[{"data":1,"prerenderedAt":228},["ShallowReactive",2],{"news-streamlining-the-risk-based-approach-to-anti-money-laundering-compliance-2895":3,"news-streamlining-the-risk-based-approach-to-anti-money-laundering-compliance-2895-similar":37,"i-heroicons:arrow-left-20-solid":223},[4],{"id":5,"status":6,"date_created":7,"date_updated":8,"title":9,"type":10,"body":11,"date":12,"topic":13,"slug":15,"activity":16,"nid":17,"topics":18,"activities":19,"programme":8,"area":8,"websites":8,"language":20,"image":21,"translation_of":8,"countries":31,"tags":32,"authors":33,"images":34,"translations":35,"content":36},10623,"published","2026-06-04T21:13:52.000Z",null,"Streamlining the risk-based approach to anti-money laundering compliance","News","This feature appears in the 2025 Basel AML Index Public Edition report. [Download the full report and related resources](https:\u002F\u002Findex.baselgovernance.org\u002Fdownloads).\n\n### Key takeaways \n\nA risk-based approach has long been at the core of efforts to mitigate risks of financial crimes like money laundering and terrorist financing. But application of the approach has been uneven, often focusing too heavily on high-risk areas while paying too little attention to where risks are lower. \n\nGlobal AML\u002FCFT standards now place stronger emphasis on applying the risk-based approach _proportionately_, encouraging the use of simplified measures in lower-risk situations. \n\nMany financial institutions and authorities find it difficult to assess or provide guidance on what constitutes lower risks in specific contexts. This limits the use of simplified measures and adds to compliance burdens. \n\nThe Basel AML Index’s updated risk classification offers a more nuanced, data-driven way to identify lower-risk jurisdictions and to support the application of a proportionate risk-based approach. \n\n### Proportionality: why clarity on lower-risk jurisdictions matters\n\nThe [risk-based approach](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html) has become the backbone of efforts to prevent money laundering, terrorist financing and related financial crimes. Its logic is straightforward: understand the different levels of risk, then apply stronger or lighter controls as appropriate. \n\nYet in many jurisdictions as well as in the private sector, the risk-based approach is not used as effectively as intended. Most attention is placed on identifying _high-risk_ clients, products or jurisdictions – for example, through the FATF’s black and grey lists, international sanctions regimes or high-risk lists. By contrast, there has been much less discussion about what should count as _lower risk_. \n\nThis gap matters because lower-risk situations are where simplified measures should be used by financial institutions. If they are not, resources are not used efficiently and people or organisations can be unjustifiably [excluded from accessing financial services](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002Fguidance-financial-inclusion-aml-tf-measures.html). Yet financial institutions often hesitate to use simplified measures out of fear that they may not be accepted by supervisors, which may not have clearly articulated their own risk tolerance.\n\nThe FATF, which sets global AML\u002FCFT standards, has recognised this imbalance and the unintended consequences. [Updates to its Recommendations](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Fupdate-standards-promote-financial-conclusion-feb-2025.html) this year encourage jurisdictions not only to _consider_ allowing simplified measures for lower-risk situations but to actually _allow and encourage_ them. \n\nThe FATF has also shifted to using the word _proportionate_ instead of _commensurate_ to describe how controls should be applied. While this may sound like semantics, it does signal a stronger expectation that AML\u002FCFT measures should not be uniform or mechanistic, but carefully calibrated in a way that ensures effectiveness and reduces compliance burdens. \n\n### The missing piece: what exactly is “lower risk”? \n\nEven with this shift, many authorities and financial institutions find it difficult to decide what genuinely counts as lower risk. According to our review of several recent national risk assessments from different regions, and from discussions with public and private-sector experts, several factors contribute to this uncertainty: \n\n*   Lack of clear definitions. The [FATF distinguishes](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html) between _low risk_ or (where isolated exemptions from AML\u002FCFT measures may be possible) and _lower risk_ (where simplified measures may be appropriate). Most national risk assessments do not draw this distinction. \n*   Different approaches. Some jurisdictions use structured risk scales in their national risk assessments. [Malaysia’s](https:\u002F\u002Famlcft.bnm.gov.my\u002Fpublications) national risk assessment, for example, uses a four-band model: high, medium-high, medium and low. Others, such as that of the [U.S.](https:\u002F\u002Fhome.treasury.gov\u002Fnews\u002Fpress-releases\u002Fjy2080), describe risks in narrative form without assigning categories. \n*   Unhelpful shortcuts. Jurisdiction risk models sometimes rely mainly on sanctions lists or lists of offshore centres, which offer a limited picture of financial crime risk. \n\n### Why clearer lower-risk categories support better outcomes \n\nWhen lower-risk jurisdictions and other situations are clearly identified, the benefits are significant: \n\n*   Better resource allocation and reduced compliance burdens. Staff and systems can be better directed towards higher-risk areas instead of being spread thinly. \n*   Improved quality of suspicious activity reports. Financial intelligence units often complain of defensive reporting, i.e. reporting entities submitting large numbers of suspicious activity reports mainly to protect themselves from possible criticism, rather than because the activity is genuinely suspicious. Specifically allowing simplified measures in lower-risk situations would help to reduce this. \n*   Less de-risking. When risk is assessed more accurately, financial institutions are less likely to withdraw services from whole countries or sectors based on broad assumptions. \n*   Public authorities can also distinguish between jurisdictions or regions requiring intense scrutiny in terms of cross-border financial crime risks and those where less close attention is justified. \n\nTo achieve these outcomes, financial institutions need a clear internal framework and risk assessment methodologies, as well as reliable data sources, on which to base their decisions.\n\n### How the Basel AML Index’s updated classification helps \n\nThe [Expert Edition](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) of the Basel AML Index has long provided an independent, data-driven assessment of money laundering and related financial crime risks across jurisdictions. \n\nPreviously it used three fixed risk bands: low, medium and high. This straightforward approach offers stability and simplicity, but may no longer capture the granularity needed by financial institutions and policymakers, especially where the rating drives due diligence or monitoring processes. \n\nFollowing our annual expert review meeting (see page 12), the Expert Edition will now use Jenks natural breaks, a statistical method that groups jurisdictions according to natural patterns in the data rather than fixed cut-off points. This results in the following categories: \n\n*   Lower risk: \u003C 4.70 \n*   Medium risk: 4.70–6.08 \n*   Higher risk: > 6.08 \n\nThe categories have also been renamed “lower”, “medium” and “higher” to emphasise that risk is relative. This new approach produces a clearer spread across categories and helps users see which jurisdictions fall meaningfully below the global risk pattern. \n\nThe purpose is not to label any jurisdiction as “safe” or “unsafe” but to offer a practical tool that supports geographic risk assessments and the application of proportionate measures. The Index’s underlying data remain available to subscribers. Users can then consider specific indicators relevant to their company’s risk appetite.","2025-12-05",[14],"","streamlining-the-risk-based-approach-to-anti-money-laundering-compliance-2895",[14],2895,[],[],"English",{"id":22,"storage":23,"filename_disk":24,"filename_download":25,"title":9,"type":26,"created_on":7,"modified_on":7,"charset":8,"filesize":27,"width":28,"height":29,"duration":8,"embed":8,"description":8,"location":8,"tags":8,"metadata":30,"focal_point_x":8,"focal_point_y":8,"tus_id":8,"tus_data":8,"uploaded_on":7},"d17b33b4-0aa3-4940-a5f9-1951e0e60f43","local","d17b33b4-0aa3-4940-a5f9-1951e0e60f43.webp","tmp.webp","image\u002Fwebp",7134,800,450,{},[],[],[],[],[],[],[38,65,98,122,152,176,201],{"id":39,"body":40,"status":6,"type":41,"date":42,"slug":43,"title":9,"image":44,"countries":45,"topic":8,"activity":8,"tags":46,"nid":8,"topics":47,"activities":49,"authors":51,"images":53,"websites":54,"area":55,"programme":57,"language":20,"translations":59,"translation_of":8,"user_created":60,"date_created":61,"user_updated":60,"date_updated":62,"content":63,"link":64},10589,"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\u003Cul>\n\t\u003Cli>\u003Cstrong>A risk-based approach has long been at the core of efforts to mitigate risks of financial crimes \u003C\u002Fstrong>like money laundering and terrorist financing. But application of the approach has been uneven, often focusing too heavily on high-risk areas while paying too little attention to where risks are lower. \u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>Global AML\u002FCFT standards now place stronger emphasis on applying the risk-based approach \u003C\u002Fstrong>\u003Cstrong>\u003Cem>proportionately\u003C\u002Fem>\u003C\u002Fstrong>, encouraging the use of simplified measures in lower-risk situations. \u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>Many financial institutions and authorities find it difficult to assess or provide guidance on what constitutes lower risks \u003C\u002Fstrong>in specific contexts. This limits the use of simplified measures and adds to compliance burdens. \u003C\u002Fli>\n\t\u003Cli>\u003Cstrong>The Basel AML Index’s updated risk classification offers a more nuanced, data-driven way \u003C\u002Fstrong>to identify lower-risk jurisdictions and to support the application of a proportionate risk-based approach. \u003C\u002Fli>\n\u003C\u002Ful>\n\u003C\u002Fblockquote>\n\n\n### Proportionality: why clarity on lower-risk jurisdictions matters\n\nThe \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html\">risk-based approach\u003C\u002Fa> has become the backbone of efforts to prevent money laundering, terrorist financing and related financial crimes. Its logic is straightforward: understand the different levels of risk, then apply stronger or lighter controls as appropriate.\n\nYet in many jurisdictions as well as in the private sector, the risk-based approach is not used as effectively as intended. Most attention is placed on identifying \u003Cem>high-risk \u003C\u002Fem>clients, products or jurisdictions – for example, through the FATF’s black and grey lists, international sanctions regimes or high-risk lists. By contrast, there has been much less discussion about what should count as \u003Cem>lower risk\u003C\u002Fem>.\n\nThis gap matters because lower-risk situations are where simplified measures should be used by financial institutions. If they are not, resources are not used efficiently and people or organisations can be unjustifiably \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002Fguidance-financial-inclusion-aml-tf-measures.html\">excluded from accessing financial services\u003C\u002Fa>. Yet financial institutions often hesitate to use simplified measures out of fear that they may not be accepted by supervisors, which may not have clearly articulated their own risk tolerance.\n\nThe FATF, which sets global AML\u002FCFT standards, has recognised this imbalance and the unintended consequences. \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Fupdate-standards-promote-financial-conclusion-feb-2025.html\">Updates to its Recommendations\u003C\u002Fa> this year encourage jurisdictions not only to \u003Cem>consider \u003C\u002Fem>allowing simplified measures for lower-risk situations but to actually \u003Cem>allow and encourage \u003C\u002Fem>them.\n\nThe FATF has also shifted to using the word \u003Cem>proportionate \u003C\u002Fem>instead of \u003Cem>commensurate \u003C\u002Fem>to describe how controls should be applied. While this may sound like semantics, it does signal a stronger expectation that AML\u002FCFT measures should not be uniform or mechanistic, but carefully calibrated in a way that ensures effectiveness and reduces compliance burdens.\n\n### The missing piece: what exactly is “lower risk”?\n\nEven with this shift, many authorities and financial institutions find it difficult to decide what genuinely counts as lower risk. According to our review of several recent national risk assessments from different regions, and from discussions with public and private-sector experts, several factors contribute to this uncertainty:\n\n- \u003Cstrong>Lack of clear definitions\u003C\u002Fstrong>. The \u003Ca href=\"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Ffatf-recommendations.html\">FATF distinguishes\u003C\u002Fa> between \u003Cem>low risk \u003C\u002Fem>or (where isolated exemptions from AML\u002FCFT measures may be possible) and \u003Cem>lower risk \u003C\u002Fem>(where simplified measures may be appropriate). Most national risk assessments do not draw this distinction.\n- \u003Cstrong>Different approaches\u003C\u002Fstrong>. Some jurisdictions use structured risk scales in their national risk assessments. \u003Ca href=\"https:\u002F\u002Famlcft.bnm.gov.my\u002Fpublications\">Malaysia’s\u003C\u002Fa> national risk assessment, for example, uses a four-band model: high, medium-high, medium and low. Others, such as that of the \u003Ca href=\"https:\u002F\u002Fhome.treasury.gov\u002Fnews\u002Fpress-releases\u002Fjy2080\">U.S.\u003C\u002Fa>, describe risks in narrative form without assigning categories. \n- \u003Cstrong>Unhelpful shortcuts\u003C\u002Fstrong>. Jurisdiction risk models sometimes rely mainly on sanctions lists or lists of offshore centres, which offer a limited picture of financial crime risk.\n\n### Why clearer lower-risk categories support better outcomes\n\nWhen lower-risk jurisdictions and other situations are clearly identified, the benefits are significant:\n\n- \u003Cstrong>Better resource allocation and reduced compliance burdens\u003C\u002Fstrong>. Staff and systems can be better directed towards higher-risk areas instead of being spread thinly.\n- \u003Cstrong>Improved quality of suspicious activity reports\u003C\u002Fstrong>. Financial intelligence units often complain of defensive reporting, i.e. reporting entities submitting large numbers of suspicious activity reports mainly to protect themselves from possible criticism, rather than because the activity is genuinely suspicious. Specifically allowing simplified measures in lower-risk situations would help to reduce this.\n- \u003Cstrong>Less de-risking\u003C\u002Fstrong>. When risk is assessed more accurately, financial institutions are less likely to withdraw services from whole countries or sectors based on broad assumptions.\n- \u003Cstrong>Public authorities \u003C\u002Fstrong>can also distinguish between jurisdictions or regions requiring intense scrutiny in terms of cross-border financial crime risks and those where less close attention is justified.\n\nTo achieve these outcomes, financial institutions need a clear internal framework and risk assessment methodologies, as well as reliable data sources, on which to base their decisions.\n\n### How the Basel AML Index’s updated classification helps\n\nThe \u003Ca href=\"https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition\">Expert Edition\u003C\u002Fa> of the Basel AML Index has long provided an independent, data-driven assessment of money laundering and related financial crime risks across jurisdictions.\n\nPreviously it used three fixed risk bands: low, medium and high. This straightforward approach offers stability and simplicity, but may no longer capture the granularity needed by financial institutions and policymakers, especially where the rating drives due diligence or monitoring processes.\n\nFollowing our annual expert review meeting (see page 12), the Expert Edition will now use \u003Cstrong>Jenks natural breaks\u003C\u002Fstrong>, a statistical method that groups jurisdictions according to natural patterns in the data rather than fixed cut-off points. This results in the following categories:\n\n- \u003Cstrong>Lower risk\u003C\u002Fstrong>: < 4.70\n- \u003Cstrong>Medium ris\u003C\u002Fstrong>k: 4.70–6.08\n- \u003Cstrong>Higher risk\u003C\u002Fstrong>: > 6.08\n\n![](https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F9b974fd1-47e9-49f8-9d2c-9f2ec25bd99c)\n\nThe categories have also been renamed “lower”, “medium” and “higher” to emphasise that risk is relative. This new approach produces a clearer spread across categories and helps users see which jurisdictions fall meaningfully below the global risk pattern.\n\nThe purpose is not to label any jurisdiction as “safe” or “unsafe” but to offer a practical tool that supports geographic risk assessments and the application of proportionate measures. The Index’s underlying data remain available to subscribers. Users can then consider specific indicators relevant to their company’s risk appetite.\n","Blog","2025-12-08","streamlining-the-risk-based-approach-to-anti-money-laundering-compliance","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd0c794ab-f975-4521-9333-579c5d947048?width=1000&height=650&format=webp&quality=80",[],[],[48],"Anti-Money Laundering",[50],"Basel AML Index",[52],1364,[],[50],[56],"Asset Recovery & Enforcement",[58],"International Centre for Asset Recovery",[],"545a204d-e41b-4882-afda-481ecf3fd971","2025-12-05T11:16:34.000Z","2025-12-08T07:09:33.000Z",[],"\u002Fresources\u002Fnews\u002Fstreamlining-the-risk-based-approach-to-anti-money-laundering-compliance",{"id":66,"body":67,"status":6,"type":41,"date":68,"slug":69,"title":70,"image":71,"countries":72,"topic":73,"activity":76,"tags":78,"nid":83,"topics":84,"activities":85,"authors":86,"images":88,"websites":89,"area":8,"programme":8,"language":8,"translations":91,"translation_of":8,"user_created":92,"date_created":93,"user_updated":94,"date_updated":95,"content":96,"link":97},9749,"Governments are already contemplating life after lockdown and are keen to permit as many businesses as possible to resume operations, ramp up global trade once more, and to galvanise their economies as best they can - even as forecasts about global recession get bleaker by the day.\n\nAs economic activity resumes, what will be the effects of the pandemic on the health and well-being of corporate integrity standards and anti-corruption compliance? What support will companies need or want in the post-covid economic reality? \n\nDoes Horrid History Help?\n-------------------------\n\nLooking forward makes it tempting for policy makers to look back to similar periods of economic misery such as the fallout following the Spanish Flu, the Great Depression, or the long shadow of the economic downturn after the financial crisis in 2008. Whatever these new or re-cycled economic recovery programmes entail, there are bound to be implications for anti-corruption compliance. Laws introducing new compliance standards followed the 2008 financial crisis, but the changes experienced by companies in the last 10 years or so that have influenced anti-corruption compliance are profound and exceed the scope of the policy making that has followed these historical examples.\n\nThese changes were not only the result of new laws around the globe criminalising corporate bribery inspired by the [OECD Bribery Convention](https:\u002F\u002Fwww.oecd.org\u002Fcorruption-integrity\u002Freports\u002Fconvention-combating-bribery-foreign-public-officials-international-business-transactions-aci.html) and the ensuing explosion of interest in anti-corruption compliance. They were also more comprehensive and included:\n\n*   digital developments in all aspects of business conduct, such as interacting with customers, suppliers and other third parties;\n*   broader questions of the company’s role in society;\n*   corporate governance;\n*   behavioural science.\n\nThese are just some of the transformations that have influenced anti-corruption compliance, ethics and the notion of acting with integrity over the last decade.\n\nDefault positions\n-----------------\n\nSome of these developments might be ditched, diluted or extended in the coming years, with implications for corporate standards on ethics and integrity. It’s not likely to be all bad news. It may be a rather mixed bag of opportunities and potential pitfalls and backtracking. Here are some thoughts on some possible scenarios from that mixed bag:\n\n### The law will remain the law\n\nIf it turns out that an organisation paid bribes, perpetrated fraud or tried to shore up its finances through improper practices allegedly as a result of the hardships caused by the pandemic, covid-19 will not provide a justification. Enforcement of laws addressing corruption and other forms of corporate crime will continue. Companies should not therefore neglect their anti-corruption implementation efforts. It might in fact be a time to consider more collaborative approaches like Collective Action – see below.\n\nProsecution authorities might be keen to get back to work, but some governments may inflict financial cuts that could affect the capacity of law enforcement to pursue investigations. Government cuts to stymie effective enforcement or weak political will to support anti-corruption laws are nothing new, as [OECD reviews on enforcement](http:\u002F\u002Fwww.oecd.org\u002Fcorruption\u002FFighting-the-crime-of-foreign-bribery.pdf) of anti-bribery laws indicate, but may be more evident in a post-covid world. Increased corporate pressure on home governments to support efforts to re-establish business in foreign markets could see backtracking by some governments when it comes to pursuing corporate corruption cases.\n\n### Survivors due to sustainable principles\n\nCorporate leaders who are genuinely convinced that integrity in business is essential to success are well placed to weather the effects of the economic downturn and get ahead in the post-covid economic environment. This is because such companies are more likely to have a culture that welcomes employees “speaking up” and actively listens when they do. Being open to receiving new ideas and engaging with employees to find solutions and suggestions encourages innovation.\n\nIn other words, companies that can adapt, are agile and are known to have ethical and sustainable approaches to business, including strong anti-corruption compliance principles, have a competitive advantage. They may even have undergone similar challenges in the past and learned from their experiences when developing enhancements to their ethics and compliance programme.\n\nRobust principles aren’t always enough to keep a company alive. Some industry sectors are more vulnerable than others, and companies with financial or other problems might also struggle however good their compliance programme is. Flexibility and continuity planning based on a robust [business continuity plan](https:\u002F\u002Fwww.baselgovernance.org\u002Fblog\u002Fbroken-beamers-and-more-shining-light-business-continuity-plans-and-compliance) that envisages a wide variety of serious risk scenarios may also give some companies the edge to bounce back more quickly than their competitors.\n\nFrom an anti-corruption perspective, companies that have well-designed and mature compliance programmes are potential mentors for their supply chains and business partners: they represent the good examples and offer inspiration to others. They can help others to meet the same high standards and create a level playing field by sharing and collaborating in Collective Action.\n\n### More state-owned companies\n\nAs governments promise ever larger sums of money and rescue packages to shore up their economies, there will be a surge in state support and bail-outs of some industries. This will lead to an increase in government influence in company ownership. The high levels of corruption risks in SOEs are well documented - see the OECD’s international standards [here](http:\u002F\u002Fwww.oecd.org\u002Fcorporate\u002FOECD-Guidelines-Anti-Corruption-Integrity-State-Owned-Enterprises.htm) and [here](http:\u002F\u002Fwww.oecd.org\u002Fcorporate\u002Fstate-owned-enterprises-and-corruption-9789264303058-en.htm).  Increased due diligence and a critical eye on governance will be crucial for any organisation entering into business with an SOE. This is essential in any case to properly identify and mitigate bribery risks, but especially important with new SOEs that emerge from the covid-19 crisis. Message to CEOs: don’t assume that an SOE that was previously privately held still has the same ethical standards in government hands – you may be in for a rude and costly awakening.     \n\n### SMEs will need support to attract investment and enter new markets\n\nThere can be little doubt that many micro or small and medium-sized enterprises (SMEs) will not survive either the lockdown or the resulting economic meltdown.  SMEs that do manage to stay in business may not have anti-corruption compliance at the top of their “to do” lists, but business survival mode should not be at the expense of good practices.\n\nIn any case, smart SMEs can use their compliance and anti-corruption credentials to make themselves more attractive to investors, enter into business partnerships and develop their capacity to enter new markets. Schemes like the UK’s [Business Integrity Initiative](https:\u002F\u002Fwww.baselgovernance.org\u002Fcompliance\u002Fsme-guidance-services) are designed to support SMEs do exactly that.\n\n### Increased vertical integration\n\nThe pandemic lockdowns soon revealed weaknesses in supply chains and reliance on a single source for essential components and products. Governments, citizens and some companies were taken aback by the deleterious knock-on effects of having outsourced production to suppliers that had to cease production due to the pandemic. This led to unethical behaviour in some cases – including accusations of “piracy” – and possibly involved bribery in others. Substantial increases in cargo costs as shipping options diminished have had severe consequences for many companies around the globe.\n\nAlready before covid-19, large companies were increasingly aware of such dilemmas and choke points. So they may well now speed up decisions to own more - or all - of their supply chains to avoid such risks in future. For integrity and anti-corruption compliance this could have various implications:\n\n*   Current anti-corruption laws and compliance standards make companies responsible for third parties that offer, pay or promise improper advantages to government officials. Having a coherent and comprehensive anti-corruption compliance management system implemented throughout an integrated chain of companies would be a dream come true for a chief compliance officer. Alas, achieving a homogenous, fully implemented set of standards is likely to be as challenging as ever. Streamlining of ownership won’t remove all the factors that determine bribery risks  - such as the diversity of the supply chain or its sub-sectors, different business models and the locations where business is conducted.\n*   The reputation risks in vertically integrated structures could be affected in both directions. On the one hand, the company will have more reputation to lose if a scandal breaks, and so might be more motivated to protect it with a decent compliance programme. On the other hand, the capacity to cover it up and manage the disassociation process may be greater in a complex structure.    \n*   The immense economic power that these vertical structures are likely to wield could raise corruption risks. This could arise through the leverage that such conglomerates can exert when it comes to local prosperity and employment, enabling them to demand special conditions from local and national governments. These could relate to financial advantages such as tax privileges, or preferential terms for permits or licences that will induce the conglomerate to keep operating in certain cities or regions. Examples of such behaviours abound in countries where multinationals have already paved the way with such requests. To expect highly powerful conglomerates to act with impeccable ethical standards at all times and throughout their operations would be naïve. Good governance, robust anti-bribery laws and effectively implemented anti-corruption compliance standards are therefore essential to hold such organisations to account.  \n*   Antitrust issues seem to have been less of a concern to competition authorities compared to horizontal risks - at least so far - but this may change if vertical integration becomes more common and hinders competition.\n\n### Special treatment for strategic industries?\n\nPolitical considerations about what is a key or strategic industry post-covid-19 might change in response to lessons learned from weaknesses in public health systems, supply chains and procuring essential goods. Experience shows that strategic industries often enjoy a proximity to governments that can be unhealthy when it comes to transparency, bribery risks and competition. The use of lobbyists by strategic industries can also raise additional challenges. Due diligence, robust procedures and good advice on how to handle potential risks will be invaluable.\n\nA perfect storm is best weathered together\n------------------------------------------\n\nIt almost goes without saying that increased vertical integration with an SOE at the top of the chain in a newly designated strategic sector would be the perfect anti-corruption compliance storm. It may or may not be a realistic scenario. But before compliance goes under and is drowned in such a tempest, there are opportunities for anti-corruption compliance in whatever the new economic reality turns out to be.\n\nOne such opportunity is [Collective Action](https:\u002F\u002Fwww.baselgovernance.org\u002Fcollective-action). In an economic tight spot, the need for cost-effective solutions to compliance issues is more pressing than ever. Anti-corruption Collective Action not only between the private sector and governments, but also between private sector actors themselves, can offer opportunities to address issues of common interest in a cost-effective and pragmatic way.\n\nObvious issues that are best tackled together could be identifying and eliminating new risks from new ways of working, or sharing ideas on the best training practices for a weakened supply chain. For examples and advice on this area, the Basel Institute hosts the [B20 Collective Action Hub](https:\u002F\u002Fwww.baselgovernance.org\u002Fnode\u002F1095) and offers free advice on anti-corruption Collective Action.\n\nAfter the storm\n---------------\n\nThe covid-19 pandemic has destroyed lives and livelihoods around the world, and will continue to do so in the future. Yet companies can also take the post-covid world as an opportunity not just to start operating at full power once more but to reconsider how they do business and how their anti-corruption and compliance programmes fit into this new world order. Establishing a strong, ethically based culture to develop business and enter new markets will be an investment worth making.\n\nThe Basel Institute has worked with companies and other organisations of all sizes, sectors and from around the world for almost 20 years to help [prevent or weather compliance and corruption crise](https:\u002F\u002Fwww.baselgovernance.org\u002Fcompliance)s. We know how hard it is for organisations to be under immense pressure, juggling multiple issues while working to stay in business and regain customers in the face of fierce competition. And we know that compliance officers are going to have a challenging time keeping their company’s integrity and anti-corruption compliance steady against the wind and waves of the post-covid world. Whatever the future holds – and we’re still being told that the only certainty is uncertainty – the need for good compliance officers with pragmatic and solid approaches will remain.\n\nContact our Head of Compliance, Corporate Governance and Collective Action [Gemma Aiolfi](https:\u002F\u002Fwww.baselgovernance.org\u002Fabout\u002Fpeople\u002Fgemma-aiolfi) if you feel like you’re cast out at sea and would like some advice on compliance needs and opportunities in the post-covid world.\n\n[Download a PDF of this article](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-04\u002Fcompliace-post-covid.pdf). Photo by [Clément Falize](https:\u002F\u002Funsplash.com\u002F@centelm?utm_source=unsplash&utm_medium=referral&utm_content=creditCopyText).","2020-04-14","here-today-and-gone-tomorrow-integrity-and-anti-corruption-in-the-private-sector-post-covid-19-1566","Here today and gone tomorrow? Integrity and anti-corruption in the private sector post covid-19","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F35acc94a-f4f1-4b3d-b348-6c4d5b7fbdd3?width=1000&height=650&format=webp&quality=80",[],[74,75],"Collective Action","Private Sector",[77],"Insights",[79],{"tags_id":80},{"id":81,"name":82},1381,"Health",1566,[74,75],[77],[87],1237,[],[90,74],"Main page",[],"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","2022-05-26T22:55:09.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-04-27T21:02:02.000Z",[],"\u002Fresources\u002Fnews\u002Fhere-today-and-gone-tomorrow-integrity-and-anti-corruption-in-the-private-sector-post-covid-19-1566",{"id":99,"body":100,"status":6,"type":10,"date":101,"slug":102,"title":103,"image":104,"countries":105,"topic":106,"activity":107,"tags":109,"nid":110,"topics":111,"activities":112,"authors":113,"images":114,"websites":115,"area":8,"programme":8,"language":8,"translations":116,"translation_of":8,"user_created":92,"date_created":117,"user_updated":118,"date_updated":119,"content":120,"link":121},10255,"Professor Mark Pieth, Chairman of the Independent Governance Committee of FIFA, gave this address at the 62nd FIFA Congress 2012. \n\n[Download the presentation](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-01\u002F62nd_fifa_congress_2012.pdf) (PDF).\n\nMr President, Ladies and Gentlemen, \n\nOn behalf of the Independent Governance Committee (IGC) and its members I would like to thank you for this opportunity to present our findings. Allow me first, though, to congratulate you to the decision to engage in this major reform process.\n\nI. The challenges\n-----------------\n\nSome of you may ask, why this far reaching reform process is necessary, and probably the perceptions of FIFA’s current situation will diverge. However, I assume there is a common understanding that FIFA has evolved from a mere game regulator and organizer to a commercially extremely powerful entity. And yet, its structures have remained simple, basically those of an association according to Swiss law. It is an experience most enterprises have gone through: economic success and minimal governance structures invite risk of abuse. Clearly, a Sports Governing Body of the significance of FIFA needs a modern Governance structure. What is more, you are not a supervised entity, you have to govern yourself. That is why it is so crucial that you recognize your responsibility to regulate yourself (self-regulation).\n\nII. The reform process\n----------------------\n\nNow, you have been informed about the steps of this reform process. You have heard about the very useful and constructive work done by the Task Forces, leading to suggestions to amend the statutes (I am referring to the Annexes C. and E. of your Congress package). Our own role has been that of an independent oversight body. It is crucial, though, to understand that the IGC is made up half of professional governance experts and half of members of the football world, representing different types of stakeholders. For me it has been a very comforting experience that we in the IGC came out, at the end of intensive discussions, with results adopted by unanimity. And, what is more, they are very close to what the Task Forces, made up of insiders, are proposing to you. Let me highlight the key Recommendations relating to the two stages of this reforms: first, the suggestions for now, the Congress 2012, and then the issues for further consideration and decision in 2013.\n\nIII. The reform of the internal justice system\n----------------------------------------------\n\nToday, you are asked to upgrade FIFA’s Internal Justice System. The Task Force “Ethics Committee” has rightly placed emphasis on the separation of powers, and this in two ways:\n\n*   Investigation and adjudication need to be placed in different hands.\n*   Furthermore, the Investigatory Chamber decides independently from FIFA’s administration whether to open an investigation.\n\nNext, the Chairs of the Investigatory and the Adjudicatory Chamber of the Ethics Committee need to be independent experienced professionals of a high standing. We have proposed a series of names to the ExCo to choose from and this point will be addressed by the President under agenda item 13. Trust me, that we have found the best possible names available worldwide. They will lend your first stage of reform the necessary credibility.\n\nFinally, it is essential that FIFA officials standing for election or re-election are – in the same way as this is established practice, both in the corporate world and in international organizations – subjected to an integrity check. “Fit and proper conduct” or “due diligence” are standard requirements of leadership in the public and the private sector. It is high time that criteria are applied also to the officials of Sports Governing Bodies. There is nothing peculiar in this, rather integrity checks have become a standard discipline, following technical rules.\n\nIV. Audit Committee and integrity check\n---------------------------------------\n\nStill within the first stage is the upgrade of FIFA’s financial and compliance oversight:\n\nThe Chairman of the Audit Committee needs to be in the same way independent. Furthermore, you need someone with a very specific professional background, with the experience of years in a senior position in multinational enterprises. Again, the IGC has proposed a list of candidates to FIFA and there is a concrete person fitting perfectly these requirements. This point will be addressed by the President under agenda item 13.\n\nThe “Audit and Compliance Committee”, as it is now called, will under the new rules have three major tasks: \n\n*   financial oversight\n*   compliance oversight\n*   the decision on remunerations of senior officials\n\nV. Consultation phase for 2013\n------------------------------\n\nTurning now to your second phase of reforms:\n\nIt rapidly became obvious that there are several further fundamental issues that need to be considered, but in a democratic environment they need time for discussion. I would like to invite you to consider in particular the following Recommendations for 2013. I am merely picking some of the points made and I would like to refer to our own report (available on the web) as well as the draft statutes in annex E. of your Congress Materials.\n\n*   I am sure you will want to discuss our proposal to include an independent component within the ExCo, this is current practice in business and there are several ways of doing so. This is an item addressing the requirement of accountability.\n*   You will equally want to study our suggestions on new ways to determine the remuneration of senior officials and staff and to make the information available to Congress (addressing the requirement of transparency).\n*   We have made several Recommendations upgrading the system of financial reporting as well as streamlining the procedures on development programs. Here we are proposing unified strategies and procedures within a newly created Development Committee.\n*   There are several standard Recommendations on creating an adequate compliance program and a conflict of interest policy. This implies introducing a whistleblower hotline, open to the general public. Again, we are here in the sphere of established business principles.\n*   The report contains further details on the election of senior officials as well as − on hosting and on marketing.\n\nNow, I am not going to go through the entire list. Please read our report (handed out to you and available on the web) and please consult the reform proposals by the Task Forces. I will merely encourage you to address the key issues and to abstain from “cherry picking”. Please do not just pick the easy decisions out of a menu that has an overall logic.\n\nVI. Conclusion\n--------------\n\nI would like to conclude my presentation by inviting you to make use of this opportunity. It will not repeat itself easily: do something courageous and generations footballers, fans and further stakeholders will remember you for it!","2012-05-25","fifa-reform-address-by-the-chairman-of-the-independent-governance-committee-360","FIFA reform: address by the Chairman of the Independent Governance Committee","\u002Fpics\u002Fimg-placeholder.png",[],[75],[108],"Presentations",[],360,[75],[108],[],[],[90],[],"2022-05-26T22:59:36.000Z","b0662e2a-864d-4888-a1b7-4342b7570b30","2025-08-31T23:14:59.000Z",[],"\u002Fresources\u002Fnews\u002Ffifa-reform-address-by-the-chairman-of-the-independent-governance-committee-360",{"id":123,"body":124,"status":6,"type":41,"date":125,"slug":126,"title":127,"image":128,"countries":129,"topic":130,"activity":131,"tags":132,"nid":141,"topics":142,"activities":143,"authors":144,"images":146,"websites":147,"area":8,"programme":8,"language":8,"translations":148,"translation_of":8,"user_created":92,"date_created":149,"user_updated":118,"date_updated":119,"content":150,"link":151},9803,"Child labour. Forced evictions. Confiscation of migrant-worker identity documents. Crackdowns by security forces on peaceful assemblies. Serious illness resulting from corporate pollution.\n\nThese are all examples of human rights abuses that might arise in business operations or supply chains, knowingly or unknowingly, in a company’s home country or abroad.\n\n### What are human rights and who is obliged to respect them?\n\nHuman rights are the universal rights and freedoms inherent to all individuals established through a range of international treaties. States have the primary duty to respect human rights and prevent human rights abuses on their territories.\n\nYet businesses also have a corporate responsibility to respect internationally recognised human rights. The [United Nations Guiding Principles on Human Rights](https:\u002F\u002Fwww.ohchr.org\u002Fdocuments\u002Fpublications\u002FGuidingprinciplesBusinesshr_eN.pdf) set out the respective roles of States and companies to prevent, address and remedy human rights abuses committed in business operations. Since the Guidelines were endorsed in 2011, society’s expectations that businesses are held to account for their role in respecting human rights have risen.\n\n### Human rights in corporate compliance\n\nHuman rights are progressively entering the compliance sphere. Many (if not all) international human rights have corresponding civil or criminal infractions under national laws, though traditionally there has been an enforcement gap. An increasing awareness of human rights has contributed to a rise in efforts to enforce them at the national level.\n\nAdditional human-rights specific legislation and standards pertaining to businesses are being adopted at the national and multilateral levels. For example:\n\n*   The United Kingdom and the Netherlands require certain companies to conduct due diligence, take other preventive measures, and report on their efforts to ensure there is no slavery, trafficking, or child labour in their supply chain.\n*   The [EU Non-Financial Reporting Directive](https:\u002F\u002Fec.europa.eu\u002Finfo\u002Fbusiness-economy-euro\u002Fcompany-reporting-and-auditing\u002Fcompany-reporting\u002Fnon-financial-reporting_en), which came into effect in 2018, places a requirement on large companies to disclose the human rights impacts of their business operations and efforts to mitigate them.\n\n### Integrating human rights into anti-corruption compliance?\n\nCountries in which human rights abuses regularly occur often present high risks of corruption, and corruption can itself be a cause of human rights abuses. Companies can therefore integrate human rights issues into their compliance system by applying their existing anti-corruption mechanisms, such as risk assessments.\n\nSuch an approach has the potential to enhance both the effectiveness and the efficiency of the company's overall efforts to do business with integrity.\n\n_An adapted version of this article appeared in German in the September 2019 edition of_ _[Recht relevant – für Compliance Officers](https:\u002F\u002Fwww.schulthess.com\u002Fverlag\u002Fzeitschriften\u002Frecht-relevant), published by Schulthess._\n\nPhoto by [Safal Karki](https:\u002F\u002Funsplash.com\u002F@safal_karki) on  Unsplash","2019-10-07","streamlining-human-rights-and-anti-corruption-compliance-1009","Streamlining human rights and anti-corruption compliance","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F8ef75abd-542c-475d-ad80-8fa5cd95a6e8?width=1000&height=650&format=webp&quality=80",[],[75],[77],[133,137],{"tags_id":134},{"id":135,"name":136},932,"Human rights",{"tags_id":138},{"id":139,"name":140},982,"Anti-corruption",1009,[75],[77],[145],1255,[],[90],[],"2022-05-26T22:55:54.000Z",[],"\u002Fresources\u002Fnews\u002Fstreamlining-human-rights-and-anti-corruption-compliance-1009",{"id":153,"body":154,"status":6,"type":10,"date":155,"slug":156,"title":157,"image":104,"countries":158,"topic":160,"activity":162,"tags":163,"nid":164,"topics":165,"activities":167,"authors":168,"images":169,"websites":170,"area":8,"programme":8,"language":8,"translations":171,"translation_of":8,"user_created":92,"date_created":172,"user_updated":94,"date_updated":173,"content":174,"link":175},10245,"In the context of USAID’s FOTI Timor Leste programme, ICAR has been requested to assist local counterparts (the Attorney General Office, the Central Bank and the Anti-Corruption Commission) in analyzing and identifying the different stages of investigation and adjudication of money laundering cases; identifying legislative and\u002For procedural shortcomings that hinder the investigation and adjudication of money laundering in East Timor; and recommending inter-institutional coordination mechanisms for streamlining the investigation and adjudication of such cases.","2013-08-01","support-to-east-timor-in-reviewing-its-money-laundering-investigation-processes-and-laws-525","Support to East Timor in reviewing its money laundering investigation processes and laws",[159],7762,[161],"Asset Recovery",[14],[],525,[166],"Asset Recovery and Enforcement",[],[],[],[90],[],"2022-05-26T22:59:35.000Z","2026-05-29T22:22:20.000Z",[],"\u002Fresources\u002Fnews\u002Fsupport-to-east-timor-in-reviewing-its-money-laundering-investigation-processes-and-laws-525",{"id":177,"body":178,"status":6,"type":41,"date":179,"slug":180,"title":181,"image":182,"countries":183,"topic":184,"activity":185,"tags":188,"nid":189,"topics":190,"activities":191,"authors":192,"images":194,"websites":195,"area":8,"programme":8,"language":8,"translations":196,"translation_of":8,"user_created":92,"date_created":197,"user_updated":94,"date_updated":198,"content":199,"link":200},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",[],[48,161],[186,187],"Training","eLearning",[],950,[48,166],[186,187],[193],897,[],[90],[],"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":202,"body":203,"status":6,"type":10,"date":204,"slug":205,"title":206,"image":104,"countries":207,"topic":208,"activity":209,"tags":212,"nid":213,"topics":214,"activities":215,"authors":216,"images":217,"websites":218,"area":8,"programme":8,"language":8,"translations":219,"translation_of":8,"user_created":92,"date_created":117,"user_updated":94,"date_updated":220,"content":221,"link":222},10258,"Today, Friday March 30, 2012, the Independent Governance Committee (IGC) presented its [first report to the Executive Committee of FIFA](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-01\u002Ffirst_report_by_igc_to_fifa_exco.pdf).\n\nThe IGC has been overseeing FIFA\\`s reform process since its constitution in December 2011. To prepare the report, the IGC, which consists in part of renowned governance experts and in part of football insiders with the necessary insight into the specific risks of a large sports organisation, had held five days of in-person meetings over a period of three months in addition several phone conferences and to reading hundreds of pages of documents relating both to FIFA\\`s governance structures as well as to allegations of past wrongdoings.\n\nThe IGC also held hearings with the responsible FIFA officials both to get a better understanding of how the finances within the organisation are controlled and to assess whether FIFA\\`s response to past allegations of wrongdoings was sufficient.\n\n“I was really impressed with how quickly the group was able to focus on a common goal”, says Mark Pieth, Chairman of the IGC.\n\nThe presentation of the report to FIFA\\`s Executive Committee is an important step in the reform process before the report is put before Congress. The key recommendations that have been now presented to FIFA\\`s Executive Committee include:\n\n*   The IGC recommends that the remit of the Audit Committee be expanded to include the additional roles of a Compliance Committee as well as a Compensation Committee (new name: Audit & Compliance Committee). In the opinion of the IGC it is fundamental that the independent Chairs of the Nomination Committee and the Audit & Compliance Committee have a seat in the Executive Committee.\n*   The IGC believes that financial controls need to be strengthened. Furthermore, FIFA is in urgent need of streamlining its procedures on hosting of competitions, on marketing decisions and on development programs. A new Development Committee should see to it that development funding is awarded on a transparent and fair basis and follows a predefined strategy with all procedures fully documented.\n*   The ICG considers it absolutely fundamental to strengthen the Governance Structure of FIFA by insisting on transparency, accountability, professionalism and independence in key areas. It is thus fundamental that nominees for senior FIFA positions are vetted by an independent Nominations Committee, to be put in place as soon as possible, in order to ensure that candidates for the next elections fulfillthe necessary substantive criteria and ethical requirements and that the selection process is fair and transparent. (see full report for details).\n*   Regarding the past, the existing procedures are – in the opinion of the IGC and the relevant Task Force – insufficient to meet the challenges of a major global sport governing body. This has led to unsatisfactory reactions to persistent allegations. In particular, the IGC has identified a lack of proactive and systematic investigation of allegations. In some instances, allegations were insufficiently investigated and where sanctions were imposed, they are at times insufficient and clearly unconvincing. The IGC recommends that the most important proposals made by the Task Force Ethics Committee be implemented as soon as possible: especially the separation of an investigatory and an adjudicatory chamber as well as the right of the investigatory chamber to set procedures in motion _proprio motu_, i.e. the independent ability of the Ethics Committee to initiate investigations. The IGC strongly recommends that the Chairs and the Deputy Chairs of the judicial bodies be staffed as soon as possible by truly independent persons of high standing and expertise.","2012-03-30","first-report-of-igc-to-fifa039s-executive-committee-357","First report of IGC to FIFA's Executive Committee",[],[75],[210,211],"Reports","Media releases",[],357,[75],[210,211],[],[],[90],[],"2026-04-15T22:28:50.000Z",[],"\u002Fresources\u002Fnews\u002Ffirst-report-of-igc-to-fifa039s-executive-committee-357",{"left":224,"top":224,"width":225,"height":225,"rotate":224,"vFlip":226,"hFlip":226,"body":227},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>",1780676520947]