variously as a “catch-all term for industry standards, multi-stakeholder initiatives, and public-private partnerships,” or as “a collaborative and sustained process of cooperation amongst stakeholders (that) increases the impact and credibility of individual action, brings vulnerable individual players into an alliance of like-minded organisations and levels the playing field between competitors,” Collective Action initiatives can be sector-specific or multi-sector based, and can involve participants beyond the private sector. They may be differentiated by the level of enforcement applied to the commitments made by the firms involved, whether it be a signed declaration committing all stakeholders to operate free of corruption, or more complex varieties which include ethics boards, external monitors or mechanisms for sanctioning non-compliance.\n\nA number of Collective Action initiatives have taken shape over the past two decades, and across a number of sectors, including banking, energy and transportation, extractive industries, aerospace and defence, as well as multi-sector initiatives. Civl society representative Transparency International has long supported Collective Action through its Integrity Pacts, a tool developed to improve transparency and preven corruption in public procurement. The B20 recommendations from Los Cabos in 2012 highlighted the importance of Collective Action and encouraged business involvement. The recommendations led to the creation of this B20 Collective Action Hub.\n\nAlthough there is no ‘one-size-fits-all’ approach, several elements have been observed that contribute to the successful establishment and operation of a Collective Action initiative. Facilitators from civil society can support the initial creation of an initiative, which, as a business-driven undertaking, should be led by companies. This is often easier when taken up by a leading player within the industry, though it is not essential. The involvement of facilitators also mitigates anti-trust issues and enables a neutral basis from which to identify issues of common interest. Allowing time for companies to develop trust and understanding are also important to the success of an initiative.\n\nUnderscoring all of these elements is the support of senior leadership, as this will bolster the chances of success and exemplifies business-driven integrity.\n\nThe importance of top-level commitment\n--------------------------------------\n\nSenior management is attuned to the company’s reputation risks and business goals and has the power to command support for driving a Collective Action initiative. In practice the General Counsel, Chief Compliance Officer and the CEO are likely to be the decision makers when it comes to initiating or joining a Collective Action as they know where the firm’s corruption risks lie. Having decided to pursue Collective Action, senior management must then delegate suitably experienced and senior persons to represent the company at the discussions to develop the Collective Action. By establishing a clearly articulated vision of where anti-corruption Collective Action fits within the company, its anti-corruption compliance and in relation to its competitors and business environment, management is on a good path towards contributing to the initiative’s success.\n\nAppointing the right people to represent the company and to sit opposite peer companies and competitors will contribute to the initiative’s chances for success and show management’s clear commitment to the initiative, both internally as well as to the other companies represented. \n\nEqually, the representatives of the participating companies will be empowered by the knowledge that their efforts have the complete support of top management. This is critical due to the length of time required to develop consensus and build trust. Should the participants during the course of the discussions have doubts as to the internal reasoning behind or commitment of their firms’ engagement, this could create hurdles that hinder its effectiveness or lead to its breaking down. \n\nIn sum, top management commitment is very important to the firm’s involvement in the Collective Action initiative, thus contributing to its potential for real impact.\n\nAs a facilitator and incubator of Collective Action initiatives, the Basel Institute on Governance has witnessed how senior management commitment influences the contours, direction, and ultimately success, of a Collective Action.\n\nIn 2004, under the World Economic Forum (WEF) and in partnership with Transparency International, the Basel Institute served as a founder of the [Partnering Against Corruption Initiative (PACI)](https:\u002F\u002Fwww.weforum.org\u002Fcommunities\u002Fpartnering-against-corruption-initiative), which brought together CEOs from engineering and construction, mining and metals, and the energy sector. This initiative of today nearly 100 companies is a leading global voice on anti-corruption and transparency. Further bolstering its CEO-driven agenda, PACI has recently established the PACI Vanguard, a CEO community from within WEF and PACI members which aims to further direct the PACI strategy through sustained and high level business-government engagement with particular emphasis on anti-corruption Collective Action.\n\nIn an industry sector example, one group of companies to whom the Basel Institute has served as a facilitator demonstrates how the support of top management has been critical to the progress made by the companies involved. In this initiative, the representatives at the table themselves come from the highest levels of compliance and legal areas within their respective firms.\n\nAt times during the discussions, the representatives have stressed to their counterparts that the work that they as a group are doing to develop the Collective Action, is fully supported by their respective CEOs, with whom the representatives have direct contact. This has allayed concerns that have arisen and contributed to the trust between the parties. Conversely, a different industry group is represented by more junior level compliance personnel who continually have to revert to their managers, thus hindering the discussions and hampering progress towards any common goals.      \n\nMoving forward\n--------------\n\nWith enforcement actions against companies engaging in bribery continuing to increase, top management is becoming more aware that it makes business sense to work with other stakeholders to remove corruption from the business environment. This relationship between top management, the tone from the top and Collective Action is further reinforced by government authorities.\n\nThe UK Ministry of Justice’s [Guidance](https:\u002F\u002Fwww.justice.gov.uk\u002Fdownloads\u002Flegislation\u002Fbribery-act-2010-guidance.pdf) on the 2010 UK Bribery Act makes explicit reference to this in Principle 2 entitled “Top-level commitment,” section 2.3: “Internal and external communication of the commitment to zero tolerance to bribery,” whereby it states that demonstrations of this commitment can include reference to an organisation’s engagement in collective action against bribery.\n\nCollective Action should remain at the forefront for CEOs and boards looking beyond risk mitigation and towards improving the overall business environment and levelling the playing field. Their commitment and leadership role will play a key part in the chances for success of these endeavours.","2015-11-30","building-alliances-to-tackle-corruption-267","Building alliances to tackle corruption","\u002Fpics\u002Fimg-placeholder.png",[],[85,86],[16],[],267,[85,86],[16],[143],1311,[],[95,85],[],"2022-05-26T22:59:03.000Z","b0662e2a-864d-4888-a1b7-4342b7570b30","2025-08-31T23:14:59.000Z",[],"\u002Fresources\u002Fnews\u002Fbuilding-alliances-to-tackle-corruption-267",{"id":153,"body":154,"status":6,"type":9,"date":155,"slug":156,"title":157,"image":158,"countries":159,"topic":160,"activity":161,"tags":163,"nid":164,"topics":165,"activities":166,"authors":167,"images":168,"websites":20,"area":20,"programme":20,"language":21,"translations":169,"translation_of":20,"user_created":36,"date_created":170,"user_updated":98,"date_updated":171,"content":172,"link":173},10582,"_A breakout session at the [9th Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002F9crc) focused on blockchain intelligence standards and interoperability – an issue that is becoming ever more critical for all who seek to prevent and combat the illicit use of virtual assets for financial crime._\n\n_Breakout leader [Bernhard Haslhofer](https:\u002F\u002Fbernhardhaslhofer.info\u002F) of the Complexity Science Hub Vienna explains the challenge below, and why the breakout represents a promising step towards the co-development of open standards in this domain._\n\nThe absence of standardisation and interoperability among blockchain intelligence tools has emerged as a critical challenge for all stakeholders working on preventing and countering financial crime.\n\nIncompatibilities manifest across multiple dimensions: data formats vary between platforms, identical concepts are described using different terminologies, computational methods such as address clustering follow divergent approaches, and user interfaces lack consistency.\n\nConsequently, problems include:\n\n*   Investigators work with isolated tool ecosystems with no systematic mechanisms for connecting investigations across platforms. This hinders inter-agency and cross-border cooperation.\n*   Prosecutors face problems demonstrating the reliability, admissibility and validity of blockchain evidence in court, in the absence of court-proof forensic procedures and standardised methods (in contrast to DNA analysis, for example).\n*   Judges in court proceedings involving blockchain intelligence currently rely on case-by-case testimonies from tool providers or expert witnesses. This creates resource-intensive judicial processes and lacks consistent interpretation across cases.\n*   Regulators and supervisors for anti-money laundering and counter financing of terrorism (AML\u002FCFT) use inconsistent blockchain intelligence methodologies and typologies to monitor for suspicious transaction patterns and conduct risk profiling.\n*   Training and certification are also at stake. The field lacks independent qualification standards, allowing unqualified practitioners to operate in the field and undermining professional credibility across the domain.\n\nThis situation reflects a typical pattern in emerging technology domains. Historical parallels exist across industries. For example, electrical systems evolved from incompatible regional standards to interoperable networks through adapter technology. Word processing software transitioned from proprietary formats to systems supporting cross-platform document exchange, without capitalising on the strengths of individual tools.\n\nAs blockchain intelligence transitions from an emerging field to an established professional domain, adopting similar standardisation approaches becomes necessary to ensure long-term viability and effectiveness.\n\n### A promising step towards collaboration\n\nAt the 2025 9th Global Conference on Criminal Finances and Cryptoassets organised by Europol, the Basel Institute on Governance and UNODC, we convened a workshop on creating harmonised standards for blockchain intelligence. The session assembled expertise from multiple domains: existing standardisation initiatives by INTERPOL and the [Global Coalition to Fight Financial Crime](https:\u002F\u002Fwww.gcffc.org\u002F), legal scholarship and practice, and operational perspectives from both analytics providers and cryptocurrency exchanges.\n\nIn addition to participants from legal and academic backgrounds, we had strong industry representation including blockchain analytics firms and cryptoasset exchanges. This ensured technical feasibility considerations informed the discussion.\n\nThe workshop addressed four critical components:\n\n*   Defining the technical scope by identifying specific components and processes requiring standardisation across blockchain intelligence tools and workflows.\n*   Outlining the legal and regulatory framework, including jurisdictional considerations, data handling protocols and compliance requirements.\n*   Mapping stakeholders whose participation is essential for standard adoption and implementation.\n*   Developing a concrete implementation pathway from initial agreement through pilot implementation to deployed, operational and open standards.\n\n### Technical scope\n\nThe discussion identified interoperability challenges across multiple technical layers. Immediate opportunities include:\n\n*   standardised data formats for attribution tags enabling third-party dataset integration;\n*   unified terminologies to eliminate semantic conflicts across platforms; and\n*   standardised investigation formats allowing transaction graph sharing without exposing proprietary attribution data.\n\nThese standards would provide direct operational benefits while respecting competitive boundaries between tool providers. For criminal prosecutions or asset recovery proceedings, they would also support the documentation of attribution tag provenance with a clear chain of custody and evidence classification.\n\nAddress clustering on UTXO chains such as Bitcoin presents greater complexity. Applied computational methods such as address clustering must provide transparent justification for grouping addresses into single entities. Yet experts noted significant variation in clustering results across tools and limited external verification capabilities. Providers meanwhile emphasised that computational methods constitute intellectual property, though accessible for regulatory scrutiny.\n\nParticipants agreed that initial standardisation efforts should prioritise readily implementable solutions, with any framework accounting for economic incentives that protect proprietary intelligence from competitors.\n\n> ### What would standards look like?\n> \n> Open standards for blockchain intelligence would be technical in nature but practical in impact. Examples of successful open standards in other domains include:\n> \n> *   [IETF RFC standards](https:\u002F\u002Fwww.ietf.org\u002Fprocess\u002Frfcs\u002F) describing internet technologies, protocols, and procedures\n> *   [W3C Web Standards](https:\u002F\u002Fwww.w3.org\u002Fstandards) ensuring a consistent and harmonious digitally connected world. They are implemented in browsers, blogs, search engines, and other software that power our experience on the web.\n> *   [STIX and TAXII](https:\u002F\u002Foasis-open.github.io\u002Fcti-documentation\u002F) are industry standards for sharing cyber threat intelligence.\n\n### Stakeholder participation and incentives\n\nThe successful development and implementation of standards require engagement from at least three stakeholder groups:\n\n*   Blockchain intelligence providers must contribute to the standardisation process and implement them within their platforms.\n*   User communities, including law enforcement agencies, financial regulators, cryptocurrency exchanges and financial institutions, must articulate operational needs and validation criteria.\n*   Technical experts provide methodological guidance to ensure standards are robust, implementable, and account for current capabilities as well as future scalability.\n\nIncentive structures differ across stakeholders. Tool providers benefit from meeting expressed user requirements. Establishing technically grounded standards through bottom-up consensus would also pre-empt potentially impractical top-down regulatory mandates.\n\nUsers gain operational autonomy and reduced vendor lock-in. This enables investigative continuity across platforms and organisational flexibility in tool selection, as well as enhanced reliability and sharing of blockchain intelligence data.\n\n### Next steps and learn more\n\nParticipants agreed that continued discussion must translate into concrete action, prioritising readily implementable solutions while considering incentive structures across all stakeholder groups. Follow-up steps will be announced in due course. Meanwhile:\n\n*   See the joint press release from the [9th Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fglobal-experts-advance-joint-fight-against-crypto-enabled-crime), including links to recordings from public sessions.\n*   Read a Q&A with Vincent Danjean, Head of INTERPOL’s Cyberspace and New Technologies Laboratory, on efforts to enhance the [quality of blockchain intelligence](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fsmarter-blockchain-investigations-insights-interpol).\n*   Learn more about the [concept and use of blockchain intelligence](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fsetting-global-standards-blockchain-intelligence-idea-reality) and why professional standards are needed.\n*   Need the basics? Check out the Basel Institute's [introductory courses on blockchain: crypto investigation and AML compliance](https:\u002F\u002Fbaselgovernance.org\u002Fcrypto-aml-training).","2025-11-24","developing-blockchain-intelligence-standards-and-interoperability-a-critical-need-to-fight-financial-crime-in-the-digital-age-2879","Developing blockchain intelligence standards and interoperability: a critical need to fight financial crime in the digital age","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F0abcdf39-2cbe-462b-a1b2-74fbe836dc7c?width=1000&height=650&format=webp&quality=80",[],[112],[16,162],"Partnerships",[],2879,[117],[16,162],[],[],[],"2025-11-24T11:01:40.000Z","2026-05-29T22:22:38.000Z",[],"\u002Fresources\u002Fnews\u002Fdeveloping-blockchain-intelligence-standards-and-interoperability-a-critical-need-to-fight-financial-crime-in-the-digital-age-2879",{"id":175,"body":176,"status":6,"type":177,"date":178,"slug":179,"title":180,"image":181,"countries":182,"topic":184,"activity":185,"tags":187,"nid":188,"topics":189,"activities":190,"authors":191,"images":192,"websites":193,"area":20,"programme":20,"language":20,"translations":194,"translation_of":20,"user_created":36,"date_created":195,"user_updated":98,"date_updated":196,"content":197,"link":198},10094,"Experts from ICAR delivered a 4-day training workshop on Operational Analysis to the Peruvian Financial Intelligence Unit (FIU) in Lima from 6 to 9 June 2016 with the aim to strengthen the FIU's analytical and operational capacities in financial investigations.\n\nThe training involved in a first instance the EGMONT [Operational Analysis course as an e-learning experience](https:\u002F\u002Fwww.baselgovernance.org\u002Felearning\u002Fcourses\u002Foperational-analysis) developed by the Institute's IT E-learning Specialists, which was regularly interspersed with a hands-on and interactive group exercise approach. While the former e-learning focused on best-practises in financial investigations, the latter subsequently emphasised country-specific operational elements relevant to Peru embedded in a potentially real money-laundering case scenario. The training integrated Peru's AML\u002FCFT and criminal frameworks with the aim to create stronger awareness of both, as well as to strengthen collaboration and cooperation between all concerned law enforcement authorities and the FIU.\n\n27 participants attended the training, mainly from the Operational Analysis Department of the FIU Peru. Most participants found the training very useful as it addressed “exactly what they have been doing in their everyday work”. \n\nThe training is part of a 5-year cooperation agreement signed between Superintendencia de Banca, Seguros y AFP (SBS) Peru and the Basel Institute aimed at supporting the strengthening of the capacity of the SBS to fight corruption, money laundering and other financial crimes. The funding for this specific training programme was provided by the State Secretariat for Economic Affairs (SECO).","News","2016-06-15","operational-analysis-training-for-the-financial-intelligence-unit-in-peru-289","Operational Analysis training for the Financial Intelligence Unit in Peru","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F57017434-4067-4e19-ad61-58429bf4cd9b?width=1000&height=650&format=webp&quality=80",[183],7644,[112],[186],"Training",[],289,[117],[186],[],[],[95],[],"2022-05-26T22:58:51.000Z","2026-05-29T22:22:12.000Z",[],"\u002Fresources\u002Fnews\u002Foperational-analysis-training-for-the-financial-intelligence-unit-in-peru-289",{"id":200,"body":201,"status":6,"type":177,"date":202,"slug":203,"title":204,"image":205,"countries":206,"topic":208,"activity":209,"tags":210,"nid":211,"topics":212,"activities":213,"authors":214,"images":215,"websites":216,"area":20,"programme":20,"language":20,"translations":217,"translation_of":20,"user_created":36,"date_created":218,"user_updated":98,"date_updated":219,"content":220,"link":221},9662,"The training team of the International Centre for Asset Recovery last week delivered an intensive [Advanced Operational Analysis](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes\u002Fadvanced-operational-analysis) training programme to 20 anti-corruption practitioners in Ukraine. This was the first time our ICAR training team has delivered a virtual workshop that involved both complex group work and simultaneous interpreting, and we are pleased to say that it went flawlessly.\n\nThe participants came from Ukraine’s State Financial Monitoring Service (SFMS), National Anti-Corruption Bureau (NABU), Specialized Anti-Corruption Prosecutor's Office (SAPO) and Asset Recovery and Management Agency (ARMA).\n\nThe training was funded by the [European Union Anti-Corruption Initiative](https:\u002F\u002Feuaci.eu\u002F) in Ukraine (EUACI). It built on two previous EUACI-funded training programmes that focused on essential skills in [financial investigations and asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Ficar-training-supports-new-anti-corruption-body-ukraine) and [offshore structures\u002Fmutual legal assistance](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fukrainian-anti-corruption-practitioners-trained-mla-requests-and-offshore-structures).\n\n### Analysing a suspicious transaction report: creating intelligence from information\n\nThe workshop combined our [Operational Analysis eLearning module](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=3), which the participants had to complete as an assignment, with live instructor-led sessions. These sessions included a complex simulated operational analysis tailored to the Ukrainian environment, in which the participants had to:\n\n*   analyse a suspicious transaction report (STR);\n*   gather information from databases and open-source searches;\n*   request more information from reporting entities and foreign counterparts;\n*   co-operate with other national agencies through information-sharing mechanisms and as part of investigative taskforces.\n\n### Understanding different roles and needs\n\nThe training helped the financial intelligence analysts to tailor their analysis to the needs of law enforcement agencies by identifying relevant aspects of the criminal offences detected and by tracing illegal assets. When applied in real life, this kind of knowledge helps ensure a smooth transition from the intelligence stage to the full-fledged investigation of a case.\n\nSAPO, NABU and ARMA representatives were also able to appreciate the role of the SFMS, which is Ukraine’s Financial Intelligence Unit, and how it can assist them in the investigation and prosecution of corruption and money laundering offences and in asset recovery. (For a general insight into this, read Thierry Ravalomanda’s [quick guide to the role of FIUs in asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fthierry-ravalomandas-quick-guide-role-fius-asset-recovery).)\n\n### In their own words\n\nParticipants enjoyed working in multi-disciplinary and multi-agency teams. It allowed them _\"to join forces together to crack the criminal case\"_ and _\"to work on common goals against a common enemy\",_ they said. One participant commented: _\"New knowledge was gained and more active cooperation between different law enforcement agencies was ensured.\"_\n\nAnother recurring comment was that the training was highly practical, as participants were required to apply the skills and knowledge in the _\"detective game\"_ or in daily assignments. _\"The materials on the platform have an unusually high level of interactivity, it really helps to master the knowledge.\"_","2020-10-28","advanced-operational-analysis-training-in-ukraine-helps-financial-intelligence-analysts-and-law-enforcement-work-better-together-1904","Advanced Operational Analysis training in Ukraine helps financial intelligence analysts and law enforcement work better together","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd789024e-0483-4e36-bacc-deeaefb65792?width=1000&height=650&format=webp&quality=80",[207],7384,[112],[186],[],1904,[117],[186],[],[],[95],[],"2022-05-26T22:53:58.000Z","2026-05-29T22:21:49.000Z",[],"\u002Fresources\u002Fnews\u002Fadvanced-operational-analysis-training-in-ukraine-helps-financial-intelligence-analysts-and-law-enforcement-work-better-together-1904",{"id":223,"body":224,"status":6,"type":177,"date":225,"slug":226,"title":227,"image":228,"countries":229,"topic":230,"activity":231,"tags":233,"nid":234,"topics":235,"activities":236,"authors":237,"images":238,"websites":239,"area":20,"programme":20,"language":20,"translations":240,"translation_of":20,"user_created":36,"date_created":241,"user_updated":98,"date_updated":242,"content":243,"link":244},9701,"Kenyan officials working in the fields of anti-corruption, intelligence and financial investigation undertook a four-day intensive training programme on [Advanced Operational Analysis](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes\u002Fadvanced-site-training-operational-analysis) last week. Delivered online by our [International Centre for Asset Recovery (ICAR) training team](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes), the course combines a self-paced eLearning course with more advanced presentations and a complex practical exercise.\n\n### “I loved the breakout sessions”\n\nAlthough ICAR has piloted this blended learning concept successfully before in Peru, Uganda, Namibia and Ecuador, this is the first time that the training programme was conducted fully online, including the “on-site” element.\n\nThe practical exercise involved a simulated analysis of a suspicious transaction report, which the participants conducted in small groups in virtual breakout rooms. Our experience is that when it comes to practical exercises and teamwork, virtual spaces are never as effective as getting everyone together around a physical table. Nevertheless, one participant said they _“loved the breakout sessions”_.\n\nAnother participant commented on how useful it was to complete the _“excellent”_ self-paced Operational Analysis eLearning course before taking the programme. “_It was practical … and highly interactive, easy to understand and very user-friendly,”_ they said.\n\n### Multi-agency groups – practising “how they should engage in real cases”\n\nEchoing [previous comments on how ICAR training programmes promote inter-agency cooperation](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fworking-together-against-common-enemy-how-icar-training-promotes-inter-agency-relations), one participant said _\"The multi-agency groups made it easier for participants to interact and project how it is they should actually engage in real cases.\"_\n\nThe 16 participants came from various Kenyan agencies responsible for investigating and prosecuting financial crimes, including:\n\n*   Financial Reporting Centre (Kenya’s Financial Intelligence Unit - FIU)\n*   Ethics and Anti-Corruption Commission\n*   Office of the Director of Public Prosecutions\n*   Kenya Revenue Authority\n\nThe main objective was to strengthen the analytical skills of financial intelligence analysts at the FIU. But the course was also designed to help participants from the other agencies to understand how the FIU operates and how they can benefit from its products while investigating or prosecuting financial crimes and recovering the proceeds of crime.\n\nOne prosecutor said _\"I now appreciate better the work of FIU and I wonder how it can really be fully utilised in prosecution-led investigations.\"_ The FIU analysts also learnt how to tailor their reports to the needs of law enforcement or prosecutorial authorities. One stated that for him, _\"it was one of the most useful courses of 2020.\"_\n\n### Free eLearning courses and quick guides\n\nThe Operational Analysis eLearning course, which was developed jointly with the [Egmont Group of Financial Intelligence Units](https:\u002F\u002Fegmontgroup.org\u002Fen), is freely available on the Basel Institute’s new [LEARN platform](https:\u002F\u002Flearn.baselgovernance.org\u002F). The platform is still under development and will shortly host all of the Basel Institute’s eLearning courses, as well as useful guidelines and resources for practitioners.\n\nIn the meantime, see an overview of all of our [free eLearning courses](https:\u002F\u002Fwww.baselgovernance.org\u002Felearning-courses) on our main website. Simply log in or create an account to get started.\n\nYou may also like some of our recent quick guides:\n\n*   [Phyllis Atkinson’s quick guide to effective training on financial investigations](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fphyllis-atkinsons-quick-guide-effective-training-financial-investigations)\n*   [Thierry Ravalomanda’s quick guide to the role of FIUs in asset recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fthierry-ravalomandas-quick-guide-role-fius-asset-recovery)\n*   [Peter Huppertz’s quick guide to eLearning for asset tracing and financial analysis](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fpeter-huppertzs-quick-guide-elearning-asset-tracing-and-financial-analysis)\n\nView [all quick guides here](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428).","2020-07-28","advanced-operational-analysis-training-in-kenya-gets-multiple-agencies-working-together-around-a-virtual-table-1826","Advanced Operational Analysis training in Kenya gets multiple agencies working together around a virtual table","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F3287d679-a7e6-40a6-bb90-126ab9c7f17c?width=1000&height=650&format=webp&quality=80",[],[112],[186,232],"eLearning",[],1826,[117],[186,232],[],[],[95],[],"2022-05-26T22:54:30.000Z","2026-05-29T22:21:50.000Z",[],"\u002Fresources\u002Fnews\u002Fadvanced-operational-analysis-training-in-kenya-gets-multiple-agencies-working-together-around-a-virtual-table-1826",{"id":246,"body":247,"status":6,"type":177,"date":248,"slug":249,"title":250,"image":251,"countries":252,"topic":262,"activity":263,"tags":264,"nid":265,"topics":266,"activities":267,"authors":268,"images":269,"websites":270,"area":20,"programme":20,"language":20,"translations":271,"translation_of":20,"user_created":36,"date_created":272,"user_updated":98,"date_updated":273,"content":274,"link":275},9647,"Twenty anti-corruption investigators and financial intelligence analysts from 10 African countries completed an intensive [Advanced Operational Analysis](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes\u002Fadvanced-operational-analysis) course last week hosted by the [Commonwealth Africa Anti-Corruption Centre](http:\u002F\u002Fwww.thecaacc.org\u002F) (CAACC).\n\nDelivered online by our International Centre for Asset Recovery (ICAR) [training team](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes), the workshop blended eLearning modules with live video sessions in which the participants worked together to solve a simulated corruption case.\n\n### Enhancing mutual understanding\n\nThe participants came from anti-corruption agencies and Financial Intelligence Units (FIUs) in Botswana, South Africa, Nigeria, Sierra Leone, Kenya, Namibia, Mauritius, Zambia and Lesotho.\n\nAs usual in ICAR training programmes, the multi-agency approach helped participants to better understand each other’s needs and roles. FIU analysts were encouraged to tailor their intelligence products to the needs of investigators in law enforcement agencies. In turn, investigators learnt how an FIU operates by taking the [Operational Analysis eLearning module](Enhancing%20mutual%20understanding) and solving the simulated case.\n\nBy the end of the week, participants fully understood the value of breaking silos down, of exchanging information and coordinating their actions, nationally and regionally. \n\n### Reflecting on FATF mutual evaluations\n\nThe training was also an opportunity for the participants to reflect on the lessons learnt from the recent Financial Action Task Force (FATF) evaluations of Mauritius, Zambia and Botswana.\n\nThese three countries have undergone an FATF fourth-round evaluation, which covers the _effectiveness_ of national systems to combat money laundering and terrorist financing and not merely technical compliance with FATF Recommendations. The [Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fbasel-aml-index), which assesses the risk of money laundering and terrorist financing around the world, has consistently noted that countries typically fall down the rankings when assessed with the new methodology.\n\nThe participants together looked at ways to enhance effectiveness in the use of financial intelligence for money laundering investigations, as well as in investigations, prosecutions and the confiscation of assets.\n\n### Impact and collaboration\n\nThis impact-driven training aimed to provide participants with skills that are directly applicable in their daily work. We were happy to receive participants’ comments including “it touched on similarities of the case I am currently investigating” and “the financial analysis will improve the presentation of my case”. One participant commented that the training will “help me in investigating suspicious transaction reports that I recently received”.\n\nThe Basel Institute has a long-standing relationship with the Botswana-based CAACC and has conducted previous workshops in 2017 and 2020. See our article about the [2020 workshop on Financial Investigations and Asset Recovery](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fbuilding-bridges-anti-corruption-cooperation-africa) for more information about the CAACC and our fruitful collaboration.\n\n### ICAR training in multiple languages\n\nTo find out more about ICAR training programmes, please download our latest brochure in English, Spanish, French or Portuguese:\n\n*   [English: Training programmes – Financial investigations and asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-11\u002FICAR%20training%20brochure%20Nov%202020.pdf)\n*   [Español: Programas de capacitación – Investigaciones financieras y recuperación de activos](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-12\u002F201208_icar-trainings-spanish.pdf)\n*   [Français : Programmes de formation – Enquêtes financières et recouvrement d’avoirs](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-12\u002F201208_icar-trainings-french.pdf)\n*   [Português: Programas de formação – Investigações financeiras e recuperação de activos](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-12\u002F201208_icar-trainings-portugese.pdf)","2020-12-08","ten-country-advanced-operational-analysis-training-offers-chance-to-reflect-on-the-effectiveness-of-aml-systems-1937","Ten-country Advanced Operational Analysis training offers chance to reflect on the effectiveness of AML systems","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Ff9578a9e-8360-48f7-983d-5a9df0281030?width=1000&height=650&format=webp&quality=80",[253,254,255,256,257,258,259,260,261],7368,7369,7370,7371,7372,7373,7374,7375,7376,[84,112],[186,232],[],1937,[84,117],[186,232],[],[],[95],[],"2022-05-26T22:53:45.000Z","2026-05-29T22:21:47.000Z",[],"\u002Fresources\u002Fnews\u002Ften-country-advanced-operational-analysis-training-offers-chance-to-reflect-on-the-effectiveness-of-aml-systems-1937",{"id":277,"body":278,"status":6,"type":177,"date":279,"slug":280,"title":281,"image":134,"countries":282,"topic":283,"activity":284,"tags":285,"nid":286,"topics":287,"activities":288,"authors":289,"images":290,"websites":291,"area":20,"programme":20,"language":20,"translations":292,"translation_of":20,"user_created":36,"date_created":293,"user_updated":98,"date_updated":294,"content":295,"link":296},10071,"Analysing suspicious financial activities is a key function of Financial Intelligence Units (FIUs). To enhance the capacity of FIUs worldwide, ICAR in cooperation with the Egmont Group of FIUs has developed a unique e-learning course on “Operational Analysis”. The course is designed for FIU analysts, financial analysts in law enforcement agencies and staff members working in financial intelligence departments of private banks. It is currently available in English and Spanish and offered for free to all public institutions on the [Basel Institute's e-learning CAMPUS](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ffree-elearning-courses).","2016-10-01","e-learning-course-on-operational-analysis-now-online-471","E-learning course on “Operational Analysis” now online",[],[112],[232],[],471,[117],[232],[],[],[95],[],"2022-05-26T22:58:42.000Z","2026-05-29T22:22:10.000Z",[],"\u002Fresources\u002Fnews\u002Fe-learning-course-on-operational-analysis-now-online-471",{"left":298,"top":298,"width":299,"height":299,"rotate":298,"vFlip":300,"hFlip":300,"body":301},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>",1780676520127]