[{"data":1,"prerenderedAt":336},["ShallowReactive",2],{"news-what-do-bulgarian-citizens-think-about-corruption-integrity-and-anti-corruption-efforts-2691":3,"news-what-do-bulgarian-citizens-think-about-corruption-integrity-and-anti-corruption-efforts-2691-similar":82,"i-heroicons:arrow-left-20-solid":331},[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":20,"topics":21,"activities":22,"programme":23,"area":23,"websites":24,"language":23,"image":26,"translation_of":23,"countries":37,"tags":61,"authors":62,"images":79,"translations":80,"content":81},10489,"published","2024-09-23T16:01:39.000Z","2025-08-31T23:14:40.000Z","What do Bulgarian citizens think about corruption, integrity and anti-corruption efforts?","Blog","Bulgarian citizens need no reminding that corruption causes immense social harm, including limiting a country's ability to fight poverty, negatively affecting economic development, rupturing social values and eroding the fundamental principles of democracy and good governance.\n\nBut what do they really think about corruption in their country and the Government’s anti-corruption efforts? It is vital to gather evidence on this in order to better shape government anti-corruption policies and communications going forward.\n\nAs part of wider efforts to support the Government of Bulgaria’s anti-corruption measures, the Basel Institute carried out a [public perception survey](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcorruptionsurveybg2024) together with Global Metrics. The survey reveals that although corruption remains a top public concern in the country, citizens:\n\n*   are mostly unaware of any government anti-corruption reform initiatives;\n*   are not likely to report corrupt behaviour; and\n*   are increasingly losing trust in the democratic system of governance.\n\nThese negative trends, together with the frequent government changes and the critically low voter turnout in the June 2024 parliamentary elections (34 percent), make it imperative for the Bulgarian authorities to institute urgent anti-corruption and integrity reforms _and_ to better communicate to citizens how they are working to address corruption in the country. Such communication is critical for building and sustaining trust in public institutions and the democratic process in the country, for demonstrating that reform can actually be achieved in this area and for actively engaging citizens in the fight against corruption.\n\n### Corruption remains a primary concern\n\nThree years after tens of thousands of dissatisfied citizens flocked to the streets of Bulgarian cities to demand anti-corruption reforms, Bulgaria heads to its seventh parliamentary election on 27 October 2024. Corruption remains a top concern for Bulgarian citizens, according to the 2024 report on “Public attitudes towards corruption in Bulgaria and the anti-corruption actions of the Bulgarian Government”.\n\nThe 2024 survey found that corruption is among the top three most important problems facing Bulgaria for more than 70 percent of Bulgarian citizens. A quarter of respondents ranked it first. Low incomes and political and state governance were among the other most pressing problems identified.\n\nBulgarian citizens also overwhelmingly believe that corruption is widespread among high-ranking public officials, with almost 72 percent of the respondents stating that either most or almost all high-ranking public officials in Bulgaria are involved in corruption.\n\n### The importance of instituting and communicating reforms\n\nThe majority of Bulgarian citizens still see anti-corruption reforms as vitally important and expect the Bulgarian Government to deliver on an anti-corruption agenda. So, it is essential for the authorities to implement urgent reforms to combat corruption and strengthen integrity. The Government also needs to adequately communicate these reforms to citizens in order to galvanise their support, engage them in the reform agenda, and build and retain their trust.\n\nThe survey data also suggests that respondents were more likely to be willing to report corrupt behaviour if they were exposed to media reports about effective government actions against corruption. And yet, the 2024 findings show that more than half of the respondents could not name a single anti-corruption effort of the Bulgarian Government.\n\nConvincing a majority of the population that change is possible needs constant and evidence-based communication, awareness raising and information campaigns.\n\n### Reforms despite political instability\n\nDespite going through a period of extreme political instability and six snap elections in the last two and half years, Bulgaria has made progress in strengthening capacity to tackle corruption, particularly in the area of legislative reforms and galvanising bottom-up support for integrity reforms from the business sector. These improvements demonstrate that it is possible for political rivals to coalesce around common anti-corruption and integrity policy priorities.\n\nThe European Commission decisions to [end the cooperation and verification mechanism](https:\u002F\u002Fcommission.europa.eu\u002Fdocument\u002Fdownload\u002F701dd1d1-b13f-491f-b9a2-ec7c38b1661b_en?filename=C%282023%295652_0.pdf) (October 2023) and to [authorise Bulgaria’s partial entry into the Schengen area](https:\u002F\u002Fec.europa.eu\u002Fcommission\u002Fpresscorner\u002Fdetail\u002Fen\u002Fip_24_1722) (March 2024) also recognised that some progress has been made on rule of law and anti-corruption reforms.\n\nIf continued reform efforts are combined with thorough citizen engagement, there is hope that Bulgaria’s anti-corruption and integrity progress may also be reflected in future perception surveys, in day-to-day business and politics and, most importantly, in an improvement in the daily lives of Bulgaria’s citizens.\n\n### Learn more\n\nThe Basel Institute has provided technical support on integrity issues to the Government of Bulgaria since 2022. Through our current programme this support has included, among other topics, the development of the Government’s capacity to communicate on corruption issues through the design and launch of a Public Integrity Campaign based on data from public opinion surveys, media sentiment analysis and focus group research conducted in partnership with the Institute. The programme is funded by the Swiss Agency for Development and Cooperation (SDC) and USAID.","2024-09-23",[14],"","what-do-bulgarian-citizens-think-about-corruption-integrity-and-anti-corruption-efforts-2691",[17,18,19],"Research","Reports","Insights",2691,[],[17,18,19],null,[25],"Main page",{"id":27,"storage":28,"filename_disk":29,"filename_download":30,"title":9,"type":31,"created_on":32,"modified_on":32,"charset":23,"filesize":33,"width":34,"height":35,"duration":23,"embed":23,"description":23,"location":23,"tags":23,"metadata":36,"focal_point_x":23,"focal_point_y":23,"tus_id":23,"tus_data":23,"uploaded_on":32},"0bb07d34-4a69-431b-b6e1-834e90bc3d1f","local","0bb07d34-4a69-431b-b6e1-834e90bc3d1f.webp","tmp.webp","image\u002Fwebp","2025-05-12T21:10:22.000Z",91886,1400,788,{},[38],{"id":39,"news_id":40,"countries_id":55},7095,{"id":5,"status":6,"user_created":41,"date_created":7,"user_updated":42,"date_updated":8,"title":9,"type":10,"body":11,"image":27,"date":12,"topic":43,"slug":15,"activity":44,"nid":20,"topics":45,"activities":46,"programme":23,"area":23,"websites":47,"translation_of":23,"language":23,"countries":48,"tags":49,"authors":50,"images":52,"translations":53,"content":54},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","b0662e2a-864d-4888-a1b7-4342b7570b30",[14],[17,18,19],[],[17,18,19],[25],[39],[],[51],1102,[],[],[],{"id":56,"name":57,"code":58,"latitude":59,"longitude":60},22,"Bulgaria","BG",42.73388,25.48583,[],[63],{"id":51,"news_id":64,"authors_id":76},{"id":5,"status":6,"user_created":41,"date_created":7,"user_updated":42,"date_updated":8,"title":9,"type":10,"body":11,"image":27,"date":12,"topic":65,"slug":15,"activity":66,"nid":20,"topics":67,"activities":68,"programme":23,"area":23,"websites":69,"translation_of":23,"language":23,"countries":70,"tags":71,"authors":72,"images":73,"translations":74,"content":75},[14],[17,18,19],[],[17,18,19],[25],[39],[],[51],[],[],[],{"id":77,"name":78,"position":23,"image":23},548,"Renne Traicova",[],[],[],[83,119,147,170,194,219,243,276,303],{"id":84,"body":85,"status":6,"type":10,"date":86,"slug":87,"title":88,"image":89,"countries":90,"topic":91,"activity":94,"tags":95,"nid":104,"topics":105,"activities":107,"authors":108,"images":111,"websites":112,"area":23,"programme":23,"language":23,"translations":113,"translation_of":23,"user_created":41,"date_created":114,"user_updated":115,"date_updated":116,"content":117,"link":118},10418,"How do corruption and security intersect? What is _strategic_ corruption and what can we do about it?\n\nThese were two fundamental questions tackled at the Countering Strategic Corruption workshop at the [2024 Basel Peace Forum](https:\u002F\u002Fbasel-peace.org\u002Fbpf-2024\u002F). Claudia Baez Camargo, Head of Prevention, Research and Innovation at the Basel Institute on Governance, spoke at the event. Together with her colleague Saba Kassa, the team’s Deputy Head, she highlights two key ideas:\n\n*   Using the lens of power helps us to better understand how corruption impacts security_._ Corruption changes power dynamics, which in turn affect security.\n*   We need to see how corruption is a highly functional tool for those seeking not just private benefits but – in the case of strategic corruption – geopolitical goals.\n\n### Power: at the heart of corruption and security issues\n\nCorruption fuels insecurity in many ways, directly and indirectly. But the big picture is that corruption affects the exercise of power by undermining it, or by strengthening it in a particular person or group’s favour.\n\nChanges in power in turn affect all forms of human security, including a country’s ability to defend itself against internal or external threats.\n\nIt is useful to think of three different types of corruption:\n\nCorruption State power Implications Insecurity Endemic corruption Weakens ability to serve citizens.\n\nErodes trust. \n\nIncreases inequalities and poverty.\n\nFuels insecurity.\n\nErodes performance of security institutions.\n\nState capture\n\nRepressive capacities are instrumentalised. State institutions serve elites. \n\nConsolidates power in hands of political elites.\n\nImpunity is the norm.\n\nEnables discretionary and abusive control of security apparatus.\n\nFuels radicalisation of oppressed groups. \n\nStrategic corruption State powers abused and weaponised to achieve a geopolitical goal.\n\nFunds conflict, weapons.\n\nInfluences or destabilises other countries.\n\nContributes to polarisation.\n\nEmboldens populists, authoritarian or violent groups.\n\n### Endemic corruption: weakening institutions and trust\n\nWidespread and systemic corruption affects the ability of the state to serve citizens. Consider the theft of public funds earmarked for hospitals or medicines, which affects citizens' access to good health care. Consequences include higher inequality and poverty, as well as an erosion of trust in government and public institutions. This is where security risks come in. [Popular protests may spur violence](https:\u002F\u002Fcarnegieendowment.org\u002F2018\u002F04\u002F12\u002Ffighting-hydra-lessons-from-worldwide-protests-against-corruption-pub-76036) and conflict as tensions rise.\n\nIn conflict-afflicted and fragile contexts, theft of humanitarian aid or resources dedicated to strengthening legitimate state actors and institutions can undermine the prospects for sustainable peace.\n\nA related problem is the systematic erosion of defence and security institutions. Corrupt procurement deals and embezzlement leave institutions with underpaid and underequipped staff while draining national budgets.\n\nThis makes it very challenging to respond to domestic and external threats, and organised crime and terrorism can get a stronger foot in the door. For example, research in [Nigeria](https:\u002F\u002Fwww.tandfonline.com\u002Fdoi\u002Fabs\u002F10.1080\u002F09592318.2020.1672968) has shown that corruption in the military affects the ability to respond effectively to the militant group Boko Haram. In other words, corruption undermines the most basic responsibility of states: protecting citizens from violence and conflict.\n\n### State capture: centralising power\n\nState capture is a systemic form of corruption in which political elites, often together with economic elites, control state institutions for their narrow purposes. It is more than about siphoning off state resources with impunity. It can be about getting laws, such as procurement rules, just right for those political elites and their associates to win lucrative contracts or control valuable natural resource sectors.\n\nThe unchecked ability to shape laws and direct state intuitions puts a lot of power in the hands of a few people. For example, they can instrumentalise enforcement institutions such as the police or courts to neutralise opponents and ensure impunity for their circle. All this strengthens their power base. And it shows again that corruption can be a highly functional tool.\n\nThe citizens of a country suffering from state capture understand that power is exercised discretionarily and that the rules apply to some and not to others. Fear and powerlessness often close the door to challenging the situation through democratic means.\n\n### Strategic corruption: a powerful geopolitical tool\n\nStrategic corruption goes beyond the kind of narrow personal benefits implied in the common definition of corruption as “the abuse of entrusted power for private gain”. Here, corruption is weaponised to help change power dynamics on the geopolitical stage.\n\nIn this cross-border and global context, states can use corrupt means and divert public resources to fund their geopolitical objectives. For an in-depth case study of strategic corruption, see the _[Kremlin Playbook](https:\u002F\u002Fwww.csis.org\u002Fprograms\u002Feurope-russia-and-eurasia-program\u002Fprojects\u002Frussia-and-eurasia\u002Fkremlin-playbook)_ series.\n\nLooking at examples of strategic corruption again highlights the _functionality_ of corruption. It’s used not only to gain money and control of resources but because it gives people the power to achieve their goals.\n\nThat functionality goes both ways. Even in democratic contexts, politicians can use [accusations of corruption](https:\u002F\u002Fedition.cnn.com\u002F2023\u002F08\u002F09\u002Fpolitics\u002Fhouse-oversight-republicans-hunter-biden\u002Findex.html) to erode trust in opponents or public institutions and weaken their legitimacy. On the other hand, politicians with a strong anti-corruption platform can see success in the polls, as [Guatemala](https:\u002F\u002Fwww.wsj.com\u002Fworld\u002Famericas\u002Fleftist-sociologist-to-take-office-as-guatemalas-new-president-1a378380) and Bulgaria have recently demonstrated.\n\n### What we can learn from corruption’s power and functionality\n\nThe main takeaway? Looking at power and functionality helps us better understand how corruption affects security and at why strategic corruption is increasingly becoming a concern.\n\nThe main lesson? That we need to fight (strategic) corruption by disrupting its functionality, i.e. making it less of an effective strategy for obtaining power and achieving other illicit goals. And to do that, we need to ensure that anti-corruption efforts are strategic, coordinated and effective.","2024-02-13","how-strategic-corruption-fuels-insecurity-by-affecting-power-2582","How (strategic) corruption fuels insecurity by affecting power","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fa57ab670-9908-41dd-81ed-6a68124ff94b?width=1000&height=650&format=webp&quality=80",[],[92,93],"Prevention"," Research and Innovation",[19],[96,100],{"tags_id":97},{"id":98,"name":99},1376,"Defence and security",{"tags_id":101},{"id":102,"name":103},973,"Corruption",2582,[106],"Prevention Research and Innovation",[19],[109,110],1120,1121,[],[25],[],"2024-02-13T17:01:30.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-05-07T21:29:55.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-strategic-corruption-fuels-insecurity-by-affecting-power-2582",{"id":120,"body":121,"status":6,"type":122,"date":123,"slug":124,"title":125,"image":126,"countries":127,"topic":129,"activity":131,"tags":134,"nid":135,"topics":136,"activities":137,"authors":138,"images":139,"websites":140,"area":23,"programme":23,"language":23,"translations":141,"translation_of":23,"user_created":41,"date_created":142,"user_updated":143,"date_updated":144,"content":145,"link":146},10399,"> “Fighting corruption has to be a collective effort. No single stakeholder can do it alone. Government cannot do it alone, or the public administration. If only citizens are left to fight corruption, they will struggle. And the private sector likewise.” – Gretta Fenner, Managing Director, Basel Institute on Governance\n\nEffectively combating pervasive corruption in Bulgaria requires sustained, collective efforts by the government, the business sector, civil society and individual citizens. And there is a lot of appetite across all those sectors for concrete [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) to build trust and achieve change.\n\nThat was the overwhelming message of a high-level forum on 10 October 2023 on [strengthening transparency and governance through Collective Action in Bulgaria](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fhigh-level-forum-strengthening-transparency-and-governance-through-collective-action-bulgaria).\n\nA joint initiative of the Basel Institute on Governance and the Ministry of Finance of Bulgaria, the event was a chance to shape private-sector engagement in anti-corruption and good governance efforts in Bulgaria.\n\nIt was organised in collaboration with the [American Chamber of Commerce](https:\u002F\u002Famcham.bg\u002F), the [Bulgarian-Swiss Chamber of Commerce](https:\u002F\u002Fbscc.bg\u002Fen\u002F) and [Transparency International Bulgaria](https:\u002F\u002Ftransparency.bg\u002F?lang=en), with funding from the Swiss Agency for Development and Cooperation and from USAID.\n\n[View the YouTube playlist here](https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=qPS4mO02hpk&list=PLYRnhpCcnLP9EY71a8BO1zc_-Js66FHMn).\n\n### Curing the cancer of corruption\n\nA zero-tolerance approach to corruption is essential in both the public and private sectors, agreed participants, to turn the page on Bulgaria’s deeply rooted corruption. Minister of Finance Assen Vassilev put it bluntly, saying:\n\n> “Corruption is a cancer. It suffocates society…. It has infiltrated trade unions, employer organisations, almost all sectors of the economy, and nearly the entire state administration. The fight against such a significant cancer in Bulgarian society will be neither quick nor easy. It will require… to use a quote of \\[former Prime Minister\\] Stefan Stambolov, \"grasping at the devil's tail to pull the country out of the swamp\".\n\nMinister of Regional Development Andrey Tsekov agreed, calling corruption in public procurement a “disease”. More than a third of public contracts are awarded with only one company bidding, he said. That raises red flags. Transparently publishing tenders and technical certifications online will help, he said, but more than that:\n\n> Only by uniting together – the government and the private sector – can we tackle the causes of corruption in public procurement.\n\n### Complementing regulations\n\nThe government’s role is not limited to introducing and enforcing regulations. With the help of businesses and civil society, it can also introduce collectively developed measures that promote transparency and fairness for all.\n\nAs Nicola Bonucci, Member of the Board of the Basel Institute on Governance, said:\n\n> The law is a necessary but not sufficient condition for ensuring transparency and governance. That is where Collective Action plays a role.\n\nHigh-level business representatives echoed this. In the words of Boni Bonev, Chair of the Bulgarian-Swiss Chamber of Commerce:\n\n> It is only through Collective Action that we can create and sustain a culture of integrity at all levels of political, business and social life in Bulgaria. Where there is integrity, there is no corruption.\n\nIvan Mihaylov, CEO of the American Chamber of Commerce in Bulgaria, added that:\n\n> The collective efforts of government and business in the fight against corruption would be more effective if, in vulnerable sectors like public procurement, recurring patterns of violations were identified and effectively eradicated.\n\n### A platform for dialogue\n\nHow to turn from abstract agreement to real action on the ground? Deputy Prime Minister Mariya Gabriel’s speech emphasised the need to establish a robust platform for dialogue between the public and private sectors:\n\n> In finding solutions to a common problem like corruption, it is essential to share experiences, good ideas and practices – national and international, from the perspective of institutions, companies, NGOs and civil society. Different sectors have different perspectives and each one is useful and welcome in this process.\n\nSuch a platform could significantly improve transparency and integrity, support the liberalisation of key sectors prone to corruption (like the energy sector), and encourage more openness and accountability in major infrastructure projects.\n\nSwiss Ambassador Raymund Furrer noted the flexibility of the Collective Action approach, noting that initiatives could seek to:\n\n*   raise standards of integrity in an industry or market;\n*   develop self-regulatory standards for specific sectors;\n*   solve systemic issues related to corporate bribery and corruption; and\u002For\n*   enhance fair competition and level the playing field between competitors\n\n### International implications\n\nThe stakes are high, both within Bulgaria and with regard to its international reputation, investment and trade. Within Bulgaria, as Furrer said,\n\n> Governance, accountability, transparency are essential for economic, social and political systems to work effectively, efficiently and justly.\n\nFrançois Valérian, Member of the Board of Transparency International, warned of the wider “global economy of corruption”, saying:\n\n> The economy of corruption harms common good by delivering a global economic output which is much lower than the one that can be obtained through the licit economy.\n\nU.S. Ambassador [Kenneth Merten highlighted](https:\u002F\u002Fbg.usembassy.gov\u002Fremarks-by-ambassador-kenneth-merten-at-basel-institute-forum-10-10-2023\u002F) how Collective Action could support foreign investment in Bulgaria, saying that:\n\n> Close coordination with the business community and civil society is considered critical in the implementation of investment screening. This partnership can help attract constructive foreign capital while preventing the entry of corrosive capital.\n\nThat is why it is vital for Bulgaria’s key political and business representatives to look beyond its borders and collaborate internationally.\n\nCollective efforts and knowledge sharing among peers from different countries can provide valuable insights into effective anti-corruption strategies and efforts to eradicate corruption.\n\n### What’s next?\n\nWe are heartened by the strong appetite for change in Bulgaria. Motivation spans from political, business, diplomatic and civil society representatives at the highest levels to those on the front lines of fighting corruption every day.\n\nThat is already a huge step forward in fostering the trust that is needed to collaborate effectively across sectors.\n\nWe stand ready to assist the Government of Bulgaria and all relevant stakeholders to launch develop innovative Collective Action initiatives to support the fight against corruption. Learn more about the Basel Institute’s leading role in fostering Collective Action against corruption on our online resource centre, the [B20 Collective Action Hub](https:\u002F\u002Fcollective-action.com\u002F).","News","2023-10-13","360-degree-support-for-collective-action-against-corruption-in-bulgaria-whats-next-2520","360-degree support for Collective Action against corruption in Bulgaria – what’s next?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F00b6dc69-ba82-4430-af26-aa313281baf3?width=1000&height=650&format=webp&quality=80",[128],7162,[130],"Collective Action",[132,133],"Events","Partnerships",[],2520,[130],[132,133],[],[],[25,130],[],"2023-10-13T10:01:35.000Z","dfef11db-1bc6-47e9-a61d-93443995484b","2026-05-08T21:11:09.000Z",[],"\u002Fresources\u002Fnews\u002F360-degree-support-for-collective-action-against-corruption-in-bulgaria-whats-next-2520",{"id":148,"body":149,"status":6,"type":10,"date":150,"slug":151,"title":152,"image":153,"countries":154,"topic":155,"activity":156,"tags":157,"nid":158,"topics":159,"activities":160,"authors":161,"images":162,"websites":163,"area":23,"programme":23,"language":164,"translations":165,"translation_of":23,"user_created":41,"date_created":166,"user_updated":115,"date_updated":167,"content":168,"link":169},10542,"There could hardly be a more critical time for policymakers in the European Union to understand how corruption _really_ intersects with organised crime and impacts citizens’ security, prosperity and trust in institutions.\n\nAnd just as importantly, how to leverage data and advanced tools to fight corrupt networks effectively.\n\nThe Basel Institute is proud to be a partner in the [FALCON](https:\u002F\u002Fwww.falcon-horizon.eu\u002F) (Fight Against Large-scale Corruption and Organised Crime Networks) project. In this cross-sector EU Horizon research project, a consortium of 25 organisations from different countries is developing innovative tools targeting the intersection of corruption and crime. The Basel Institute’s participation in the EU project is funded by the Swiss State Secretariat for Education, Research and Innovation (SERI).\n\nAt the halfway point of the three-year project, we spoke with Project Coordinator Evgenia Adamopoulou to find out how it is going and what it could mean for the future of anti-corruption efforts in the EU and beyond.\n\n### 1\\. What is Project FALCON and what makes it unique as a corruption research project?\n\nFALCON is an EU-funded research project to enhance the fight against corruption and thereby minimise its negative impacts on democratic freedoms, security and people’s trust in institutions.\n\nThe aim is to equip law enforcement agencies, policymakers and watchdogs with data-driven tools for corruption risk assessment, investigation support and decision-making. We want to bridge the gaps between policy, law enforcement and technology – gaps that can make anti-corruption efforts uncoordinated and leave law enforcement one step behind the criminals.\n\nThe idea is to build a next-generation corruption detection and prevention ecosystem which stays ahead of evolving corruption schemes.\n\nAt FALCON we’re focused on innovation. For example:\n\n*   We are developing novel, evidence-based indicators of corruption which go beyond perception-based indices.\n*   We are finding ways to automate risk assessments by fusing structured and unstructured data from a wide range of sources, including public procurement and corporate records, crypto transactions, satellite imagery and open-source intelligence.\n*   We are using this data to create AI-powered tools that reveal hidden corruption patterns in order to facilitate the work of law enforcement, and test them in real-world scenarios.\n\n### 2\\. Why is the EU funding FALCON – what will Member States gain?\n\nCorruption remains a major challenge across Europe, undermining democratic institutions, distorting fair competition and facilitating organised crime. Corruption detection, risk assessment and prosecution remain slow, complex and costly.\n\nFALCON delivers innovative, data-driven solutions which can enhance the EU’s ability to combat corruption effectively.\n\nHere’s why our focus areas matter for the EU:\n\n1\\. Public procurement fraud costs the EU billions of euros each year. FALCON will provide tools to automatically detect high-risk tenders, favouritism and overpricing, preventing fraud before it happens.\n\n2\\. Corruption at border crossings enables smuggling, human trafficking and illegal trade. FALCON will help to strengthen border integrity and security by developing AI-powered visual recognition tools, crypto-asset tracking and pattern analysis of illicit financial flows.\n\n3\\. Sanctions circumvention is a serious risk in the current geopolitical situation. Sanctioned individuals and entities exploit loopholes in financial systems to move their assets under cover. FALCON is developing tools to reveal hidden ownership structures, detect suspicious movements of money and uncover transnational networks facilitating the illicit financial activities of corrupt elites.\n\n4\\. Conflicts of interest of politically exposed persons (PEPs) can lead to the abuse of public funds – i.e. EU taxpayers’ money. FALCON’s tools will cross-analyse financial records, public procurement data and asset declarations to help investigators detect undisclosed conflicts of interest and safeguard public funds.\n\nTechnological tools are just one part of FALCON. The fight against corruption also demands coordinated efforts across borders, institutions and sectors. FALCON supports this by fostering collaboration among law enforcement agencies. At the same time, our research teams help to build capacity by providing training and producing policy recommendations to strengthen anti-corruption frameworks across the EU.\n\n### 3\\. How will FALCON ensure the tools will work in practice?\n\nAt FALCON, our focus is on delivering tools that can be used in the real world, not only theoretical research. Some are already being tested and refined in real-life pilot scenarios with law enforcement agencies and border guards in Bulgaria, France, Lithuania, Moldova, Romania and Serbia. They include:\n\n*   Automated corruption risk assessment, a data-driven platform for risk assessment and investigation prioritisation. This will help law enforcement and anti-corruption agencies analyse public procurement data, company data and border corruption patterns.\n*   Investigation support platform: A search tool which makes it easy to explore the FALCON Knowledge Base – basically a large collection of data – using ready-made or custom queries.\n*   Predictive analytics for corruption trends: A tool for predicting corruption risks in procurement processes by identifying high-risk scenarios, such as single bidding.\n*   Visual recognition for border corruption: This tool aids border guards in detecting suspicious activities by identifying vehicle licence plates.\n\nBy testing these tools in simulated corruption scenarios – bribery of an EU official in return for contracts, for example – we can ensure that they are practical, effective and adaptable for anti-corruption experts across Europe.\n\nIt’s important to stress that FALCON is committed to developing fully transparent and trustworthy AI tools that are compliant with national and EU regulations.\n\n### 4\\. The project is nearly halfway through. How is it going so far in terms of collaboration and outputs?\n\nFALCON is on track to meet its objectives. More importantly, we’re pleased to see the strong collaboration across the diverse consortium involving AI researchers, corruption experts and academics. These groups don’t typically work together – but they should do more!\n\nOne of the major achievements has been the release of the first Corruption Intelligence Pictures – detailed studies of corruption trends, schemes and connections with organised crime. These encompass actionable risk indicators for different areas. For example, for public procurement, risk indicators might cover single bidding, buyer concentration, length of submission or decision period, and unusual market entry. Risk indicators at [border crossings](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fqg38) may include the frequency of entries and exits, length of stay, model of vehicles, etc.\n\nFALCON’s AI and data analytics tools are also taking shape. For example:\n\n*   Machine learning models have been trained to detect corruption risks using real world data.\n*   Crypto-asset tracking and anomaly detection tools are showing promise for improving how illicit financial flows can be traced on blockchains.\n*   Natural language processing models are under development to enhance the analysis of public procurement records and financial disclosures for corruption risks.\n\nThe first pilot tests of FALCON tools took place in January 2025, and four training workshops have reached over 250 participants so far.\n\n### 5\\. Any surprises?\n\nYes! First, while we anticipated hidden links between corruption and organised crime, these links are often more deeply hidden than we expected. This has triggered us to develop even more advanced tools to analyse relationships, map out networks and expose corrupt actors and money flows.\n\nSecond, some financial, company and procurement datasets have limited transparency or restricted access. In response, we are developing AI techniques to extract intelligence from unstructured sources such as news archives, leaks and web-scraped financial disclosures.\n\nThat’s a powerful lesson on the need for greater access to such data, not only for law enforcement but for research and civil society monitoring purposes.\n\n### 6\\. How is the collaboration with the Basel Institute?\n\nThe Basel Institute on Governance is a key partner to FALCON and brings valuable experience not only in pioneering anti-corruption research but in working hand-in-hand with law enforcement and policy institutions around the world. As a result, our collaboration plays an important role in connecting cutting-edge research with real-world anti-corruption enforcement. As a globally recognised institution specialised in anti-corruption, asset recovery and governance, the Institute’s expertise has helped ensure that FALCON’s tools are aligned with real-world needs.\n\nWorking with the Basel Institute has been a two-way exchange. FALCON benefits from the Institute’s on-the-ground insights about what’s really driving corruption and organised crime, and the challenges faced by law enforcement. At the same time, the project’s advanced tools offer new ways to automate and enhance investigations. This will help the Basel Institute incorporate the latest advancements in AI, data analytics and machine learning into their technical assistance projects with law enforcement and related agencies worldwide.\n\nAs the FALCON project progresses, we are working increasingly closely with the Basel Institute. We’re testing corruption risk indicators on real cases. We’re developing policy recommendations based on project findings. And we’re working hard to ensure FALCON’s outputs will be sustained and integrated into ant-corruption efforts beyond the project’s lifetime. Watch this space.\n\n_The FALCON project is funded under the European Union’s Horizon Europe Framework Program Grant Agreement ID 101121281. The Basel Institute’s involvement in the project is funded by the Swiss State Secretariat for Education, Research and Innovation (SERI). Views and opinions expressed are those of the author(s) only and do not necessarily reflect those of the European Union, the European Research Executive Agency or SERI._","2025-03-19","project-falcon-innovating-the-fight-against-corruption-across-the-eu-2784","Project FALCON: Innovating the fight against corruption across the EU","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F66772822-a24f-4558-ad22-9eb2af8dc74f?width=1000&height=650&format=webp&quality=80",[],[92,93],[17,19],[],2784,[106],[17,19],[],[],[25],"English",[],"2025-03-19T17:01:36.000Z","2026-05-07T21:29:56.000Z",[],"\u002Fresources\u002Fnews\u002Fproject-falcon-innovating-the-fight-against-corruption-across-the-eu-2784",{"id":171,"body":172,"status":6,"type":122,"date":173,"slug":174,"title":175,"image":176,"countries":177,"topic":179,"activity":182,"tags":183,"nid":184,"topics":185,"activities":186,"authors":187,"images":188,"websites":189,"area":23,"programme":23,"language":23,"translations":190,"translation_of":23,"user_created":41,"date_created":191,"user_updated":42,"date_updated":8,"content":192,"link":193},10449,"Public procurement is a notorious risk area for corruption and other unfair business practices all over the world – including in Bulgaria, where diverse stakeholders are now coming together to find a practical solution to corruption risks in public tenders that works for all parties.\n\nOne solution they are discussing is a [High-Level Reporting Mechanism](https:\u002F\u002Fcollective-action.com\u002Fexplore\u002Fhlrm). In essence, this is a channel to raise and quickly resolve alerts about suspected bribery or unfair business practices in public tenders.\n\nThe concept of the HLRM was developed and continues to be advanced by the Basel Institute on Governance and OECD as a form of [anti-corruption Collective Action](https:\u002F\u002Fcollective-action.com\u002F). These types of Collective Action tools and approaches are a crucial ingredient when it comes to improving business integrity and strengthening transparency and accountability between the public and private sectors, supported by civil society.\n\n### Bringing business, government and other parties to the table\n\nTo bring relevant stakeholders to the table on this topic, the Basel Institute on Governance hosted a Collective Action Business Consultation in Sofia, Bulgaria, on 13 May 2024.\n\nThe Consultation provided a structured trust-building process to align efforts and discuss the design and implementation of an HLRM. It had the full support of the Mayor of the City of Sofia, Vassil Terziev, who made opening remarks and emphasised his commitment to making Sofia a more transparent municipality.\n\nThe event was held in collaboration with the Bulgarian Public Procurement Agency, the Bulgarian Industrial Capital Association, the Bulgarian-Swiss Chamber of Commerce as well as the American Chamber of Commerce (AmCham). As part of a holistic programme of support to the Bulgarian Government, the event was funded the United States Agency for International Development (USAID) and the Swiss Agency for Development and Cooperation (SDC).\n\n### All agree: time to test novel approaches to safeguard procurement\n\nRepresentatives from both government and the business community united around the idea of establishing regular business consultations with the government in order to introduce new mechanisms that boost transparency and accountability, reduce corruption and consequently increase competition in public procurement processes.\n\nParticipants exchanged their views on opportunities and challenges for introducing an HLRM in Bulgaria to create a more effective public procurement system beneficial to everyone (except the corrupt!). Among other things, they agreed:\n\n*   Mechanisms that help improve trust and transparency, such as the HLRM, are key to enhancing the confidence of companies in public procurement processes.\n*   There is broad and multi-stakeholder support for piloting an HLRM in public procurement – now this needs to be tested in a specific project.\n*   Opportunities for testing innovative approaches to improve public procurement exist at the regional and municipal levels as well as at the national level.\n\n### Learn more\n\nRead the [summary report](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-06\u002FReport_Business_Consultation_May_13_2024.pdf), including full takeaways, photos and quotes from the distinguished participants.","2024-06-12","what-do-businesses-in-bulgaria-say-about-safeguarding-procurement-from-corruption-2642","What do businesses in Bulgaria say about safeguarding procurement from corruption?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F978aadf0-785c-4c95-900d-f652c57ed396?width=1000&height=650&format=webp&quality=80",[178],7119,[130,180,181],"HLRM","Private Sector",[132,133],[],2642,[130,180,181],[132,133],[],[],[25,130],[],"2024-06-12T16:01:33.000Z",[],"\u002Fresources\u002Fnews\u002Fwhat-do-businesses-in-bulgaria-say-about-safeguarding-procurement-from-corruption-2642",{"id":195,"body":196,"status":6,"type":122,"date":197,"slug":198,"title":199,"image":200,"countries":201,"topic":203,"activity":205,"tags":206,"nid":207,"topics":208,"activities":210,"authors":211,"images":212,"websites":213,"area":23,"programme":23,"language":23,"translations":214,"translation_of":23,"user_created":41,"date_created":215,"user_updated":115,"date_updated":216,"content":217,"link":218},10366,"Bulgaria has been undergoing a period of political instability, with five electoral cycles in the last two years. During this period, corruption has become a highly politicised topic. Efforts to curb it are now one of the most important campaign issues. \n\nIn addition, Bulgaria has the second highest levels of perceived corruption among EU member states according to Transparency International's [2022 Corruption Perceptions Index](https:\u002F\u002Fwww.transparency.org\u002Fen\u002Fcpi\u002F2022).\n\nBut what do different groups of people within Bulgaria really know and think about corruption and, more importantly, government efforts to address corruption in the country? Are they willing to report corrupt acts? If not, what would make them more likely to do so?\n\nUnderstanding these questions is vital to the successful development and implementation of anti-corruption laws and measures, such as the new [Whistleblower Protection Act](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Frolling-out-bulgarias-new-whistleblower-protection-act).\n\n### Digging deeper\n\nIn order to gain a deeper understanding of perceptions of corruption in the Bulgarian public, we conducted a nationwide survey from February to March 2023.\n\nLed by Dr Maria Thürk and Professor Stefanie Bailer of the University of Basel, the survey asked 1,209 respondents about their knowledge, perceptions and attitudes towards corruption and anti-corruption efforts in Bulgaria.\n\nRespondents were selected based on the quota sampling criteria of age, gender, education and place of residence, in order to ensure a sample which accurately represents the Bulgarian population. \n\n### Perceptions of corruption...\n\nThe survey results demonstrate a widespread perception of corruption in Bulgarian society and a strong desire to combat it. In brief:\n\n*   Our survey revealed that – no surprise! – corruption is considered to be a pressing problem in the country. Respondents named it second most frequently as the most important problem in Bulgarian society, following inflation.\n*   People of all different genders, ages, educational backgrounds and places of residence perceive corruption as being widespread in Bulgaria.\n*   Respondents are strongly against acts of corruption, especially grand corruption, and consider them unacceptable.\n*   The sector which is perceived as most affected by corruption is the judicial system. However, many other sectors are perceived as being highly affected by corruption.\n\n### ...and of anti-corruption efforts\n\nWe also uncovered deep scepticism about the effectiveness of government efforts to combat corruption:\n\n*   Respondents are considerably critical of political elites' efforts to fight corruption, with significant variation based on political party affiliation.\n*   Paradoxically, although the Bulgarian Public Prosecutor is the most frequently selected institution to lead the fight against corruption, respondents stated they have very little trust in the Public Prosecutor or, as mentioned above, the judicial system as a whole.\n*   Only about one-third of respondents are likely to report incidents of corruption, with a higher likelihood among younger and higher educated individuals.\n*   The lower the effort required to report acts of corruption – and the lower the risks involved – the more likely respondents say they are to report corruption.\n\nWe hope the survey serves its purpose as an important source of information for policymaking and governmental communication efforts in the fight against corruption in Bulgaria, as well as our team's support to Bulgarian partners under an [MoU signed in May 2022](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fnew-agreement-government-bulgaria-strengthen-anti-corruption-and-asset-recovery-efforts).  \n\n### More\n\n*   View and download the survey report in English and Bulgarian: [Working Paper 44 – Perceptions of corruption and anti-corruption efforts in Bulgaria](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-44)\n*   The survey was conducted by with operational support from Global Metrics in Bulgaria. The research was made possible by the support of the Swiss Agency for Development and Cooperation (SDC) under the Swiss-Bulgarian Cooperation Programme and of the American people through the United States Agency for International Development (USAID).","2023-05-30","how-do-bulgarians-perceive-of-corruption-and-anti-corruption-efforts-results-of-a-new-study-2453","How do Bulgarians perceive of corruption and anti-corruption efforts? Results of a new study","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F390338d8-5345-474c-a4cd-6d5063c18f4e?width=1000&height=650&format=webp&quality=80",[202],7183,[204],"Asset Recovery",[17,18],[],2453,[209],"Asset Recovery and Enforcement",[17,18],[],[],[25],[],"2023-05-30T08:57:09.000Z","2026-05-29T22:22:26.000Z",[],"\u002Fresources\u002Fnews\u002Fhow-do-bulgarians-perceive-of-corruption-and-anti-corruption-efforts-results-of-a-new-study-2453",{"id":220,"body":221,"status":6,"type":10,"date":222,"slug":223,"title":224,"image":225,"countries":226,"topic":228,"activity":229,"tags":230,"nid":231,"topics":232,"activities":233,"authors":234,"images":236,"websites":237,"area":23,"programme":23,"language":23,"translations":238,"translation_of":23,"user_created":41,"date_created":239,"user_updated":115,"date_updated":240,"content":241,"link":242},10350,"In a speech at the [Anti-Corruption and National Security policy forum](https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F2405) in Sofia, Bulgaria, the Basel Institute's President Peter Maurer commended how the Summit for Democracy is finally putting corruption at the centre of the debate about global peace and stability. He called on leaders in government, civil society and the private sector to work together to turn their commitments into action.\n\nThe event was co-hosted by the Ministry of Justice of Bulgaria, the Basel Institute on Governance and the Center for the Study of Democracy. The three institutions co-lead the Summit for Democracy's [Democratic Cohort on Anti-Corruption Policies](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fanti-corruption-centre-stage-summit-democracy).\n\nPeter Maurer's address followed opening remarks by Bulgaria's President Rumen Radev and short speeches by other leading voices on anti-corruption, peace and democracy.\n\n> President Radev\n> \n> Honourable Ministers\n> \n> Excellencies\n> \n> Ladies and gentlemen, dear colleagues\n> \n> It is my pleasure to address this distinguished audience of political leaders, policy makers and practitioners that have gathered in Sofia.\n> \n> I wish to start by thanking the Government of Bulgaria for bringing us together and for leading this important cohort on anti-corruption policies in the context of the Summit for Democracy.\n> \n> The Summit for Democracy has kickstarted valuable discussions about the challenges that lie at the heart of some of today’s most pressing global issues. This engagement is particularly welcome at a time when multilateralism is under severe stress.\n> \n> At the Basel Institute, we appreciate the fact that corruption has been recognised as central to this debate.\n> \n> For too long, corruption has been treated as a technical problem to be solved by experts and limited to development contexts.\n> \n> By putting corruption squarely at the centre of the debate about global peace and stability, we are finally recognising its global dimensions. And we are acknowledging that technical solutions are not enough, but rather need unwavering political leadership at the highest level to stand a chance to reduce the devastating effect that corruption has on our world.\n> \n> And this is what is important about today’s event:\n> \n> Firstly, that it is bringing together political leaders from countries of the region to commit to implementing more effective anti-corruption policies.\n> \n> Secondly, that the countries represented today are committed to working together in the region and with countries from across the world.\n> \n> Corruption is not a problem of the few and it is not only a local phenomenon.  \n> \n> I would like to briefly reflect on the example of Bulgaria, with which we have worked for over a year now on strengthening its anti-corruption policy framework. In line with its aspirations to join the Schengen Area, the Eurozone and OECD, we have seen important multi-party efforts resulting in the adoption of the Whistleblower Protection Act, as well as numerous other initiatives which are under way.\n> \n> As we commend Bulgaria for these important efforts, we need further discussions on the way forward and how to leverage anti-corruption measures for a more equitable distribution of public resources, better quality of public services, safer roads, healthier businesses, and ultimately, higher trust in our public institutions and in the fundamental principles of democracy.\n> \n> At the same time, I want to emphasise that adopting laws and policies is not enough. It’s the implementation gap that has been slowing us down and which should be the focus of this gathering.\n> \n> What does that mean?\n> \n> *   We need to resource the responsible agencies properly.\n> *   We need to ensure they can operate independently and without interference and that staff do not have to fear reprisal or intimidation for doing their jobs.\n> *   Beyond that, it is vital that we implement the policies transparently and that we give civil society and the media the space and information that they need to be critical partners and play their role.\n> *   We also need to bring the private sector more prominently into our discussions. I am glad to see that we have a session later today dedicated to Collective Action and private-sector engagement. The best chance to growing our countries is through clean investments, fair competition and evidence-based innovation.\n> \n> The anti-corruption cohorts under the Summit for Democracy are an excellent illustration of the importance of multi-stakeholder engagement to combat corruption. The leaders of the two cohorts that we have supported – Bulgaria and Moldova – have both demonstrated foresight by reaching out to partners from civil society and academia in the very early stages of the Year of Action.\n> \n> In Bulgaria, this was the case with initial partners from the Office of the Prime Minister and now with the Ministry of Justice and our esteemed colleagues from the Center for the Study of Democracy. In Moldova, we have had the privilege of working alongside the Office of the President and the National Anti-Corruption Centre, together with our longstanding partners from Transparency International.\n> \n> In both cohorts, we have engaged in a truly collaborative effort, I would like to express our sincere thanks to our partners for this.\n> \n> With the Basel Institute on Governance, we remain committed to working with partners, in building resilient networks against corruption and thus pathways to a safer, more prosperous and more equitable future.\n> \n> Once again, let me express our appreciation to the Government of Bulgaria and our partners for bringing us together today. I wish you fruitful deliberations and look forward to hearing back from my team how we can take commitments forward into action.\n> \n> Thank you.\n\n### Learn more\n\n*   See more information about [anti-corruption under the Summit for Democracy](http:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fanti-corruption-centre-stage-summit-democracy)\n*   Watch a [short video produced by the two anti-corruption cohorts](https:\u002F\u002Fwww.youtube.com\u002Fwatch?v=8x-quSAziwE): Anti-Corruption Policies and International Cooperation for Anti-Corruption. It features short statements by the co-leaders:\n    *   Gretta Fenner, Managing Director, Basel Institute on Governance\n    *   Krum Zarkov, Minister of Justice of Bulgaria\n    *   Iulian Rusu, Director, National Anti-Corruption Centre, Moldova\n    *   Ruslan Stefanov, Program Director, Center for the Study of Democracy\n    *   Daniel Eriksson, CEO, Transparency International","2023-03-22","fighting-corruption-for-global-peace-and-stability-peter-maurer039s-speech-at-summit-for-democracy-event-in-bulgaria-2410","Fighting corruption for global peace and stability – Peter Maurer's speech at Summit for Democracy event in Bulgaria","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F2d4ef615-1fb6-4dfd-9977-302c40638d65?width=1000&height=650&format=webp&quality=80",[227],7191,[14],[132,19,133],[],2410,[],[132,19,133],[235],1142,[],[25],[],"2023-03-22T11:01:30.000Z","2026-04-15T22:28:51.000Z",[],"\u002Fresources\u002Fnews\u002Ffighting-corruption-for-global-peace-and-stability-peter-maurer039s-speech-at-summit-for-democracy-event-in-bulgaria-2410",{"id":244,"body":245,"status":6,"type":10,"date":246,"slug":247,"title":248,"image":249,"countries":250,"topic":251,"activity":252,"tags":253,"nid":258,"topics":259,"activities":260,"authors":261,"images":262,"websites":23,"area":23,"programme":23,"language":164,"translations":263,"translation_of":23,"user_created":41,"date_created":264,"user_updated":115,"date_updated":265,"content":266,"link":275},10607,"Corruption is not just a collection of isolated acts by individuals. It is a complex, adaptive system that evolves in response to efforts to control it. And seeing it this way opens up new possibilities to tackle it more effectively.\n\nThis was the central message of a recent Basel Institute on Governance research webinar exploring how corruption evolves and what this means for designing interventions that remain effective over time.\n\nTwo senior researchers from the Basel Institute's Prevention, Research and Innovation – Dr Claudia Baez Camargo and Dr Jacopo Costa – were joined by Dr Maria Nizzero, Head of Sanctions Policy at UK Finance and Associate Research Fellow at RUSI, to explore corruption's networked nature and its implications.\n\nThese implications are practical as much as conceptual. Understanding corruption as a networked, adaptive system changes how corruption, organised crime, sanctions evasion and related threats need to be addressed in practice.\n\n### Corruption as a dynamic system\n\nA recent [academic paper](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fconceptualizing-evolution-corruption-empirical-analysis-italy) by Dr Baez Camargo and Dr Costa highlights a key gap in how corruption is typically analysed. While it is widely accepted that corrupt and criminal strategies change over time, the mechanisms driving that change have received far less attention.\n\nTheir analytical framework suggests that corruption evolves through changes in the behaviour of individuals within networks, shaped by shifts in the broader environment. These shifts may include stronger enforcement, legal and regulatory reforms, technological developments, or wider political and economic change. When new strategies prove effective, they spread across networks through collaboration, brokerage and imitation.\n\nA case study of Italy illustrates this process. In the early 1990s, corruption operated through relatively centralised, pyramidal structures linked to political parties. Over time, following scandals, reforms and increased scrutiny, this system became more fragmented and decentralised. Corrupt practices moved away from formalised exchanges and became more networked, informal and embedded in relationships.\n\nThe outcome was not less corruption, but different corruption.\n\nAs Dr Costa noted, corruption and anti-corruption are engaged in an “uninterrupted dance”, in which “very often, corrupt actors are two steps ahead of us”.\n\n### The concept of the “kleptocratic enterprise”\n\nLooking at corruption through a network lens also opens up new ways of thinking about how to tackle it.\n\n[Research by Dr Nizzero and co-authors](https:\u002F\u002Fgiace.org\u002Fwp-content\u002Fuploads\u002F2026\u002F01\u002FGIACE_Kleptocratic-Enterprises_NizzeroHeathershawMayne.pdf) Professor John Heathershaw and Professor Tom Mayne highlights the persistent challenges of asset recovery and enforcement in cases of large-scale corruption. Illicit wealth is often concealed through complex ownership structures, dispersed across jurisdictions and distanced from its original source over time. Legal frameworks may exist, but applying them effectively remains difficult.\n\nA key part of the problem lies in the role of professional service providers. Lawyers, accountants, real estate actors, company service providers and others help move, manage and shield assets. These actors often operate across borders and may serve a wide range of clients, including both organised crime groups and politically exposed individuals.\n\nThis has led to the idea of a “kleptocratic enterprise”: a networked system in which clients demand services such as concealment and asset protection, and a range of actors supply those services. Viewing corruption in this way shifts attention towards patterns of conduct, relationships and enabling structures.\n\nIt also suggests that tools used to tackle organised crime, such as anti-racketeering or anti-mafia approaches, may offer useful insights. These frameworks often focus on networks rather than individuals, combine multiple legal tools and allow for a broader understanding of harm, including the impact on society.\n\nAt the same time, responses must remain grounded in due process and the rule of law. Stronger measures can create new risks, including displacement of illicit activity to other jurisdictions or unintended consequences linked to overreach. The challenge is to expand the toolkit without compromising core legal principles.\n\n### When enforcement creates new risks\n\nField research by the Basel Institute under the EU-funded [FALCON project](https:\u002F\u002Fwww.falcon-horizon.eu\u002F) shows how quickly corrupt and criminal networks adapt to enforcement pressure.\n\nAt the [Port of Rotterdam](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-58), increased inspections and surveillance aimed at tackling drug trafficking made insider access more valuable. Corruption became a critical mechanism for bypassing strengthened controls, illustrating how enforcement can shift incentives in ways that reinforce the role of corruption.\n\nAt the Kapitan Andreevo border crossing between Bulgaria and Turkey, changes linked to EU accession, including new regulatory frameworks and stronger border controls, were followed by new forms of corruption and criminal activity. These included routinised extractive practices, shifts in smuggling strategies and the emergence of new actors.\n\nAcross both cases, the pattern is consistent. Measures designed to reduce corruption and illicit activity can reshape how those activities are organised and carried out.\n\n### Why networks are so resilient\n\nOne reason corruption adapts so effectively lies in the nature of the networks themselves.\n\nAs Dr Baez Camargo explains, enforcement-focused approaches can become a “whack-a-mole game” when underlying incentives remain unchanged. Efforts to close one avenue often lead to the emergence of another.\n\n[Informal networks](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-23-informal-networks-and-anti-corruption) are particularly resilient because they are built on more than financial exchange. Trust, personal relationships and shared social norms play a central role. These elements are difficult to detect, harder to regulate and highly adaptable.\n\nCriminal and corrupt networks are also flexible and opportunistic. They can shift strategies, routes and methods quickly, drawing on significant resources and expertise. Formal institutions, by contrast, operate within legal and procedural constraints, which can limit their ability to respond at the same pace.\n\n### Towards more adaptive responses\n\nIf corruption behaves like a complex adaptive system, anti-corruption efforts need to reflect that reality.\n\nOne emerging approach is to place greater emphasis on understanding systems rather than focusing narrowly on individual interventions. This involves mapping relationships, incentives and behavioural patterns in much greater depth, and remaining alert to how these evolve over time.\n\nIt also requires a shift away from strictly linear theories of change. Fixed indicators and predefined outcomes can miss important developments, particularly when systems are dynamic and interconnected. A more flexible approach allows practitioners to identify early signals of change, whether positive or negative, and adjust their strategies accordingly.\n\nAs Dr Baez Camargo puts it, “we cannot keep thinking that change is linear”. A better understanding of systems, combined with the ability to detect and respond to change, is essential for staying relevant in rapidly evolving contexts.\n\n### A shift in perspective\n\nTaken together, these insights point to a broader conclusion. Corruption is not static, and responses to it cannot be static either.\n\nUnderstanding corruption as a networked, adaptive system changes how problems are defined and how solutions are designed. It brings greater attention to relationships, incentives and enabling structures. It also highlights the importance of anticipating how systems will respond to interventions.\n\nFor practitioners working on corruption, organised crime or related risks, this shift is increasingly important. Integrating it into programming should help us not only respond more quickly as corruption adapts – i.e. whack the moles more rapidly when they pop up. It should also help us design flexible, creative and context-sensitive interventions that can genuinely disrupt these resilient illicit networks and themselves adapt to remain effective over time.\n\n### Learn more\n\n*   [Conceptualizing the evolution of corruption: an empirical analysis from Italy](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fconceptualizing-evolution-corruption-empirical-analysis-italy), by Dr Jacopo Costa and Dr Claudia Baez Camargo.\n*   [Corruption as a facilitator of drug trafficking in the port of Rotterdam](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-58), by Dr Saba Kassa and Dr Jacopo Costa \n*   [The Kleptocratic Enterprise: Lessons from organised crime to target transnational corruption and strengthen asset recovery in the UK](https:\u002F\u002Fgiace.org\u002Fwp-content\u002Fuploads\u002F2026\u002F01\u002FGIACE_Kleptocratic-Enterprises_NizzeroHeathershawMayne.pdf), by Dr Maria Nizzero, Professor John Heathershaw and Professor Tom Mayne\n\n### Webinar recording\n\n\u003Ciframe allowfullscreen=\"\" frameborder=\"0\" height=\"315\" src=\"https:\u002F\u002Fwww.youtube.com\u002Fembed\u002FETQto16U_q4?si=yrjbtCTRmQ5ceTPo\" title=\"YouTube video player\" width=\"560\">\u003C\u002Fiframe>\n\nDisclaimer\n\n_This webinar and summary are part of the FALCON (Fight Against Largescale Corruption and Organised Crime Networks) project. FALCON is funded under the European Union’s Horizon Europe Framework Program Grant Agreement ID 101121281. The Basel Institute on Governance, as an associated partner without the right to receive funds directly from the European Research Executive Agency, has received funding from the Swiss State Secretariat for Education, Research and Innovation (SERI). The contents of this summary are the sole responsibility of the authors and do not necessarily reflect the views of the European Union, the European Research Executive Agency or SERI._","2026-03-25","corruption-is-a-complex-adaptive-network-what-does-this-mean-for-anti-corruption-policy-and-practice-2945","Corruption is a complex, adaptive network. What does this mean for anti-corruption policy and practice?","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Faf37ba1d-85e1-4724-ab47-4e58056330c6?width=1000&height=650&format=webp&quality=80",[],[92,93],[132,17],[254],{"tags_id":255},{"id":256,"name":257},982,"Anti-corruption",2945,[106],[132,17],[],[],[],"2026-04-15T22:45:18.000Z","2026-05-07T21:29:58.000Z",[267,268,269,270,271,272,273,274],1,2,3,4,5,6,7,8,"\u002Fresources\u002Fnews\u002Fcorruption-is-a-complex-adaptive-network-what-does-this-mean-for-anti-corruption-policy-and-practice-2945",{"id":277,"body":278,"status":6,"type":10,"date":279,"slug":280,"title":281,"image":282,"countries":283,"topic":287,"activity":288,"tags":290,"nid":293,"topics":294,"activities":295,"authors":296,"images":297,"websites":298,"area":23,"programme":23,"language":23,"translations":299,"translation_of":23,"user_created":41,"date_created":300,"user_updated":42,"date_updated":8,"content":301,"link":302},10421,"Corruption was on the main programme of the [Munich Security Conference](https:\u002F\u002Fsecurityconference.org\u002Fen\u002F) on 16–18 February 2024 for the first time.\n\nGretta Fenner, Managing Director of the Basel Institute on Governance, moderated a panel discussion featuring Bernardo Arévalo, President of Guatemala, Nikolai Denkov, Prime Minister of Bulgaria, Ketakandriana (Ke) Rafitoson, Vice Chair of Transparency International and Sheldon Whitehouse, U.S. Senator and Chairman of the Senate Committee on the Budget.\n\nThe main challenge in Gretta Fenner’s closing words, referring to the theme of this year’s [conference report “Lose-Lose](https:\u002F\u002Fsecurityconference.org\u002Fpublikationen\u002Fmunich-security-report-2024\u002F)”:\n\n> _“If we do not understand, acknowledge and then act accordingly in relation to the critical role of corruption undermining everything to do with stability, global governance and international law, we will have a lose-lose situation. And we cannot allow that to happen.”_\n\n### Beyond classical corruption\n\nThe Munich Security Conference's decision to include corruption as a “spotlight” in the conference programme, together with other non-traditional security topics such as sexual violence, climate finance and mineral supply chains, was highly welcome. It coincides with a rise in recognition and concern over strategic or \"weaponised\" corruption as a threat to national, regional and global security and peace.\n\nAs Fenner emphasised at the outset, corruption even in the narrow sense of bribery must be of great concern to the defence and security community. When kickbacks or other bribery schemes lead to the purchase of the wrong military equipment, to the construction of substandard infrastructure, or to half the ordered ammunition missing, it has direct and potentially deadly consequences.\n\nWhat we must also talk about more is the use of corruption for longer-term (geo) strategic goals. In other words, when corruption is used as an instrument – indeed a weapon – of power and influence at home and abroad. And when, as a consequence, it completely evades and thereby undermines global governance and international law.\n\nThe result, in the words of Ke Rafitoson, is _“an escalation of violence and conflicts around the world.”_ Corruption has long been seen as a _“soft governance”_ issue, she said, but now: \n\n> _“We have to recognise that corruption has become a global threat.”_\n\n### Vicious cycle: state capture and transnational organised crime\n\nTake just about any case of state capture – when power is consolidated in the hands of a few elites, who misuse state institutions to serve their own narrow purposes – and you can trace how [corruption is wielded as a highly functional tool](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fhow-strategic-corruption-fuels-insecurity-affecting-power) to gain and preserve power and influence.\n\nThat pattern is clearly visible in Guatemala, where President Arévalo’s recent election success owes much to popular unrest over corruption and to his personal anti-corruption campaigning. Corruption has penetrated every arm of the state over the last 20 years, he explained. Money stolen through corruption is used to empower criminal elites, who then further capture the political system in order to extract more rents – and on it goes in a vicious circle.\n\nThat has serious implications on peace and stability far beyond Guatemala as it emboldens and empowers transnational organised crime, he said, including the trafficking of drugs, humans and wildlife.\n\n> _“When you have corrupt officials, they are quite open to the type of big-money incentives that transnational organised crime can put on the table. On the other hand, transnational organised crime is interested in pushing politicians into office.”_\n\nIn the end, you find the entire governance of countries is in the hands of corrupt actors and of criminal groups. Driven by the transnational nature of organised crime, this can quickly lead to entire regions descending into a vicious circle of illegitimate governance and crime, and eventually into ever greater instability and violence.\n\n### Control over critical sectors\n\nMuch concern over strategic uses of corruption for geopolitical purposes also centres on foreign states gaining influence over sectors that are critical for sovereignty, security and stability, such as energy, water and minerals. Historical links and geographical proximity to kleptocratic states increase a country’s vulnerability.\n\nBulgaria has recently struggled with exactly that phenomenon. Noting parallels with Guatemala’s experience of state capture and organised crime, Prime Minister Denkov emphasised that corruption was not just used as a way for individuals to make money for narrow personal gain:\n\n> _“Along with classical corruption schemes, you have another type of corruption at a huge scale that affects all aspects of our lives.”_\n\nRussia-related energy deals in Bulgaria have wasted more than a billion euros, Denkov said, and resulted in little except total energy dependence on the aggressive autocratic Russian regime. It is clearly a security concern when corrupt deals result in a foreign state gaining power over critical sectors such as energy – not least when they involve sensitive installations such as nuclear power plants.\n\nOn the positive side, an anti-corruption focus is leading Bulgaria towards a much brighter future, not only in terms of its energy independence but also more broadly in terms of the quality of its governance, of rule of law and of its role in protecting the Euro-Atlantic alliance. In the last two years, with parties in government who subscribe to the fight against corruption, the country has succeeded in removing oil and gas dependence with strategic and transparent energy arrangements. It is also working persistently towards freeing other sectors from state capture.\n\nBulgaria’s example shows how political commitments to transparency, participation and anti-corruption can help countries loosen the grip of corrupt states on sectors critical to their security.\n\n### How anti-corruption and security communities can join forces\n\nAnti-corruption and defence\u002Fsecurity communities often work in bubbles, but closer collaboration could bring benefits to both sides.\n\n#### Anti-corruption tools and knowledge\n\nDespite legitimate concerns about foreign power and influence through corruption, it’s not helpful to see corruption purely as a foreign threat. Many countries need to do more to prevent corruption and illicit financial flows _domestically,_ since these ultimately threaten both their own and global security.\n\nTried and tested anti-corruption tools are essential to get one’s own house in order. Senator Whitehouse gave a powerful description of how the U.S. introduced a series of anti-corruption reforms following the realisation that:\n\n> _“We were the problem. The greatest location for hiding corruptly obtained assets was the United States of America. So we began to take that apart.”_\n\nApart from basic transparency measures like beneficial ownership registers, priorities for many states should include cracking down on enablers such as unscrupulous lawyers and accountants. These are often based in high-income jurisdictions but are key to [enabling corruption in other countries](https:\u002F\u002Fwww.transparency.org\u002Fen\u002Fpublications\u002Floophole-masters).\n\nSenator Whitehouse also testified to the usefulness of working with civil society in devising and implementing the anti-corruption reforms.\n\nLikewise, in general security policy making could benefit greatly from the knowledge and analysis of specialist anti-corruption organisations whose understanding of connections between corruption and security, and related data, facts and [reports](https:\u002F\u002Fti-defence.org\u002F), can support security-related decision making.\n\n#### Embedding anti-corruption across the functions of state\n\nBeyond applying tools in specific areas, panellists concluded that states need to embed anti-corruption as a strategic priority across all aspects of security in its widest sense – from procurement to peace building to the development of strong and independent institutions.\n\nThe [U.S. designation of corruption as a core national security issue](https:\u002F\u002Fwww.whitehouse.gov\u002Fbriefing-room\u002Fpresidential-actions\u002F2021\u002F06\u002F03\u002Fmemorandum-on-establishing-the-fight-against-corruption-as-a-core-united-states-national-security-interest\u002F) has helped to _“put corruption higher up the agenda,”_ said Senator Whitehouse. This is vital because, as President Arévalo also emphasised:\n\n> _“We were used to corruption being a problem of bad administration…. Now we are seeing political criminal cliques organising to take control of state institutions in order to make them work for corruption. This is a fundamental threat to the viability of democratic states. It is beyond a threat to the security establishment.”_\n\nUkraine’s experience also shows that anti-corruption needs to be elevated as a core and state-wide security issue. Reacting to the panel discussion, Ukrainian anti-corruption activist Hanna Hopko explained that while Ukraine has made significant progress on fighting corruption since the 2014 Maidan Revolution, the illegal invasion of Ukraine by Russia has propelled corruption to the top of the country’s priorities:\n\n> _“Russia’s aggression against Ukraine has redefined the struggle against corruption. In the past, we considered the fight against corruption to be about… eliminating kickbacks, \\[money laundering in\\] offshore jurisdictions, vanity construction projects… \\[Now\\] it is crystal clear that without strong institutions, producing strong policies and implementing them, anti-corruption means nothing.”_\n\nIn other words, Ukraine can only win this war if it wins the war against corruption and builds strong, independent institutions resilient to external attempts to corrupt and control them.\n\n### A tough fight ahead\n\nGuatemala and Bulgaria are just two countries facing a tough fight ahead to dismantle corrupt systems and create a well-governed state that works for the people. Legal reforms are important but not sufficient, stressed Denkov.\n\n> _“You have to have the people. It is not only the leaders. In every position you have to have a person who is willing to fight every day.”_\n\nThose people will need a lot of energy, said Senator Whitehouse:\n\n> _“For the corruption machine, maintaining corruption is life or death. You take away their corruption, there goes their money, there goes their power, their limousines, there goes everything. So they fight to defend it with determination…. The energy and persistence and determination of the corrupt needs to be matched by similar energy, persistence and determination of those trying to root out corruption.”_\n\nAnd that energy can only come from the recognition that corruption is, according to _“is no longer \\[just\\] a nuisance. It is a direct political threat,”_ according to President Arévalo.\n\n> “_Until we do not recognise that, we are not going to really be able to muster the energy, imagination and commitment at the international level to fight corruption effectively.”_\n\n### Learn more\n\n*   See the [full recording](https:\u002F\u002Fsecurityconference.org\u002Fmsc-2024\u002Fagenda\u002Fevent\u002Fspotlight-corruption\u002F) on the Munich Security Conference website.\n*   See related articles on [corruption and peace building](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Ffighting-corruption-promote-peace-and-security-basel-peace-forum-2024) and on [how corruption fuels insecurity by affecting power](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fhow-strategic-corruption-fuels-insecurity-affecting-power).","2024-02-21","the-changing-face-of-corruption-and-security-munich-security-conference-2024-2588","The changing face of corruption and security: Munich Security Conference 2024","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F206ae2d8-12c3-44d3-a203-8fdd1171bdde?width=1000&height=650&format=webp&quality=80",[284,285,286],7132,7133,7134,[14],[132,289],"Presentations",[291],{"tags_id":292},{"id":98,"name":99},2588,[],[132,289],[],[],[25],[],"2024-02-21T11:01:31.000Z",[],"\u002Fresources\u002Fnews\u002Fthe-changing-face-of-corruption-and-security-munich-security-conference-2024-2588",{"id":304,"body":305,"status":6,"type":10,"date":306,"slug":307,"title":308,"image":309,"countries":310,"topic":311,"activity":313,"tags":314,"nid":319,"topics":320,"activities":321,"authors":322,"images":324,"websites":325,"area":23,"programme":23,"language":23,"translations":326,"translation_of":23,"user_created":41,"date_created":327,"user_updated":115,"date_updated":328,"content":329,"link":330},10532,"_This article is adapted from the_ [_2024 Basel AML Index public report_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024)_._\n\nFinancial crime has far-reaching impacts on people’s lives. Yet often the only time it draws serious attention in the media is when a country is added to the [FATF’s grey list](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fcountries\u002Fblack-and-grey-lists.html). This designation of “jurisdictions under increased monitoring” frequently sparks debate and concern, and is clouded by misconceptions. This section looks at five common myths that we come across in our work to support partner countries seeking to avoid or leave the grey list.\n\n### Myth 1: The grey list = high-risk countries\n\nA common misconception about the FATF grey list is that it represents (the only) countries and jurisdictions that pose high risks for money laundering, terrorist financing and proliferation financing.\n\nIn fact, in the FATF’s own words, the grey list is the public list of jurisdictions that are “actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.” It is the FATF’s black list that specifically identifies high-risk countries and calls for enhanced due diligence and\u002For countermeasures when dealing with these.\n\nThe distinction is important because not all grey-listed countries pose the same level or type of risk. Many are on a rapid path to improvement. Not all will require enhanced due diligence. And some countries that are not and never have been on the grey list may still present significant risks.\n\nInclusion on the grey list is based on the FATF's [International Co-operation Review Group](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FHigh-risk-and-other-monitored-jurisdictions\u002FMore-on-high-risk-and-non-cooperative-jurisdictions.html) (ICRG) process and on the criteria summarised under Myth 2, rather than merely on its own criteria for identifying a higher-risk country (see box below).\n\nA complicating factor for financial institutions seeking to identify clear criteria for applying enhanced due diligence is the use of both the black and grey lists by the EU and UK for their own lists of high-risk third countries.\n\n> What is a higher-risk country?\n> \n> The Interpretative Note to the FATF’s [Recommendation 10](https:\u002F\u002Fcfatf-gafic.org\u002Fdocuments\u002Ffatf-40r\u002F376-fatf-recommendation-10-customer-due-diligence) on customer due diligence sets out guidelines on country or geographic risk factors that might trigger the application of enhanced due diligence according to a risk-based approach. The criteria (note 15b) refer to countries that are “identified by credible sources” as having inadequate AML\u002FCFT systems, high levels of corruption and crime or high levels of terrorist activity and financing, or that are subject to sanctions or similar measures. It does not specifically refer to either the grey list or the black list, though this may be one factor that organisations take into account.\n> \n> Similarly, [Recommendation 19](https:\u002F\u002Fwww.cfatf-gafic.org\u002Fdocuments\u002Ffatf-40r\u002F385-fatf-recommendation-19-higher-risk-countries) on higher-risk countries and its Interpretative Note require enhanced due diligence by financial institutions to be applied only to countries “for which this is called for by the FATF”, indicating the black list of jurisdictions subject to a call for action.\n\n### Myth 2: Grey listing is a surprise\n\nEach time the FATF holds a plenary session, commentators appear to “bet” which countries will be added or removed. This leads some to believe that grey listing comes as a surprise – even to a country’s authorities.\n\nIn fact, grey listing is based mainly on a country’s poor performance in its mutual evaluation report, specifically in one of four criteria:\n\n*   Fifteen or more non-compliant or partially compliant ratings for technical compliance in any Recommendation.\n*   A non-compliant or partially compliant rating for three or more of the following Recommendations: R.3 (money laundering offences), R.5 (terrorist financing offences), R.6 (targeted financial sanctions related to terrorist financing), R.10 (customer due diligence), R.11 (record keeping) and R.20 (reporting of suspicious transactions).\n*   A low or moderate level of effectiveness for nine or more of the 11 Immediate Outcomes, with a minimum of 2 low ratings.\n*   A low level of effectiveness for six or more of the 11 Immediate Outcomes.\n\nThe authorities typically have a year or more to work on their specific weaknesses without being publicly listed, under the FATF’s International Co-operation process.\n\nThe FATF also prioritises countries and jurisdictions with significant financial centres. For the fifth round of evaluations, the threshold has been increased from USD 5 billion to USD 10 billion, measured in [broad money terms](https:\u002F\u002Fwww.oecd.org\u002Fen\u002Fdata\u002Findicators\u002Fbroad-money-m3.html).\n\nSo grey listing is rarely a surprise to the authorities. It is however less easy for third parties like financial institutions and foreign donors to predict whether a jurisdiction will end up on the grey list.\n\nOur [Expert Edition Plus](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) now offers subscribers an assessment of the risks that a particular country will end up on the grey list. This makes it possible to better anticipate this and prepare accordingly – including, we would recommend, by using the Basel AML Index to assess the broad range of factors contributing to a higher level of money laundering risk.\n\n### Myth 3: Grey listing has only negative impacts\n\nBeing added to the FATF grey list can trigger severe economic consequences for countries, especially low-income countries dependent on foreign investment and assistance. Investors and financial institutions may reduce their business in the country. A 2021 [IMF paper](https:\u002F\u002Fpapers.ssrn.com\u002Fsol3\u002Fpapers.cfm?abstract_id=4026331) found that capital inflows decline on average by 7.6 percent of GDP following grey listing, for example.\n\nFinancial institutions may also “de-risk” completely – cutting off all business to avoid the extra compliance and risk management costs. Individuals and businesses may have challenges accessing financial services as a result, leading to lower financial inclusion. Other [unintended consequences](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12) may include an increase in the use of less regulated channels to move money.\n\nNegative economic consequences are not inevitable, however, especially for more developed economies. [Croatia’s economy and its financial sector](https:\u002F\u002Fwww.imf.org\u002Fen\u002FPublications\u002FCR\u002FIssues\u002F2024\u002F07\u002F26\u002FRepublic-of-Croatia-2024-Article-IV-Consultation-Press-Release-and-Staff-Report-552561), for example, both appear to be relatively unscathed by its placement on the grey list in 2023. S&P Global even [upgraded](https:\u002F\u002Fdisclosure.spglobal.com\u002Fratings\u002Fen\u002Fregulatory\u002Farticle\u002F-\u002Fview\u002Ftype\u002FHTML\u002Fid\u002F3250133) its long-term sovereign credit rating from BBB+ to A- in September 2023.\n\nWould it have done even better if it hadn’t been grey listed? It is hard to know – but in some cases perhaps being grey listed could even help a country’s performance in the long run, by motivating it to conduct necessary reforms quickly. For example, Iceland and Malta both managed to leave the grey list after just a year, having speedily fulfilled the requirements of their action plans.\n\nFor countries receiving development aid, grey listing can bring the benefit of increased targeted assistance to implement reforms and eventually exit the grey list. However, since authorities are typically aware of the risk of grey listing in advance (see Myth 2), it would be more effective if this assistance were provided earlier to help prevent the country from being listed in the first place.\n\n### Myth 4: The grey-listing system is inherently unfair\n\nCritics of the grey-listing system point out that it unfairly penalises low-income jurisdictions with less capacity for AML\u002FCFT but also lower significance due to their small financial centres.\n\nIt is true that low-income countries are disproportionately represented on the grey list, but this is changing. More than half of grey-listed countries at the time of writing are in [Sub-Saharan Africa](https:\u002F\u002Findex.baselgovernance.org\u002Fapi\u002Fassets\u002Ff2c74bc1-2760-4bea-a118-aaa96b9cdf09), for example. Yet the addition of European countries in 2023 and 2024 – Bulgaria, Croatia and Monaco – shows that the geography is shifting.\n\nThe following figure shows the percentage of jurisdictions in each region on the grey list as of October 2024:\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2025-02\u002FGraphic%20regional%20percentage%20FATF%20grey%20list.png)\n\n[New prioritisation criteria](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfgeneral\u002FFATF-grey-listing-criteria.html) announced in October 2024 in effect apply a risk-based approach to grey listing. High-income countries and jurisdictions with financial centres over USD 10 billion will be prioritised. Least developed countries as defined by the UN will not be prioritised except in rare cases of high risk, in which case they will have a longer time period to work on their deficiencies before being grey listed.\n\nAs these changes take effect, we should see the grey-listing geography shift towards higher-income countries that are deeply integrated in financial markets.\n\nAnd there are some simple things that a country can do to avoid grey listing – namely, prepare well for the mutual evaluation process, which is always announced well in advance. Quite basic actions can help, like preparing an up-to-date [national risk assessment](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-26-national-money-laundering-and-terrorist-financing-risk-assessments) (and specific sectoral assessments where relevant), gathering statistical data and developing strategies to mitigate identified risks.\n\nThe Basel AML Index methodology does not penalise countries for being on the grey list, since the deficiencies that led to them being grey listed are already apparent in the mutual evaluation report data. In 2023, we also [updated our methodology](https:\u002F\u002Findex.baselgovernance.org\u002Fnews\u002Fbasel-aml-index-2023-reflecting-the-progress-of-grey-listed-jurisdictions-2513) to better capture improvements in the effectiveness of jurisdictions that exit the grey list, even if the FATF does not release new effectiveness data.\n\n### Myth 5: Leaving the grey list is the end of the story\n\nGrey listing is just one period in a country’s anti-money laundering journey. Being delisted is naturally a cause for celebration and hope, but it’s not the end of the story. Many jurisdictions have been grey listed more than once, including Cambodia, Nicaragua, Panama and Pakistan.\n\nFATF standards continue to evolve and to strengthen, so jurisdictions need to constantly improve in order to keep up.\n\nA prominent example highlighted in several Basel AML Index reports over the years is Recommendation 15 on virtual assets. After it was updated in 2018, almost all subsequently assessed jurisdictions [achieved lower levels of compliance](https:\u002F\u002Findex.baselgovernance.org\u002Fnews\u002Fvirtual-currencies-are-we-missing-a-trick-insights-from-the-basel-aml-index-2023-2541) than previously. We can expect a similar effect with the [updated Recommendations 4 and 38](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Ffatf-seeks-change-landscape-international-asset-recovery-what-means-latin-america) on asset recovery, where there are still some countries that do not meet basic criteria such as having a non-conviction based forfeiture law or enforcing international judgements based on these laws.\n\nThe FATF’s fifth round of evaluations will [emphasise effectiveness](https:\u002F\u002Fwww.fatf-gafi.org\u002Fcontent\u002Ffatf-gafi\u002Fen\u002Fpublications\u002FMutualevaluations\u002FFatf-methodology.html) over technical compliance. Countries will need to put in more effort to improve their effectiveness ratings, which are, on average, less than half as strong as their ratings for technical compliance.\n\nAs financial systems continue to evolve, criminals will find ever more ingenious ways to steal, launder and hide money or to use it for illicit purposes such as the financing of terrorism and weapons of mass destruction. Avoiding or graduating from the grey list is one step along a never-ending journey to a resilient system that successfully wards of money laundering and related threats while not limiting financial inclusion and innovation.\n\n### Learn more\n\n*   Read the [13th annual Public Edition report of the Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024).\n*   Explore the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F).","2025-02-06","fatf-grey-list-truth-and-myths-2760","FATF grey list: truth and myths","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F2397c564-394a-4f1e-8448-ec230a14810c?width=1000&height=650&format=webp&quality=80",[],[312,204],"Anti-Money Laundering",[19],[315],{"tags_id":316},{"id":317,"name":318},818,"Anti-money laundering",2760,[312,209],[19],[323],1090,[],[25],[],"2025-02-06T11:01:49.000Z","2026-05-29T22:22:34.000Z",[],"\u002Fresources\u002Fnews\u002Ffatf-grey-list-truth-and-myths-2760",{"left":332,"top":332,"width":333,"height":333,"rotate":332,"vFlip":334,"hFlip":334,"body":335},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>",1780676501354]