[{"data":1,"prerenderedAt":275},["ShallowReactive",2],{"news-transforming-governance-in-government-related-entities-ifctf-2018-malaysia-19":3,"news-transforming-governance-in-government-related-entities-ifctf-2018-malaysia-19-similar":39,"i-heroicons:arrow-left-20-solid":270},[4],{"id":5,"status":6,"date_created":7,"date_updated":8,"title":9,"type":10,"body":11,"date":12,"topic":13,"slug":14,"activity":15,"nid":16,"topics":17,"activities":18,"programme":19,"area":19,"websites":20,"language":19,"image":22,"translation_of":19,"countries":33,"tags":34,"authors":35,"images":36,"translations":37,"content":38},9925,"published","2022-05-26T22:57:31.000Z","2025-08-31T23:14:59.000Z","Transforming governance in government-related entities: IFCTF 2018, Malaysia","","Gemma Aiolfi, Head of Compliance, Corporate Governance and Collective Action at the Basel Institute of Governance, presented at the 10th International Conference of Financial Crime and Terrorism Financing ([IFCTF](https:\u002F\u002Fwww.aif.org.my\u002Fevent_view.aspx?eid=7e4baf00-119d-4bb8-b265-39e74ff893c1)) in Kuala Lumpur on 30 October 2018. Organised by the Asian Institute of Finance, the conference brought together about 1,000 compliance officers from Malaysian and international financial institutions.\n\nThe conference took place against a growing body of evidence emerging from the worldwide investigations into the 1Malaysia Development Berhad (1MDB) scandal. Former Malaysian Prime Minister Najib Razak has been accused of criminal offences in relation to the misuse of funds from the sovereign wealth fund. As the evidence unfolds, allegations of wrongdoing are spreading to numerous politicians and banks worldwide, with the US Department of Justice recently filing [1MDB-related charges against two ex-bankers from Goldman Sachs](https:\u002F\u002Fwww.bloomberg.com\u002Fopinion\u002Farticles\u002F2018-11-02\u002Fgoldman-sachs-left-counting-the-damage-of-1mdb-scandal). So the conference theme this year, “The rising voice of compliance – towards greater governance and transparency”, was highly appropriate.\n\nGemma Aiolfi spoke during the first plenary session, focusing on how to address government-linked companies that have been sharply criticised by the new Malaysian government as having increased corruption risks. There is a lack of transparency around government-linked companies generally, so Ms Aiolfi spoke about what financial institutions should be doing to understand the companies’ structure, ownership, business goals and reasons for transactions.\n\nThe participants also heard from the Governor of the Malaysian Central Bank, Negara Malaysia Nor Shamsiah Mohd Yunus, about the need for strong anti-money laundering controls in their operations. The Governor took the opportunity to announce a new regulation that will come into force in January 2019. This measure will require the reporting of all cash transactions above USD 5,000, half the current threshold. Her announcement was greeted with surprise and a touch of shock by the audience. \n\nIt can only be hoped that Malaysia will now start to mount investigations and cases against banks located in Malaysia that were involved in the 1MDB scandal, rather than leave it to other jurisdictions to play that role. This would certainly help further strengthen Malaysia's reputation as a country tough on financial crime.\n\nTo see the conference highlights and photos, please visit the [Asian Institute of Finance website](https:\u002F\u002Fwww.aif.org.my\u002Fevent_view.aspx?eid=7e4baf00-119d-4bb8-b265-39e74ff893c1).","2018-11-07",[10],"transforming-governance-in-government-related-entities-ifctf-2018-malaysia-19",[10],19,[],[],null,[21],"Main page",{"id":23,"storage":24,"filename_disk":25,"filename_download":26,"title":9,"type":27,"created_on":28,"modified_on":28,"charset":19,"filesize":29,"width":30,"height":31,"duration":19,"embed":19,"description":19,"location":19,"tags":19,"metadata":32,"focal_point_x":19,"focal_point_y":19,"tus_id":19,"tus_data":19,"uploaded_on":28},"ff40fb35-bd19-4638-a05b-4fe4a8851de2","local","ff40fb35-bd19-4638-a05b-4fe4a8851de2.webp","tmp.webp","image\u002Fwebp","2025-05-12T21:23:28.000Z",59086,1400,933,{},[],[],[],[],[],[],[40,63,88,116,140,171,196,219,246],{"id":41,"body":42,"status":6,"type":10,"date":43,"slug":44,"title":45,"image":46,"countries":47,"topic":48,"activity":49,"tags":50,"nid":51,"topics":52,"activities":53,"authors":54,"images":55,"websites":56,"area":19,"programme":19,"language":19,"translations":57,"translation_of":19,"user_created":58,"date_created":59,"user_updated":60,"date_updated":8,"content":61,"link":62},9930,"Gemma Aiolfi, Head of Compliance, Corporate Governance and Collective Action at the Basel Institute of Governance, will be speaking at the [10th International Conference of Financial Crime and Terrorism Financing (IFCTF) 2018](https:\u002F\u002Fwww.aif.org.my\u002Fevent_view.aspx?eid=7e4baf00-119d-4bb8-b265-39e74ff893c1). Organised by the Asian Institute of Finance, the conference will take place on 30–31 October 2018 in the Malaysian capital Kuala Lumpur. The theme this year is: _The rising voice of compliance – towards greater governance and transparency._\n\nMs. Aiolfi will participate as a panellist in the first plenary session on _Transforming governance in government-related entities: What it means to compliance in the financial services sector_.\n\nThe one-hour session will take place on Tuesday, 30 October at 10.45am. Other panellists include H.E. Vicki Treadell CMG, MVO, British High Commissioner to Malaysia and Dato' Lim Chee Wee, Partner, Dispute Resolution Division, Skrine. The session moderator, P. Gunasegaram is the former editor at The Star, The Edge and Malaysian Business.\n\nOn the afternoon of Tuesday, 30 October, Gemma Aiolfi will also take part in a dialogue on Anti-Corruption Compliance and Collective Action at a separate event organised by the [Malaysian Institute of Management](https:\u002F\u002Fwww.baselgovernance.org\u002Fnews\u002Fmalaysian-compliance-event-and-training-courses).","2018-10-23","gemma-aiolfi-at-ifctf-conference-2018-23","Gemma Aiolfi at IFCTF conference 2018","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd5c374a7-8185-4817-a52a-5172f1dff81f?width=1000&height=650&format=webp&quality=80",[],[10],[10],[],23,[],[],[],[],[21],[],"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","2022-05-26T22:57:34.000Z","b0662e2a-864d-4888-a1b7-4342b7570b30",[],"\u002Fresources\u002Fnews\u002Fgemma-aiolfi-at-ifctf-conference-2018-23",{"id":64,"body":65,"status":6,"type":66,"date":67,"slug":68,"title":69,"image":70,"countries":71,"topic":72,"activity":74,"tags":76,"nid":77,"topics":78,"activities":79,"authors":80,"images":82,"websites":83,"area":19,"programme":19,"language":19,"translations":84,"translation_of":19,"user_created":58,"date_created":85,"user_updated":60,"date_updated":8,"content":86,"link":87},9831,"The trend among organisations with well-established anti-corruption compliance programmes is to integrate these into enterprise-wide risk management frameworks and set measurable indicators to ensure that their programmes remain fit for purpose. There is growing recognition that effective compliance contributes to a healthy business model and sustainable growth.\n\nOur compliance advisory work during 2018 has supported this development by seeking to help companies to use their existing risk management processes as the basis to integrate anti-corruption compliance into wider frameworks of risk management and sustainability. We believe this will continue as human rights risk assessments and corruption risk mitigation become increasingly important.\n\nOur work in [Collective Action](\u002Fblog\u002Freflections-2018-international-centre-collective-action) supports this approach by helping companies to solve shared challenges related to bribery and raise standards of integrity across an industry or region.\n\n### Support for small businesses\n\nSmall- and medium-sized enterprises (SMEs) that do business internationally are open to the same bribery and corruption risks as their larger competitors, yet have far fewer resources to protect themselves from these risks. Our tailored, resource-sensitive guidance on anti-corruption compliance and bribery prevention helps SMEs to avoid legal and reputational risks and enjoy the competitive advantage that solid compliance systems provide.\n\nA mandate from the UK Department for International Development, awarded in late 2018 as part of the Business Integrity Initiative, will enable us to expand our support for SMEs in the coming year.\n\n### Tailored compliance training\n\nRobust compliance is based on strong communication that reinforces the corporate culture and is relevant to the employees that are being addressed. That is why a strong focus of our compliance work is on bespoke training for companies and public sector organisations.\n\nThese customised training programmes were joined in 2018 by a comprehensive training curriculum on Corporate Governance and Compliance, developed in cooperation with Nestor Advisors for Malaysian compliance practitioners and other interested individuals. Around 30 practitioners completed the modules during 2018, hosted by the Malaysian Institute on Management.\n\n### User-friendly compliance tools\n\nPractical online tools are essential to supplement efficient compliance systems.\n\nOur long-standing [Basel AML Index](\u002Fnode\u002F403), an interactive country risk assessment tool covering corruption, money laundering, financial transparency and related risks, was upgraded and transferred to a new user-friendly platform in 2018.\n\nThis is now joined by [Basel Open Intelligence](\u002Fnode\u002F556), a newly developed open-source search tool to make multilingual background checks and due diligence processes faster, easier and more thorough.\n\n2018 at a glance\n----------------\n\n### Advisory services\n\n*   [Advice and support](https:\u002F\u002Fwww.baselgovernance.org\u002Fcompliance\u002Fadvisory-services) to international companies for crisis management in relation to their anti-corruption compliance programmes.\n*   Development of legal opinions on cases of corruption and conflict of interest in collaboration with [Professor Mark Pieth](https:\u002F\u002Fwww.pieth.ch\u002F).\n\n### Compliance training \n\n*   In cooperation with Nestor Advisors, rollout of a training curriculum in [Corporate Governance and Compliance](\u002Fnews\u002Fmalaysian-compliance-event-and-training-courses) for the Malaysian Institute on Management (MIM).\n\n### Moderation and speaking events\n\n*   Presentation at the 10th International Conference of Financial Crime and Terrorism Financing ([IFCTF](https:\u002F\u002Fwww.baselgovernance.org\u002Ftransforming-governance-government-related-entities-ifctf-2018-malaysia)) in Kuala Lumpur.\n*   Panel moderation at the [Arbitration and Crime Conference](https:\u002F\u002Farbcrime.org\u002Fconference) at the University of Basel. \n*   Moderation of the C5 Anti-Corruption Conference, plus moderation of a private sector panel.\n*   Co-chairing of a high-level panel with Professor Mark Pieth at the International Anti-Corruption Conference.\n*   Participation in the ICC Young Arbitrators Conference; a meeting of Ethics and Compliance Switzerland and the EU Anti-Corruption Conference.\n\n### Looking ahead - planned activities in 2019\n\n*   Provide [guidance to SMEs on anti-corruption compliance and bribery prevention](\u002Fcompliance\u002Fsme-guidance-services) as part of the UK government’s DFID-funded Business Integrity Initiative.\n*   Launch [Basel Open Intelligence](\u002Fboi) and raise awareness in the corporate community of this new anti-corruption compliance and due diligence tool.\n\nThis text appears in the Basel Institute's [Annual Report 2018](\u002Fsites\u002Fdefault\u002Ffiles\u002F2019-07\u002FBasel%20Institute%20Annual%20Report%202018.pdf).","Blog","2019-07-21","reflections-on-2018-compliance-and-corporate-governance-956","Reflections on 2018: Compliance and corporate governance","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F43e536fe-cbe2-4969-87c3-336c42d5d46c?width=1000&height=650&format=webp&quality=80",[],[73],"Private Sector",[75],"Reports",[],956,[73],[75],[81],1270,[],[21],[],"2022-05-26T22:56:18.000Z",[],"\u002Fresources\u002Fnews\u002Freflections-on-2018-compliance-and-corporate-governance-956",{"id":89,"body":90,"status":6,"type":66,"date":91,"slug":92,"title":93,"image":94,"countries":95,"topic":97,"activity":99,"tags":103,"nid":104,"topics":105,"activities":106,"authors":107,"images":109,"websites":110,"area":19,"programme":19,"language":19,"translations":111,"translation_of":19,"user_created":58,"date_created":112,"user_updated":60,"date_updated":113,"content":114,"link":115},9529,"_What are the four biggest developments in anti-corruption Collective Action in the last years? And what are some examples of these around the world?_\n\n_Gemma Aiolfi spoke on these topics to delegates at a Members Meeting of Etik ve İtibar Derneği (TEİD) – the Turkish Ethics and Reputation Society. [TEİD](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Finitiatives-database\u002Fetik-ve-itibar-dernegi-teid-turkish-ethics-and) is an inspiring cross-sectoral Collective Action initiative that has been working tirelessly since 2010 to promote business ethics in Turkey. Read her speech below or view it on [here on YouTube](https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=Js4GWi_Csz4)._\n\n_If you have any questions about Collective Action or want more details on any of these initiatives, please don’t hesitate to browse the [B20 Collective Action Hub resource centre](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub). You can get in touch with our team via our [Helpdesk](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Fcollective-action-helpdesk), a free advice service on anti-corruption Collective Action to promote fair business._\n\nThank you for the invitation to speak at this important milestone event for the ethics and reputation society. May I congratulate you all on the commitment and engagement you all bring to addressing integrity and corruption related challenges.\n\nI’ve been asked to talk about examples of [anti-corruption Collective Action](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub) initiatives from around the world.\n\nBefore doing so I just wanted to mention four developments that are incentivising companies to engage in anti-corruption Collective Action.\n\n### 1 Revised OECD Recommendation includes Collective Action for the first time\n\nThe first is the [revised OECD Recommendation](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Foecd-recommends-anti-corruption-collective-action-its-revised-anti-bribery-recommendation) published by the member countries of the Anti-Bribery Convention at the end of 2021. Among the new measures to reinforce efforts to prevent, detect and investigate foreign bribery, Collective Action is included for the first time.  Member countries have to:\n\n_“consider fostering, facilitating, engaging, or participating in anti-bribery collective action initiatives with private and public sector representatives, as well as civil society organisations, aiming to address foreign bribery and bribe solicitation.”_\n\nThis Recommendation will be part of the country monitoring process that the 44 member countries of the OECD Convention undergo on an ongoing basis. Quite simply, this means that governments will be asked to explain what they have done to foster, facilitate, engage or participate in Collective Action. So there is an international standard that is now encouraging the public and private sectors to get active and participate in Collective Action.\n\n### 2 Collective Action becomes a key part of ESG and non-financial reporting\n\nSecondly, there is rapidly growing interest in [corporate non-financial reporting](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fnew-journal-article-anti-corruption-compliance-non-financial-reporting-and-collective-action), where companies explain how they address environmental, social and governance (ESG) issues.\n\nThe largest organisation that publishes such information is the [Global Reporting Initiative](https:\u002F\u002Fwww.globalreporting.org\u002F) or GRI. GRI’s reporting standard on anti-corruption asks companies to describe whether they participate in Collective Action to combat corruption, including:\n\n*   the company’s strategy for its Collective Action activities;\n*   a list of the initiatives in which the organisation participates;\n*   a description of the main commitments of these initiatives.\n\n### 3 Companies find synergies in human rights and anti-corruption\n\nThirdly, there’s an increasing recognition in the convergences or overlaps between how companies are addressing [human rights and corruption](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Fhuman-rights).\n\nThese topics have much in common and are linked, but they also have important differences: Using Collective Action to share knowledge and experiences is a practical approach [that some companies are already using](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fconnecting-anti-corruption-and-human-rights-agendas-challenges-and-opportunities-collective) given the new laws on human rights in order to keep up with these new developments.\n\n### 4 Governments explore ways to engage with the private sector through Collective Action\n\nFourthly, the [Network of Corruption Prevention Authorities (NCPA)](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fstopping-corruption-it-occurs-why-basel-institute-has-become-partner-network-corruption) brings together government organisations from all over the world, many of which are responsible for drafting their national anti-corruption strategies. These strategies call on the private sector to prevent corruption.\n\nThese authorities are now exchanging on their experiences and different ideas on how to engage with the private sector, including through Collective Action.\n\nThose are some of the developments in mainstreaming Collective Action. Let’s now take a look at some of the inspiring examples of Collective Action for companies.\n\nCollective Action in action – examples from around the world\n------------------------------------------------------------\n\n### Measuring the effectiveness of anti-corruption compliance\n\nA question often asked by investors and boards is: How can you measure whether an anti-corruption compliance programme is really effective?\n\nThis was a question posed by the one of the world’s largest investors – the Norwegian Sovereign Wealth fund manager – to a group of pharmaceutical companies. Together, they [formed a Collective Action initiative to agree on key performance indicators](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fmeasuring-effectiveness-anti-corruption-programmes-health-care-sector-developing-indicators) to identify what an effective anti-bribery and corruption programme means in practice.\n\nThe output was a set of [indicators for companies to report on publicly](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fmeasuring-effectiveness-anti-corruption-programmes-indicators-company-reporting). So far, two companies from the eight that participated in the Collective Action have published information about the quantitative and qualitative indicators of the effectiveness of their anti-corruption compliance programmes. This is probably the start of a discussion to identify more indicators of what is effective.  \n\nThis initiative is an example of how Collective Action can break new ground. It was the first to be inspired by an investor, and also to address a new area that is useful to companies. It may inspire other industry sectors to develop improvements to these basic indicators.\n\n### Transforming beneficial ownership transparency in extractives industries\n\nThe second example is the joint project of two major global Collective Action initiatives. [Open Ownership](https:\u002F\u002Fwww.openownership.org\u002F) and the [Extractive Industries Transparency Initiative](https:\u002F\u002Feiti.org\u002F) (EITI) are partnering to develop and deliver a new global programme called [Opening Extractives](https:\u002F\u002Fbaselgovernance.org\u002Fb20-collective-action-hub\u002Finitiatives-database\u002Fopening-extractives).\n\nOpening Extractives aims to stimulate a real transformation in beneficial ownership transparency in the extractives industry. This will involve governments, companies and civil society publicly revealing the ultimate beneficial owners of their supply chain companies, and partners of the companies that engage in mineral and mining industries.\n\nThis Collective Action could be a game changer in a sector that has long been associated with corruption risks, including kleptocracy and state capture.\n\nIt's an exciting development because it brings together two well established collective action initiatives to tackle a really complex and political issue. We’ll have to see how it develops.\n\n### Sharing compliance expertise between private firms and state-owned enterprises\n\n[Compliance without Borders](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fcompliance-without-borders-new-way-build-anti-corruption-capacity-soes) is a mentoring programme between state-owned enterprises and the private sector that was developed by the B20 and the OECD.  \n\nIt has been piloted in the last few months, and could be a great way for state-owned enterprises to benefit from experienced compliance officers in the private sector sharing their experience and expertise for free.\n\nAt the same time, the private-sector compliance officers learn about the challenges of having to implement a compliance programme in a state-owned organisation.\n\n### Developing industry-tailored anti-corruption guidance for high-risk industries\n\nThe [Natural Resource Governance Institute](https:\u002F\u002Fresourcegovernance.org\u002F) (NRGI) is a non-profit organisation that seeks to improve countries’ governance of their natural resources, with a focus on the oil and gas industry.\n\nOver a two-year period, the NRGI conducted a detailed desk review and analysis of corruption cases involving state-owned enterprises and their oil and gas corporate partners. They identified recurrent corruption issues and reviewed existing best practices in corruption prevention.\n\nThen they brought together, in a series of consultations, 15 of the largest oil companies plus state-owned enterprises and civil society stakeholders. The aim was to develop a new and tailored set of guidance that recommends measures that companies in the oil, gas and mining sectors should adopt to reduce corruption risks when partnering with state-owned enterprises.\n\nThe Guidance also recommends measures SOEs can take to strengthen their anticorruption safeguards.\n\nThe Collective Action entailed interviews with over 110 individuals and 50 companies from NGOs, companies, financial institutions, universities and a core group of 18 companies through closed-door workshops.\n\nThe guidance breaks new ground for three reasons:\n\n*   It focuses on the business interactions between companies and state-owned enterprises – not on everything. For example, it does not cover gifts and entertainment because there’s already lots of guidance on that topic.\n*   It mixes basic and ambitious measures. Some can be implemented already, while others will take longer.\n*   It prioritises the _public interest_ in the producing countries, rather than the company’s interest which is often the focus of compliance guidance. This means higher disclosure levels even if the entities are not legally obliged to do so, and stopping serious forms of corruption like kleptocracy where possible.\n\nThis guidance could provide inspiration to other countries. There are SOEs everywhere in the world and many present similar risks to this industry sector. So the Collective Action methodology that the NRGI used could be applied in other sectors, other countries and to other corruption-related challenges.","2022-02-14","four-major-developments-in-the-fight-against-corruption-through-collective-action-2174","Four major developments in the fight against corruption through Collective Action","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Faa69261a-3a1b-4870-a04d-b46de184fc83?width=1000&height=650&format=webp&quality=80",[96],7270,[98,73],"Collective Action",[100,101,102],"Events","Insights","Presentations",[],2174,[98,73],[100,101,102],[108],1174,[],[21,98],[],"2022-05-26T22:52:03.000Z","2025-08-31T23:14:40.000Z",[],"\u002Fresources\u002Fnews\u002Ffour-major-developments-in-the-fight-against-corruption-through-collective-action-2174",{"id":117,"body":118,"status":6,"type":66,"date":119,"slug":120,"title":121,"image":122,"countries":123,"topic":124,"activity":125,"tags":126,"nid":127,"topics":128,"activities":129,"authors":130,"images":132,"websites":133,"area":19,"programme":19,"language":19,"translations":134,"translation_of":19,"user_created":58,"date_created":135,"user_updated":136,"date_updated":137,"content":138,"link":139},10358,"_[Gemma Aiolfi](https:\u002F\u002Fbaselgovernance.org\u002Fabout\u002Fpeople\u002Fgemma-aiolfi) is an international expert in anti-corruption compliance and a driving force behind the development of private sector-led Collective Action. Gemma helped to establish the Basel Institute on Governance in 2003 alongside Professor Mark Pieth. She served as the organisation's Head of Compliance, Corporate Governance and Collective Action from July 2013 until October 2022, when she transitioned to the role of Senior Advisor._\n\n_In this Q&A, she gives her personal perspective on the birth and evolution of anti-corruption compliance, plus the risks and challenges that compliance officers face today._\n\n### Where and how did compliance arise?\n\nAnti-corruption compliance didn’t exist when I started my working life. Where compliance existed at all, it was mostly about regulatory health and safety standards.\n\nThe concept of compliance related to economic crime began in the banking industry with the focus on profits from illicit drugs. My early career in banking in Basel in the mid-1980s coincided with the start of globalisation and the development of self-regulation (via [self-regulatory organisations](https:\u002F\u002Fwww.finma.ch\u002Fen\u002Fauthorisation\u002Fself-regulatory-organisations-sros\u002F)) to protect investors. Meanwhile, the Bank for International Settlements was focusing on market stability so contributed to the development of compliance from a supervisory angle.\n\nInternal banking compliance was based on the concept of “self-regulation within a regulated society”. In other words, those in the industry know best how to protect against risks and just need a stable framework to do so, based on some form of principles-based regulation.\n\nAs industry deregulation and globalisation started to spread in the 1990s, a series of scandals cast doubt on whether self-regulation was enough. This ongoing cycle of scandals triggering more regulations on banks and policy debates on how to change regulatory approaches still continues today.\n\n### How was compliance different to now?\n\nVery. For a start, regulatory compliance prevailed in many industries, including for the banking sector. When I joined UBS in 2005, anti-money laundering compliance was still absorbing the expansion into terrorist financing following 9\u002F11 in 2001.\n\nBack in the early 2000s, banks only considered corruption risks related to the laundering of the proceeds through transactions or clients. The idea that bank employees themselves or intermediaries working for banks could be involved in corruption was barely considered.\n\nEven with that limited scope, compliance officers didn’t have an easy job. For instance, tensions arose when compliance officers started to challenge business decisions that could lead to reputational or legal risks due to the types of transactions or clients involved. If the bankers and their compliance colleagues were not aligned, who should have the final say?\n\nIn 2010, the position of Global Head of Anti-Corruption was created in UBS. I was the lucky first holder of that position in the bank. This development coincided with an industry shift that included looking at employee-related risks involving corruption.\n\nAn important trigger was the realisation that intermediaries – “finders” who brought in wealthy clients for a fee – could present a risk to banks.\n\n### That’s banking – what about other industries?\n\nThe notion of anti-corruption compliance within companies only started to pick up internationally after the [OECD Anti-Bribery Convention](https:\u002F\u002Fwww.oecd.org\u002Fcorruption\u002Foecdantibriberyconvention.htm) came into force in 1999. The way that many countries implemented the Convention shifted the responsibility onto companies for how their staff and intermediaries behave in foreign markets where bribery involving public officials is a serious problem.\n\nFor companies that have ridden this wave and now have mature and well-functioning compliance programmes, the benefits are clear. Not only are they much better able to adapt to evolving legal and reputational risks, but they can also defend themselves should a bribery issue arise. They are better placed to demonstrate to new generations of activist shareholders, customers and other stakeholders that they are not exacerbating bribery and kleptocracy in foreign markets.\n\nThose that continue to believe that they have everything under control without an anti-corruption compliance programme may find customer and investor pressure will cause them to rethink, even if the risk of prosecutions and fines seems remote. This “stick” would be a lot stronger if [states were to enforce their foreign bribery laws](https:\u002F\u002Fwww.transparency.org\u002Fen\u002Fnews\u002Fexporting-corruption-2022-top-trading-countries-foreign-bribery-enforcement-multinational-companies) more effectively.\n\nEven so, the growth of compliance beyond banking is still evolving today. Some companies and state-owned enterprises are still at a very low level of maturity. And corruption remains a serious problem.\n\n### What principles have guided the Basel Institute’s work with the private sector?\n\nPragmatism has been a driving force. If you want compliance programmes to be accepted and implemented, they need to work from a business perspective while still effectively addressing legal and reputational risks.\n\nWe also focus on the culture within an organisation above all. Slapping more controls and checks on an organisation where the top management are indifferent to how business is won and employees are not encouraged to speak up about bribery won’t create an effective anti-corruption programme. Changing that culture to one of empowerment and “speaking up” is foundational for any anti-corruption compliance programme. It is sometimes also a huge challenge.\n\nSetting an example through actions is what brings the culture of an organisation to life. Leaders at the top, and throughout the organisation, need to give a strong, clear and constant message that bribery is not the way to do business even if it means missing out on some opportunities. Staff have to be provided with practical tools and management support when putting robust anti-corruption programmes into practice.\n\nAnd they should feel assured that if they do the right thing – refuse to pay a bribe to win a lucrative deal, for example – they will be praised and protected, not penalised.\n\nLast, individual compliance programmes help a company protect itself from risks, but alone they can’t change the environment in which they are working. That is why we have constantly promoted [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) between companies and other stakeholders as a practical and effective way to achieve systemic change in the fight against corruption in business.\n\n### What developments in compliance are you seeing now?\n\nCompliance has never ceased to evolve and for many businesses it’s now recognised as the conduit to promote values and embed the right culture throughout an organisation.\n\nI am heartened by the inspiring compliance officers and company leaders we work with, both individually and through Collective Action initiatives.\n\nOver the last year, we have accompanied many such professionals as they expand values-based compliance into topics like [human rights](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fhuman-rights) and environmental sustainability. They have broken silos and reached out to the civil society organisations that have traditionally dominated these areas. Some are working hard to raise standards of integrity across their industry, from [metals technology](https:\u002F\u002Fmetalscollectiveaction.org\u002F) to [banking](https:\u002F\u002Fwww.wolfsberg-principles.com\u002F).\n\nAnd we have celebrated some real successes against deeply ingrained corruption challenges, like [protecting seafarers](https:\u002F\u002Fcollective-action.com\u002Fnews\u002Fcutting-corruption-in-nigerian-ports-data-impact-and-collective-action-2401) from corruption in Nigerian ports.\n\nAnother positive development in compliance is closer integration with other business functions, from HR to antitrust and export controls. In many companies, HR departments now actively screen people based on their values, not only at onboarding but also as a prerequisite for promotion. They include ethics, culture and other compliance topics in staff onboarding.\n\nThis will gradually reinforce better organisational cultures over time – but only if the same approaches are also applied to those responsible for the oversight of compliance and the risk appetite of an organisation, including board members and CEOs.\n\n### What challenges does compliance face?\n\nDespite greater integration, compliance still competes within an organisation for scarce resources. When times are tough, such as during the pandemic, managers might find it easy to cut compliance programmes. But the responsibilities and risks remain. Collective Action can help compliance officers do more with less, by co-developing guidance and sharing experiences with others.\n\nBusiness practices are changing fast and compliance needs to stay abreast. For companies with complex global supply chains, compliance and due diligence are expected to extend all the way to the end of those. And it’s not necessarily any easier for companies that are moving towards end-to-end control of supply chains.\n\nThe rise in new technologies and social media runs both ways. On the one hand, they raise ethical questions and bring reputational risks that are mostly beyond a compliance officer’s control.\n\nOn the other hand, new technologies offer opportunities to enhance compliance. These might be external, such as e-government to reduce discretion and improve transparency in processes like licence approvals and customs documentation. Or internal, such as streamlined workflows and safe reporting channels.\n\nArtificial intelligence for routine compliance checks could bring efficiency – though a compliance department without humans is not something I could envisage for the time being.\n\n### Looking forward\n\nThe evolution of anti-corruption compliance is a fascinating and transforming discipline. Courageous and forward-thinking individuals and organisations have driven step changes in how compliance interacts with business functions and its power to drive cultural and behavioural shifts. I am glad to see such individuals emerging among new generations and to see young entrepreneurs embedding compliance into their companies from day one.\n\nWhat will magnify their efforts is Collective Action in its many forms. If there is one thing I hope for, it is that Collective Action becomes embedded in companies’ compliance programmes and the anti-corruption strategies of national governments.","2023-04-18","evolutions-in-anti-corruption-compliance-hope-for-the-future-2429","Evolutions in anti-corruption compliance: hope for the future","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F770f6321-8dd2-4585-afa6-7dc47bc81714?width=1000&height=650&format=webp&quality=80",[],[98,73],[101],[],2429,[98,73],[101],[131],1141,[],[21,98],[],"2023-04-18T16:01:27.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-04-27T21:02:12.000Z",[],"\u002Fresources\u002Fnews\u002Fevolutions-in-anti-corruption-compliance-hope-for-the-future-2429",{"id":141,"body":142,"status":6,"type":66,"date":143,"slug":144,"title":145,"image":146,"countries":147,"topic":149,"activity":151,"tags":153,"nid":158,"topics":159,"activities":161,"authors":162,"images":164,"websites":165,"area":19,"programme":19,"language":19,"translations":166,"translation_of":19,"user_created":58,"date_created":167,"user_updated":136,"date_updated":168,"content":169,"link":170},9657,"On 28 October 2020, Uganda registered a landmark judgment in the case of Uganda v Geoffrey Kazinda. Although there have been a couple of other previously prosecuted illicit enrichment cases, the Kazinda case is the most significant because of the vast sum of money involved: a total of UGX 4,630,195,258 (over USD 1,252,600).\n\nKazinda, a former Principal Accountant in the Office of the Prime Minister, was convicted on three counts of illicit enrichment contrary to section 31 of the Anti-Corruption Act, 2009. He has previously been prosecuted for other corruption-related offences. The case, which was investigated and prosecuted by the Inspectorate of Government, paves the way for development of the offence of illicit enrichment in Uganda.\n\n### Incompatible standard of living\n\nIn the first count, the court found that between 2009 and 2012, the accused maintained a standard of living that was not commensurate with his known sources of income. The evidence showed that between 2010 and 2012, the accused had rented a suite at Sheraton Hotel, Kampala for over six months. The accused spent UGX 210,364,011 (USD 56,910) on this expense. The accused had stated in his Asset Declaration Forms that, for the period in issue, he had no other sources of income other than his salary and allowances, which totalled UGX 83,754,655 (USD 22,658).\n\nTo disassociate this expense from himself, the accused obtained a credit facility at the hotel in the name of an accomplice. The accomplice denied having occupied the suite in his evidence. Also, expert evidence on handwriting showed that the accused had signed the invoices of the bills incurred. He also made part payments in cheques in his own name. Oral evidence from hotel staff also proved that it was the accused who occupied the suite at the time.\n\n### A mansion and plots of land in Kampala\n\nIn the second count, the court found that between 2010 and 2012, the accused was in control and possession of three plots of land in Bukoto, Kampala worth a total value of UGX 3,657,747,500 (USD 989,540), which was disproportionate to his known sources of income. On a part of this land sat the accused’s spectacular mansion.\n\nInterestingly, the accused had tried to disassociate himself from these properties by transferring them as a gift to the registered trustees of a local Christian monks’ group.  Three witnesses from the monks’ group testified that their society did not, in fact, own these properties. Their acquisition was not reflected in their Annual General Meeting reports of the years in question. Neither were they reflected in their inventory of properties.\n\nSo, though the accused had purported to have transferred these properties by way of a gift to the monks, evidence showed that he remained in possession and control of these properties. He also retained the land titles. The fact that the accused did not declare these properties in his Asset Declarations led to an inference that he had obtained them illicitly.\n\n### Luxury cars\n\nIn the third count, the court found that between 2010 and 2012, the accused was in control and possession of four motor vehicles worth a total value of UGX 769,473,835 (208,145 USD), which was disproportionate to his known sources of income. One of these vehicles was a Mercedes Benz worth a whopping UGX 544,594,287 (USD 147,315).  \n\nStrangely, the accused registered this luxurious vehicle in the name of a Christian monk who was his family friend. The other three vehicles were also registered in the names of accomplices. However, the court established that the accused owned and was in control of the said vehicles.\n\n### Asset Declaration – untrue, incomplete and incorrect\n\nThe court noted that the requirement for public servants to make Asset Declarations under the Leadership Code Act is not a mere formality but a legal requirement. Those who make the declarations undertake that the information they give is true, complete and correct. Any property or source of income that is not included in the asset declaration is therefore viewed with suspicion, and its omission must be sufficiently explained by the accused. \n\nThe court rejected the accused’s defence that he could have afforded this lifestyle since he had worked for 18 years in various positions. The court noted that even if his income were aggregated for all those years and even if he had not spent anything in all that time, the assets he was holding would still be hugely disproportionate to his known sources of income.\n\nThe accused was sentenced to suffer a total of 15 years’ imprisonment.  The court also issued confiscation orders against the three plots of land and the four motor vehicles described above. The accused was also disqualified from public office for a period of ten years. Prosecutors at the Inspectorate of Government will now work hard to ensure that the confiscation orders are executed and that the properties are realised.\n\n### Paving the way for illicit enrichment prosecutions in Uganda\n\nAt the time of writing, it was not clear whether the accused had exercised his right to appeal. Nevertheless, this case has set an excellent foundation for jurisprudence to be developed on the offence of illicit enrichment in Uganda. It is hoped that similar charges will be brought against other public servants in Uganda who have illicitly acquired enormous wealth, thereby deterring others from attempting the same.\n\nFor this to happen, it is essential to build strong capacity to investigate and prosecute cases of illicit enrichment. Through its International Centre for Asset Recovery, the Basel Institute on Governance has conducted high-impact [Financial Investigations and Asset Recovery training](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) in Uganda and many other African countries. Specifically covered in these training programmes is the “Source and Application Analysis of Funds” method of calculating the illicit wealth of an individual, elements of which appear to have been considered during this prosecution together with additional supporting evidence.\n\nThe Basel Institute also offers a practical introduction to the [Source and Application](https:\u002F\u002Flearn.baselgovernance.org\u002Fenrol\u002Findex.php?id=17) method as a free eLearning module on its LEARN virtual learning website.\n\n### Further reading\n\n*   [Full judgment of the Uganda vs. Geoffrey Kazinda case (HCT-AC\u002FCO NO. 004\u002F2016)](https:\u002F\u002Fulii.org\u002Fug\u002Fjudgment\u002Fhc-anti-corruption-division-uganda\u002F2020\u002F3)\n*   See also Tom Walugembe’s description of [Uganda’s first successful money laundering prosecution](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fbreaking-new-ground-prosecuting-first-money-laundering-case-uganda) and its implications for the country’s fight against corruption and money laundering.\n*   Andrew Dornbierer's quick guide to illicit enrichment gives a brief overview into this legal mechanism for non-specialists. It's available in [English](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28), [French](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28&lang=fr), [Spanish](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28&lang=es) and [Portuguese](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=28&lang=pt) on the Basel Institute's LEARN platform.","2020-11-18","uganda-achieves-landmark-victory-in-usd-125-million-illicit-enrichment-case-1916","Uganda achieves landmark victory in USD 1.25 million illicit enrichment case","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F7911f6da-6b25-4363-9e77-1cf9431a7a88?width=1000&height=650&format=webp&quality=80",[148],7380,[150],"Asset Recovery",[152],"Training",[154],{"tags_id":155},{"id":156,"name":157},1215,"Illicit financial flows",1916,[160],"Asset Recovery and Enforcement",[152],[163],1205,[],[21],[],"2022-05-26T22:53:53.000Z","2026-05-29T22:21:48.000Z",[],"\u002Fresources\u002Fnews\u002Fuganda-achieves-landmark-victory-in-usd-125-million-illicit-enrichment-case-1916",{"id":172,"body":173,"status":6,"type":174,"date":175,"slug":176,"title":177,"image":178,"countries":179,"topic":181,"activity":183,"tags":185,"nid":186,"topics":187,"activities":188,"authors":189,"images":190,"websites":191,"area":19,"programme":19,"language":19,"translations":192,"translation_of":19,"user_created":58,"date_created":193,"user_updated":60,"date_updated":113,"content":194,"link":195},10333,"A new report reveals the challenges that local and regional governments in Peru face in implementing public investment projects such as energy, transport and telecommunications infrastructure.\n\nIts analysis, case studies and recommendations will help all those implementing or monitoring public projects to anticipate problems and better achieve objectives.\n\nThe report, published in Spanish, is based on the experiences and research of the Basel Institute’s Subnational Public Finance Management Strengthening Programme ([Programa GFP](https:\u002F\u002Fwww.gfpsubnacional.pe\u002F)), supported by the [Swiss SECO Cooperation in Peru](https:\u002F\u002Fwww.cooperacionsuiza.pe\u002Fseco\u002F) since 2015.\n\n### Executive summary (adapted translation)\n\nVarious studies show that delays in the awarding of public tenders and the interruption of investments during project execution are among the main reasons for the low impact of public investment on competitiveness.\n\nCountries are [estimated](https:\u002F\u002Fwww.imf.org\u002Fen\u002FPublications\u002FBooks\u002FIssues\u002F2020\u002F09\u002F03\u002FWell-Spent-How-Strong-Infrastructure-Governance-Can-End-Waste-in-Public-Investment-48603) to lose on average between 30 and 50 percent of the potential benefits in the process. In Peru, around 40 percent of returns are lost due to difficulties in the administration of such projects.\n\nThat is why it is necessary to strengthen the capacities of subnational governments to implement public investment projects and to overcome the challenges posed by these processes.\n\n#### 233 problems in 36 projects\n\nThe aim of this document is to help improve the capacities of regional and local governments to successfully execute public investment projects. Through case studies, it identifies and analyses adverse situations and recurrent obstacles that affect or may affect the continuity, results or achievement of a project’s objectives.\n\nUltimately, this understanding provides subnational governments with more tools to design and manage their investment projects.\n\nTo this end, this document studies:\n\n*   233 adverse situations in the execution of large public investment projects…\n*   …identified from the analysis of 123 control\u002Faudit reports, prepared by Peru's Office of the Comptroller General during or after a project…\n*   … for a set of 36 public investment projects mainly belonging to subnational governments…\n*   … of which 12 are executed by public-private partnerships, 12 use a so-called “Obras por impuestos” model in which private companies advance the payment of their income taxes to finance and execute public investment projects, and 12 are public works.\n\n#### Twelve key typologies\n\nFrom the various typologies that emerge from the analysis of these adverse situations, 12 are prioritised due to their significant impact on variables such as cost, time and quality, as well as their frequency and relevance.\n\nThe most frequent type of adverse situation (9 percent of cases) is non-compliance, during the execution of the works, of technical regulatory requirements listed in the project's technical file.\n\nThis is followed, in order of frequency, by:\n\n*   Delays in the execution of the works\n*   Delays in the development\u002Fapproval of the technical file due to non-compliance with technical regulations or without the corresponding substantiation\n*   Approval of additional works or services without justification or without meeting the requirements\n*   Inconsistency in the valuation of works\n*   Failure to or a delay in transferring areas or land, or in providing legal clearance and eliminating interferences; and\n*   Non-compliance or deficiencies in supervision.\n\nThese typologies represent 36 percent of the adverse situations identified.\n\n#### Three top recommendations\n\nFrom the analysis of the most relevant and recurrent types of adverse situations, 11 recommendations to minimise their occurrence emerge.\n\nSome are general, referring to possible improvements in public investment regulations. Others are more specific, aimed at public officials of subnational governments in charge of executing public investment projects.\n\nAmong these recommendations, the following stand out:\n\n*   The standardisation of tools and processes for the design and execution of public investment projects, with the aim of improving quality levels in the development of technical files and ensuring compliance with the regulations.\n*   The establishment of Project Management Offices in the subnational government departments in charge of large investment projects or mega-projects. This could support more integrated management and improve the monitoring of project portfolio schedules, as well as enable more attention to be paid to the different aspects of project execution (time, cost, scope, risks, quality, communications, stakeholder management, among others).\n*   Improvements in contracting mechanisms and systems, in order to ensure quality contractors are hired. This could significantly reduce the deficiencies observed in the development and approval of technical dossiers.\n\n### More\n\n*   [Download the report](https:\u002F\u002Fwww.gfpsubnacional.pe\u002Fwp-content\u002Fuploads\u002F2023\u002F02\u002FDesafios-para-la-ejecucion-de-grandes-proyectos.pdf) (in Spanish)\n*   [Learn more](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-finance-peru) about the Swiss-funded Subnational PFM Strengthening Programme (in English)","News","2023-02-14","large-public-investment-projects-large-challenges-new-analysis-from-peru-2348","Large public investment projects, large challenges – new analysis from Peru","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F623c96eb-59d7-4697-96e2-b6c479c6411c?width=1000&height=650&format=webp&quality=80",[180],7203,[182],"Public Finance Management",[184,75,101],"Research",[],2348,[182],[184,75,101],[],[],[21],[],"2023-02-14T11:01:26.000Z",[],"\u002Fresources\u002Fnews\u002Flarge-public-investment-projects-large-challenges-new-analysis-from-peru-2348",{"id":197,"body":198,"status":6,"type":174,"date":199,"slug":200,"title":201,"image":202,"countries":203,"topic":205,"activity":206,"tags":208,"nid":209,"topics":210,"activities":211,"authors":212,"images":213,"websites":214,"area":19,"programme":19,"language":19,"translations":215,"translation_of":19,"user_created":58,"date_created":216,"user_updated":60,"date_updated":8,"content":217,"link":218},9886,"Peru’s Ministry of Economy and Finance has approved a new Code of Ethics and Conduct as part of its efforts to combat corruption and promote ethical principles and moral values.\n\nThe Code was co-developed by ministry officials with technical assistance from SECO-funded [Public Finance Management programme](\u002Fnode\u002F236\u002F) implemented by the Basel Institute on Governance in Peru. \n\nThe aim of the Code of Ethics and Conduct is to offer guidance on correct (and incorrect) behaviour, based on the example shown by public servants who demonstrate ethical behaviour in their daily work.\n\nAs the entity responsible for public finances in Peru, it is commendable that the Ministry of Economy and Finance is taking the lead in collaboratively developing tools to promote integrity. This Code of Ethics and Conduct is an important step in transforming the organisational culture of public bodies towards a culture of ethical and efficient behaviour.\n\n[Read the original article (in Spanish)](http:\u002F\u002Fgfpsubnacional.pe\u002F2019\u002F03\u002F12\u002Fel-ministerio-de-economia-y-finanzas-aprobo-su-codigo-de-etica-y-conducta-elaborado-de-forma-participativa\u002F) and [download the Code of Conduct](https:\u002F\u002Fcdn.www.gob.pe\u002Fuploads\u002Fdocument\u002Ffile\u002F297849\u002FRM099_2019EF43.pdf).","2019-03-12","peruvian-ministry-of-economy-and-finance-approves-code-of-ethics-and-conduct-851","Peruvian Ministry of Economy and Finance approves Code of Ethics and Conduct","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F167caa4d-7e9a-4532-ba90-84d7b7e79b21?width=1000&height=650&format=webp&quality=80",[204],7497,[182],[207],"Anti-corruption interventions",[],851,[182],[207],[],[],[21],[],"2022-05-26T22:57:05.000Z",[],"\u002Fresources\u002Fnews\u002Fperuvian-ministry-of-economy-and-finance-approves-code-of-ethics-and-conduct-851",{"id":220,"body":221,"status":6,"type":174,"date":222,"slug":223,"title":224,"image":225,"countries":226,"topic":231,"activity":232,"tags":233,"nid":234,"topics":235,"activities":236,"authors":237,"images":238,"websites":239,"area":19,"programme":19,"language":240,"translations":241,"translation_of":19,"user_created":58,"date_created":242,"user_updated":60,"date_updated":243,"content":244,"link":245},10556,"Congratulations to the winners of the [2025 Anti-Corruption Collective Action Awards](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fawards), presented by the Basel Institute on Governance with the support of the Siemens Integrity Initiative.\n\nThe awards were announced on 4 June 2025 in a video on social media from Elizabeth Andersen, the Basel Institute’s Executive Director.\n\n### Gretta Fenner Outstanding Achievement in Collective Action Award\n\nIn the category of Outstanding Achievement in Collective Action 2025, the award goes to [Saya Perempuan Antikorupsi – SPAK Indonesia (I am a woman against corruption)](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Finitiatives\u002F2241).\n\nOrganisations and initiatives awarded in this category have made significant contributions towards fairer market conditions and the prevention of corruption through their engagement in Collective Action.\n\nSPAK Indonesia, launched in 2014, empowers women across Indonesia to become agents of change against corruption. Through engaging educational tools and community involvement, SPAK promotes anti-corruption values in various settings, including schools and public institutions. They help build anti-corruption ecosystems and advocate against corruption as a root cause of violence against women.\n\n### Collective Action Inspirational Newcomer Award\n\nIn the category of Inspirational Newcomer, the award goes to the [Code of Ethics for Businesses in Kenya](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Finitiatives\u002F1478), developed by UN Global Compact Network Kenya in collaboration with the Kenya Association of Manufacturers and the Kenya Private Sector Alliance.\n\nOrganisations and initiatives awarded in this category have been active in the field of Collective Action for less than two years.\n\nLaunched recently, the Code of Ethics for Businesses in Kenya is a private-sector-led initiative rooted in the UN Global Compact’s Ten Principles. It unites over 800 companies in a collective stand against corruption, guiding responsible business conduct across all stakeholder groups. With digital tools like a transparency microsite enabling open reporting and compliance, the Code is transforming corporate culture across Kenya.\n\n### Finalists from around the world\n\nWe extend our heartfelt congratulations to the winners and all our shortlisted initiatives, who continue to be shining examples of Collective Action in the anti-corruption field.\n\nIn the category of Outstanding Achievement, the finalists were:\n\n*   [Indonesia Collective Action Coalition Against Corruption (KAKI)](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Finitiatives\u002F2034)\n*   [Virtuous Alliances in Argentina’s Energy Sector](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Finitiatives\u002F1581)\n\nIn the category of Inspirational Newcomer, the finalists were:\n\n*   [Anticorruption Business Club (ABC)](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Finitiatives\u002F2207) from Madagascar\n*   [Collective Action Initiative on Integrity and Anti-Corruption in the Private Sector in Mexico](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Finitiatives\u002F2234)\n\n### Jury selection and public vote\n\nAn expert jury reviewed all nominated initiatives and shortlisted the finalists before opening up to a public vote. The jury consisted of leading figures in the anti-corruption Collective Action community, including:\n\n*   Chantal Castro, Anticorruption Manager, UN Global Compact Brazil Network\n*   Lisa Miller, Integrity Compliance Officer, World Bank Group\n*   Pusetso Morapedi, Africa Coordinator, Integrity Initiatives International\n*   François Valérian, Chair, Transparency International\n\nThe final decision reflected a combination of jury scores and the public vote, ensuring that the selected initiatives demonstrated both expert merit and community resonance.\n\n\u003Ciframe frameborder=\"0\" src=\"https:\u002F\u002Fvideos.baselgovernance.org\u002Fvideos\u002Fembed\u002Fad16e0eb-d841-425b-b473-e505d0000368?title=0&amp;warningTitle=0&amp;peertubeLink=0&amp;p2p=0\">\u003C\u002Fiframe>\n\n### Learn more and see previous awards\n\nFor those interested in the selection process, the public vote, and the general awards methodology, as well as previous award winners, please find our awards methodology here: [award methodology](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2025-01\u002F2025%20Award%20Methodology.pdf).\n\nWe look forward to continuing to showcase and support outstanding efforts in Collective Action against corruption.","2025-06-04","announcing-the-winners-of-the-2025-anti-corruption-collective-action-awards-2815","Announcing the winners of the 2025 Anti-Corruption Collective Action Awards","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F48c27461-1bee-4cb7-bece-4bcbebb8929a?width=1000&height=650&format=webp&quality=80",[227,228,229,230],7776,7777,7778,7779,[98,73],[207],[],2815,[98,73],[207],[],[],[21,98],"English",[],"2025-06-04T16:01:36.000Z","2025-08-31T23:10:48.000Z",[],"\u002Fresources\u002Fnews\u002Fannouncing-the-winners-of-the-2025-anti-corruption-collective-action-awards-2815",{"id":247,"body":248,"status":6,"type":10,"date":249,"slug":250,"title":251,"image":252,"countries":253,"topic":254,"activity":256,"tags":258,"nid":259,"topics":260,"activities":261,"authors":262,"images":263,"websites":264,"area":19,"programme":19,"language":19,"translations":265,"translation_of":19,"user_created":58,"date_created":266,"user_updated":136,"date_updated":267,"content":268,"link":269},10081,"Today, [Europol](https:\u002F\u002Fwww.europol.europa.eu\u002F), [INTERPOL](https:\u002F\u002Fwww.interpol.int\u002F), and the [Basel Institute on Governance](https:\u002F\u002Fwww.baselgovernance.org\u002F) have formalised the establishment of a tripartite partnership for a working group on money laundering with digital currencies. The working group will aim to:\n\n*   gather, analyse, and exchange non-operational information regarding the use of digital currencies as a means of money laundering, and the investigation and recovery of proceeds of crime stored in the same form;\n*   organise annual workshops and meetings for the representatives of the above mentioned Law Enforcement Agencies and institutions to increase the capacity to successfully investigate crimes in which virtual currencies are involved;\n*   create a network of practitioners and experts in this field, who can collectively establish best practices and provide assistance and recommendations inside and outside the working group;\n\n### Threat for money laundering and terrorism financing\n\nInternet technologies become continuously more advanced, and so do the ways in which criminals utilise them for their illicit and illegal activities. Among these technologies, digital currencies are already transforming the criminal underworld.\n\nThere is a clear consensus that digital currencies pose a money laundering and terrorism financing threat. A small number of cases have already shown Law Enforcement Agencies that money laundering and terrorism financing can easily take place inside virtual environments, offering high levels of anonymity and low levels of detection removing many of the risks associated with real-world money laundering and terrorism financing activities.\n\n### Increasing use of digital currencies – information exchange needed\n\nEuropol, INTERPOL, and the Basel Institute on Governance are concerned about the seriousness of these threats and note the increasing use of new kinds of currencies. They are decentralised in their creation and use. In addition cryptography is used to secure transactions and to control the creation of new units.\n\nTo trace assets transferred, laundered, exchanged or stored through the use of cryptocurrencies poses new and distinctive challenges to investigators and prosecutors, as does the seizure and confiscation of the proceeds of crime in cryptocurrencies.\n\nEuropol, INTERPOL, and the Basel Institute on Governance recognise that Law Enforcement Agencies worldwide could benefit from the exchange of information and knowledge with peers from other jurisdictions. Therefore Europol, INTERPOL, and the Basel Institute on Governance established the tripartite partnership on money laundering with digital currencies.","2016-09-09","basel-institute-europol-and-interpol-establish-working-group-on-money-laundering-with-digital-currencies-158","Basel Institute, Europol and Interpol establish working group on money laundering with digital currencies","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F53d470f2-96da-485d-8276-65f142e6f617?width=1000&height=650&format=webp&quality=80",[],[255,150],"Anti-Money Laundering",[257],"Partnerships",[],158,[255,160],[257],[],[],[21],[],"2022-05-26T22:58:45.000Z","2026-05-29T22:22:11.000Z",[],"\u002Fresources\u002Fnews\u002Fbasel-institute-europol-and-interpol-establish-working-group-on-money-laundering-with-digital-currencies-158",{"left":271,"top":271,"width":272,"height":272,"rotate":271,"vFlip":273,"hFlip":273,"body":274},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>",1780676419670]