Publications
Research papers, case studies and quick guides
Quick Guide 43: Corruption sanctions
How can governments respond to serious corruption when those responsible are beyond the reach of the law?
Weak institutions, political protection or limited law enforcement capacity can make it difficult to investigate or prosecute powerful individuals suspected of corruption. In response, some governments have turned to corruption sanctions.
Corruption sanctions allow governments to impose restrictions on people suspected of serious corruption even without a criminal conviction.
This Quick Guide introduces corruption sanctions, explains how they work and highlights both their potential and the concerns they raise.
About this Quick Guide
You are free to share and republish this work under a Creative Commons BY-NC-ND 4.0 Licence. It is part of the Basel Institute on Governance Quick Guide series, ISSN 2673-5229.
Working Paper 62: Corruption sanctions: What governments need to know
How can governments respond to serious corruption when those responsible are beyond the reach of the law? Some governments have turned to corruption sanctions to address this issue.
This Working Paper examines how corruption sanctions – tools that allow governments to impose asset freezes and travel bans on individuals suspected of corruption without any finding of guilt in a court – have evolved over the past decade, and offers recommendations for their more effective and legitimate use.
Download the Working Paper hereAdvantages and limitations of corruption sanctions
Corruption sanctions emerged primarily to address situations where notoriously corrupt individuals enjoy impunity within their own legal systems. Their key strengths lie in their flexibility and versatility:
- they can be applied regardless of any geographical link between the sanctioning state and the alleged corruption, based on relatively low evidentiary thresholds; and
- they can serve a wide range of objectives – from disrupting and deterring corrupt activity to condemning corruption, facilitating asset recovery and signalling support for another country’s law enforcement efforts.
However, the paper also highlights important limitations. Corruption sanctions are often wielded without a clear post-imposition strategy. And: their inherent flexibility comes with due process trade-offs, including broad governmental discretion and limited judicial oversight.
Recommendations
Drawing on an extensive analysis of the experiences of key jurisdictions – including the US, UK, EU, Canada and Australia – the author puts forward nine recommendations for governments on how to design and maintain credible and effective corruption sanctions regimes. These include publishing clear criteria for high-priority targets, strengthening transparency around licensing and delisting decisions, and exploring sanctions against professional enablers in major financial centres.
The paper is aimed primarily at policymakers but will also be of interest to anti-corruption activists, private-sector financial crime specialists and academics.
About this paper
This paper is published as part of the Basel Institute on Governance Working Paper series, ISSN: 2624-9650. You may share or republish it under a Creative Commons BY-NC-ND 4.0 International Licence.
This is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.
The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
The Evolution of Corruption and Crimes at Kapitan Andreevo Border Checkpoint: The Impact of EU Accession
Published in the Journal of Illicit Trade, Financial Crime, and Compliance, this article examines how Bulgaria’s 2007 accession to the European Union transformed illegal activities and corruption at the Kapitan Andreevo border checkpoint.
While the introduction of stricter EU regulations and advanced surveillance technology aimed to secure the border, these measures had the effect of transforming criminal strategies and corruption. The authors detail a shift from blatant smuggling to more sophisticated financial frauds, VAT carousel schemes and the illicit privatisation of public border functions.
The article highlights that in some cases, it was the bribery schemes that evolved to bypass new standards. In other cases – particularly involving drug trafficking and the smuggling of human beings – it was the criminal strategies that transformed, including advanced concealment methods or new smuggling routes.
The study also offers a nuanced perspective on the relationship between corruption and criminal activites at border checkpoints: stronger capacity to counter criminal activities could lead to an increase in the risk of corruption, while a more coherent anti corruption framework could trigger criminal activities to evolve. Ultimately, the article argues that anti-crime and anti-corruption policies must account for this evolutionary nature.
Tackling the complexity of border corruption: How technological tools such as the project FALCON dashboard can support investigations
Corruption at land and sea borders facilitates smuggling, sanctions evasion, tax offences and the entry of counterfeit, substandard or unsafe goods into countries including EU member states. This report conceptualises border corruption as a complex system of actors, events and illicit exchanges that is difficult to detect and investigate.
Drawing on research from the Horizon Europe FALCON (Fight Against Large-scale Corruption and Organised Crime Networks) project, it explores how innovative technological tools – illustrated by the “FALCON dashboard” – can help investigators manage, visualise, interpret and report large volumes of heterogeneous data in support of more effective investigations.
About this report
You may share or republish this report under a Creative Commons CC BY-NC-ND 4.0 licence.
This report was written as part of the FALCON 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 document 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.
Preventing corruption in the timber value chain: Risk management experiences in Latin America
Corruption in the timber value chain is a major challenge for environmental sustainability and governance in Latin America.
This report presents the application of a corruption risk management approach by environmental authorities in Bolivia, Ecuador and Peru, implemented through technical assistance from the Basel Institute on Governance’s Green Corruption programme.
Key corruption risks
The report describes the main corruption risks identified in collaboration with five environmental authorities responsible for integrity in the timber value chain, covering:
- The granting of forestry rights
- The issuance and use of timber transport waybills
- The control and supervision of authorised actors.
The main corruption risks identified involve:
- Improper agreements between public servants and third parties
- Abuse of authority
- Undue influence or pressure from superiors
Mitigation measures
Planned mitigation measures fall into four main categories:
- Regulatory improvements, including updating procedures, closing implementation gaps and improving efficiency
- Strengthened supervision, such as file tracking systems and alerts to reduce discretion
- Enhanced communication, including multicultural approaches for Indigenous and rural communities
- Cross-cutting measures to promote integrity such as awareness-raising, ethical reflection and training
Given common patterns across natural resource sectors, these measures may be relevant for other environmental agencies, though they should be adapted to local contexts.
Lessons learned
The experiences in Bolivia, Ecuador and Peru highlight the importance of tailoring risk management approaches to national contexts, ensuring institutional leadership and fostering inter-institutional collaboration. They also underline the value of peer learning and cross-border exchange.
Case Study 13: The Beauty Queen case: non-conviction based forfeiture across borders
This Case Study analyses how Colombian authorities recovered assets linked to drug trafficking and held in a trust in Guernsey. It sets out the legal tools and procedures in Colombia and in Guernsey that enabled Colombia’s first international recovery under its non-conviction based forfeiture model Extinción de dominio. The Case Study highlights lessons for international cooperation between jurisdictions with different forfeiture systems or even legal traditions.
The International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance provided technical assistance as part of a Memorandum of Understanding with the General Prosecutor’s Office of Colombia.
On 30 November 2023, the Fourth Court of the Specialised Extinción de Dominio Circuit of Colombia ordered the non-conviction based forfeiture of a Guernsey trust account issued by Northern Trust Fiduciary Services (Guernsey) Limited. The beneficiary was María Marcela Serrano Camacho, a Colombian model and former beauty queen.
The Colombian forfeiture order extinguished property rights over the account – amounting to GBP 361,146 – on the grounds that the funds were the proceeds of drug trafficking offences committed by Efraín Antonio Hernández Ramírez (“Don Efra”), a well-known Colombian drug trafficker, and his former spouse María Serrano in the 1990s.
On 30 January 2025, following successful mutual legal assistance proceedings between Colombia and the Bailiwick of Guernsey, the two jurisdictions concluded an asset sharing agreement for the repatriation of the confiscated assets.
This marked Colombia’s first successful international recovery through non-conviction based forfeiture.
This Case Study examines how early and effective coordination between Colombia and Guernsey enabled the identification, freezing, forfeiture and repatriation of the assets. It analyses the legal framework underpinning Colombia’s Extinción de dominio regime and how it was applied, leading to the forfeiture of the Guernsey acccount. It also describes the procedural mechanisms used in Guernsey to execute foreign non-conviction based forfeiture orders.
The interaction between the authorities in both jurisdictions offers valuable lessons and examples of good practices.
Main takeaways of the case:
- Early and trust-based international cooperation is decisive
- Non-conviction based forfeiture is indispensable when criminal routes are closed
- Identifying beneficial ownership is central to effective asset recovery
- Direct enforcement of foreign forfeiture orders increases efficiency and legal certainty
- Asset sharing agreements strengthen cooperation incentives
The Case Study can be read alongside Policy Brief 16: “Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres”.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BYNC-ND 4.0).
The Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery.
This is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.
Disclaimer: This Case Study is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. The contents are the sole responsibility of the authors and do not necessarily reflect the views or the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Policy Brief 16: Enforcing foreign non-conviction based forfeiture orders
This Policy Brief analyses emerging international standards aimed at addressing recurring challenges in judicial practice with regard to the enforcement of non-conviction based forfeiture orders issued by foreign states. It focuses in particular on the historical absence of a binding obligation on requested states to cooperate in such cases and, where cooperation is available, on the structural tension between direct and indirect enforcement models.
Revisions in 2023 to the Financial Action Task Force (FATF) Recommendations 4 and 38 seek to clarify and strengthen states’ cooperation in the enforcement of foreign forfeiture orders. In this context, the recognition and execution of foreign non-conviction based forfeiture orders are central components of the evolving international asset recovery framework.
Through analysis and case studies involving Latin American states and international financial centres, this Policy Brief demonstrates that the choice of procedural model for enforcing foreign forfeiture orders – direct or indirect – has significant implications, while acknowledging the competing legal and institutional interests involved.
In line with FATF Recommendation 38, the Policy Brief argues in favour of direct enforcement in the requested state, based on the facts established by the foreign authority. This promotes efficiency, legal certainty and mutual trust. Indirect enforcement models that may require domestic investigations by the requested state, on the other hand, often lead to delays, duplication and increased costs, which hinders international asset recovery efforts.
The analysis provides empirical insight into how the revised FATF standards address practical deficiencies and the implications for judicial practice in requested states. For the Latin American context, the Policy Brief suggests to go beyond technical compliance of domestic non-conviction based forfeiture regimes with the FATF standards to strengthen the effectiveness of cross-border enforcement in practice.
This Policy Brief can be read alongside Case Study 13: “The Beauty Queen case: non-conviction based forfeiture across borders. Lessons learned from Colombia–Guernsey cooperation.”
About this Policy Brief
This publication is part of the Basel Institute on Governance Policy Brief series ISSN 2624-9669. You may freely share or republish it under a Creative Commons BY-NC-ND 4.0 licence.
It is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.
Disclaimer: This Policy Brief is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Suggested citation: Solórzano, Oscar. 2026. “Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres.” Policy Brief 16, Basel Institute on Governance. Available at: baselgovernance.org/publications/pb-16.
Case Study 14: Madagascar: a landmark conviction for money laundering linked to environmental crime
This Case Study demonstrates how international cooperation and the follow-the-money approach revealed a transnational criminal network trafficking endangered species and led to Madagascar’s first money laundering conviction related to wildlife trafficking.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
Photo: Studio Sifaka / khaosodenglish (used with permission).
The Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery. This case relates to the Basel Institute’s Green Corruption programme.
The development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.
The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Recommendations for combatting border corruption (FALCON Policy Brief)
Corruption at borders poses a significant threat to the integrity of the European Union’s external borders, undermining security, trust, and governance. And border corruption is not static — it evolves in response to new controls, technologies and enforcement strategies. This means that even well-designed measures may lose effectiveness over time.
A new Policy Brief by the FALCON (Fight Against Large-scale Corruption and Organised Crime Networks) project outlines actionable recommendations for EU policymakers and officials involved preventing and combatting border corruption.
The brief identifies four priority areas:
reducing discretionary face-to-face interactions at border crossing points through digitalisation;
developing harmonised, risk-based digital infrastructures that can detect corruption-prone patterns;
limiting manual data handling to close opportunities for manipulation; and
strengthening the conceptual alignment between anti-trafficking and anti-corruption strategies.
It argues that effective reform requires corruption-sensitive implementation frameworks, enhanced inter-agency coordination and a shift toward anticipatory governance.
The Basel Institute on Governance is an associated partner of the FALCON project. Jacopo Costa contributed to the Policy Brief and related research.
FALCON is funded under the Horizon Europe Framework Program Grant Agreement ID 101121281. The Basel Institute on Governance receives funding from the Swiss State Secretariat for Education, Research and Innovation (SERI).
Addressing conflicts of interest and corruption in Indonesia’s energy transition
This U4 Issue analyses Indonesia’s ambitious energy transition and highlights how political finance, weak regulations and a “revolving door” of personnel between public office and the private sector create vulnerabilities. The publication was produced by U4 and the Basel Institute on Governance through its Green Corruption programme.
About the paper
Conflicts of interest and corruption in Indonesia’s political economy pose significant risks to its energy transition, including the Just Energy Transition Partnership. Existing legal and institutional frameworks are fragmented, inconsistently applied, and often fail to address the risk of state capture by powerful political and economic actors, especially in the extractive and energy sectors.
The reliance on fossil fuel industries for political financing and the monopolistic nature of state-owned entities further complicate the shift to a low- or no-carbon system, despite the country’s ambitious renewable energy targets.
Potential pathways to greater anti-corruption resilience lie in improvements to beneficial ownership transparency and strengthening regulation, monitoring and sanctioning of conflict of interest violations.
Conceptualizing the evolution of corruption: an empirical analysis from Italy
In a new peer-reviewed journal article, Jacopo Costa and Claudia Baez Camargo look into why and how corruption evolves over time, drawing on an empirical analysis from Italy. The article was published in Trends in Organized Crime.
Abstract
Corruption evolves over time. This paper investigates why and how this evolution happens. The analysis has employed a combination of qualitative network and document analysis to explore the configuration of corruption in two moments in Italy and the changes that have happened in between them.
The findings have disclosed that a higher efficiency of the activities of the criminal-justice chain, the transformation of the critical actors and the reform of legal frameworks and governance systems have been critical in determining the evolution of corruption.
The added value of the research lies in its ability to examine these transformative mechanisms within a conceptual framework that keeps together the fact that corruption is networked and that networks evolve over time.
Political economy in the weeds: Embracing complexity in anti-corruption work – lessons learned from anti-corruption programme in Malawi
In this joint paper with Adam Smith International, authors Claudia Baez Camargo and Renee Kantelberg show how anti-corruption efforts require more than mere technical fixes, such as capacity building for civil society alone, to drive lasting change.
Anti-corruption work is often embedded in complex, politically charged environments. This requires thinking and working politically. Engaging with complex social and economic systems also means recognising that change is not linear or even predictable. What to do then?
Our years of anti-corruption research have demonstrated the centrality of having local stakeholders be in the driver’s seat for identifying priorities and finding solutions. This is how we have worked in Malawi in the Malawi Anti-Corruption Civil Society Support (MACCSS) project, funded by the UK Foreign, Commonwealth and Development Office and implemented with Adam Smith International.
This publication shares practical lessons and successes in applying this approach in the MACCSS project. It illustrates our joint efforts to navigate uncertainty and ground anti-corruption efforts in trust, resilience and local leadership. The key takeaways for practitioners who design or implement anti-corruption programmes (paraphrased) are:
- Embrace complexity. Change is adaption and pivoting to reality, which is not linear. In governance programmes, unexpected developments and temporary reversals are signs that systems are shifting.
- Local ownership matters. When partners are in the driver’s seat, impact and sustainability improve. This is true even if the route diverges from initial plans.
- Facilitation over funding. Hands-on mentoring and relationship brokering build deeper capabilities than unidirectional training, grants and results frameworks.
- Learning by doing. Regular reflection converts experience into strategy; failures become data for adaptation.
- Build trust and coalitions. Reform depends on a collective effort with credible institutions and sister anti-corruption programmes. It also requires nurturing emergent anti-corruption networks, rather than merely building the capacity of individual actors.
- Resilience grows from below. Sustainable accountability takes root when communities see anti-corruption as linked to livelihoods and services, not as an abstract governance agenda.
- Gender and inclusion strengthen legitimacy. Integrating gender and social inclusion (GESI) principles by addressing corruption in mining, infrastructure and agriculture – sectors critical for women and marginalised groups – broadens both the reach and credibility of anti-corruption efforts.
Ultimately, the MACCSS experience reinforces a simple but profound insight: anti-corruption work is not about perfect plans but about adaptive partnerships. Change happens through relationships, experimentation and persistence. The task is not to eliminate uncertainty, but to navigate it with integrity and learning at the core.
Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8/12 and beyond
At the 8th session of the Conference of the States Parties to the United Nations Convention against Corruption (UNCAC), in December 2019, States Parties adopted a resolution recognising the relationship between corruption and environmental crimes.
Resolution 8/12 – Preventing and combating corruption as it relates to crimes that have an impact on the environment – is a landmark Resolution. With its 23 operative paragraphs (OPs), it underlies the importance of addressing corruption linked to crimes that have an impact on the environment. It urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.
Saplings of hope presents an updated overview of emerging and promising prevention and enforcement actions, initiatives and measures implemented by UNCAC States Parties to combat corruption as it pertains to crimes that have an impact on the environment. It focuses specifically on initiatives from 2024 and 2025.
The Working Paper also underscores the valuable contributions made by non-state actors, in particular civil society, academia and the media, in this collective endeavour.
Finally, it makes the case for a paradigm shift, moving from “corruption as it relates to crimes that have an impact on the environment” to “corruption that has an impact on the environment”. The shift is necessary, because corruption can harm the environment without being linked to a crime that has an impact on the environment. Section 5 thus explores two interconnected issues which have a devastating impact on the environment: corruption linked to climate finance and renewable energy as well as corruption tied to the exploitation of critical minerals.
About this Working Paper
This report is part of the Green Corruption programme at the Basel Institute on Governance and was prepared in the context of the 11th Conference of the States Parties to the UN Convention against Corruption in Doha, Qatar, from 14–19 December 2025.
It provides an update to Working Paper 50, 'Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8/12’, which was prepared in the context of CoSP10 in Atlanta, Georgia, US in 2023.
The report is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. You may share or republish the report under a Creative Commons CC BY-NC-ND 4.0 licence.
It was made possible by the generous support of the Principality of Liechtenstein.
The contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Basel AML Index 2025
This is the 14th annual Public Edition report of the Basel AML Index, an independent, data-based ranking and risk assessment tool for money laundering and related financial crime risks around the world.
The Basel AML Index provides risk scores for jurisdictions based on data from 17 publicly accessible sources such as the Financial Action Task Force (FATF), Transparency International and the Global Initiative against Transnational Organized Crime. The risk scores cover five domains considered to contribute to a high money laundering risk:
- Quality of AML/CFT/CPF framework
- Corruption and fraud risks
- Financial transparency and standards
- Public transparency and accountability
- Political and legal risks
The Basel AML Index is developed and maintained by the Basel Institute on Governance through its International Centre for Asset Recovery (ICAR). ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.
Case Study 12: Indonesia: a landmark money laundering conviction in a forestry crime case
This Case Study highlights how investigators of Indonesia’s Ministry of Environment and Forestry achieved their first conviction for money laundering linked to forestry offences, leveraging institutional and legal changes in financial investigation procedures.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
The development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.
The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
International cooperation in the Migori County corruption case
This Case Study describes how Kenya obtained crucial overseas intelligence in a corruption case through the International Anti-Corruption Coordination Centre, leading to the recovery of USD 1.8 million in assets for the Kenyan people.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
It is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.
While we have made reasonable efforts to ensure the accuracy of information provided in this Case Study, neither the authors nor the Basel Institute’s donors and partners assume any responsibility or liability for any errors or omissions.
Working Paper 60: Understanding the enemy: Insights from corrupt networks to improve anti-corruption Collective Action initiatives
Corruption is not simply about individual misconduct. It is a networked phenomenon that arises from entrenched social, economic and political interactions. It is orchestrated through coordination between groups and clusters of individuals.
This Working Paper explores the networked nature of corruption and the opportunities this presents for anti-corruption efforts. The aim is to understand how shifting the unit of analysis from individuals to networks helps to understand the persistence and resilience of corruption, while opening up new anti-corruption perspectives.
A meta-analysis of findings from more than 15 years of research on informal networks and corruption underpins the conceptualisation of corrupt networks. The paper argues that a focus on networks helps to shed light on the functionality of corruption – from petty bribery to large-scale public procurement fraud – and the underlying social norms that enable it.
Understanding the structures, functions and modus operandi of the informal networks associated with corruption and applying the network logic to anti-corruption strategies can help to achieve better outcomes. The paper specifically looks at anti-corruption Collective Action initiatives, suggesting that these should emulate positive aspects of informal networks.
About this Working Paper
This paper is published as part of the Basel Institute on Governance Working Paper series, ISSN: 2624-9650. You may share or republish it under a Creative Commons BY-NC-ND 4.0 International Licence.
The contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Back in Action: How the UK is reviving unexplained wealth orders (The Academy Bulletin)
In an article published in the Fall 2025 issue of the Bulletin of the International Academy of Financial Crime Litigators, Andrew Dornbierer explores the revival of unexplained wealth orders (UWOs) in the United Kingdom.
Introduced in 2017 as a tool to combat the abuse of UK’s markets to launder criminal proceeds, the UWO mechanism suffered a severe setback in 2020. After only a handful of attempts to use it, a decision by the High Court effectively left it sprawled on the canvas.
In the last year or so, however, the mechanism has slowly started to prove itself. Most recently, the UK’s Serious Fraud Office – in its first use of the UK’s UWO mechanism – secured GBP 1.1 million from the sale of a property belonging to the ex-wife of a convicted fraudster.
This article offers a short history of UWOs in the UK. It examines how, after a turbulent start and subsequent amendments to the mechanism, UWOs are now back to being used by UK authorities to tackle illicit financial flows. If applied responsibly, proportionately and in harmony with established legal rights, unexplained wealth orders promise to be a powerful tool in the UK’s fight to recover criminal assets.
This is the fifth issue of The Academy’s Bulletin. It has been established to transmit the work of Academy Fellows, draw attention to matters of importance to the legal community and provide high-level analysis of cutting-edge issues in global financial crime investigations and litigation. The Basel Institute on Governance acts as Secretariat to the Academy.
Quick Guide 42: Non-conviction based confiscation
Criminals exploit legal loopholes, borders and other avenues to conceal the proceeds of their illegal activities and evade prosecution. Meanwhile, they use their illicit proceeds to buy luxury villas or increase their power and influence. Victims of crime – including communities affected by corruption – suffer the losses.
One tool to address this problem is non-conviction based confiscation: legal mechanisms that allow states to recover illicit assets even in the absence of a criminal conviction. It is also known as non-conviction based forfeiture or, in some jurisdictions, civil confiscation or civil forfeiture.
This Quick Guide outlines in simple terms how non-conviction based confiscation is used, the concerns and challenges it faces and how it can be implemented in line with established legal safeguards.
About this Quick Guide
You are free to share and republish this work under a Creative Commons BY-NC-ND 4.0 Licence. It is part of the Basel Institute on Governance Quick Guide series, ISSN 2673-5229.
Working Paper 58: Corruption as a facilitator of drug trafficking in the port of Rotterdam
Anti-corruption Collective Action in the G20/B20 process: Charting progress 2020–2024
This report analyses the approaches of the previous five B20 presidencies to addressing anti-corruption Collective Action. It captures lessons learned and provides recommendations for future B20/G20 cycles. It is primarily intended for upcoming B20/G20 presidencies, B20 Integrity & Compliance Task Force members and organisations engaging with the B20/G20.
About this report
You may share or republish this report under a Creative Commons CC BY-NC-ND 4.0 licence.
Suggested citation: Scarlet Wannenwetsch. 2025. ‘Anti-corruption Collective Action in the G20/B20 process: Charting progress 2020–2024.’ Basel Institute on Governance.
The report was funded by the Siemens Integrity Initiative, which supports organisations in the fight against corruption and fraud through Collective Action, education and training. The views and opinions expressed in this report are those of the author and do not reflect the position of Siemens or the Siemens Integrity Initiative.
Assessment of corruption risks in the construction, reconstruction and renovation of civilian infrastructure of Ukraine
Quick Guide 41: Managing seized and confiscated assets
This Quick Guide explains why effective, transparent and fair management of seized and confiscated assets – including assets linked to sanctions violations – is essential to successful asset recovery. It introduces key principles, standards and practical steps based on international good practice. These include legal, institutional and technical arrangements, that help countries manage seized assets in a way that preserves value, ensures accountability and supports justice.
The Guide is primarily intended for government officials working in law enforcement, justice and asset recovery. It may also be useful to policymakers and development partners seeking a better understanding of how countries can improve their asset management systems.
About this Quick Guide
You are free to share and republish this work under a Creative Commons BY-NC-ND 4.0 Licence. It is part of the Basel Institute on Governance Quick Guide series, ISSN 2673-5229.
Progress in Ukraine's anti-corruption efforts - July 2025 update
This document takes stock of recent progress (March to June 2025) in strengthening Ukraine’s anti-corruption ecosystem. It builds on a series of previous reports and is published ahead of the fourth Ukraine Recovery Conference, held in Rome 10–11 July 2025.
The report highlights key developments, including in the context of Ukraine’s European integration, and touches on:
- the status of the national Anti-Corruption Strategy;
- the nascent reform of Ukraine’s Asset Recovery and Management Agency;
- the risks related to the selection of members for the High Qualification Commission of Judges (HQCJ);
- criminal justice developments, including the first audit of the National Anti-Corruption Bureau;
- the reform of the State Register of Corrupt Officials; and
- considerations in the area of recovery and reconstruction.
This document is a joint publication of Transparency International Ukraine and the Basel Institute on Governance.
Disclaimer: This publication has been produced with the support of Switzerland. The contents of this publication are the sole responsibility of the Basel Institute on Governance and TI Ukraine and do not necessarily reflect the views of the development partner.