[{"data":1,"prerenderedAt":549},["ShallowReactive",2],{"publication-crypto-str-report":3,"publication-crypto-str-report-editions":65,"author-links-crypto-str-report":66,"related-crypto-str-report":67},[4],{"id":5,"status":6,"sort":7,"user_created":8,"date_created":9,"user_updated":8,"date_updated":10,"nid":7,"slug":11,"title":12,"body":13,"citation":14,"language":7,"year":7,"publisher":15,"date_published":16,"external":17,"topic":7,"link_internal":18,"link_external":7,"featured":17,"topics":22,"languages":26,"type":28,"area":7,"programme":7,"websites":30,"summary":33,"pdf_text":7,"main_points":34,"short_version":35,"subtitle":36,"countries":37,"tags":38,"pdf":51,"authors":59,"translations_publications":60,"image":61,"og_image":63},2477,"published",null,"d22c72aa-896a-43ce-acca-4154ff70a25a","2026-11-11T08:49:52.000Z","2026-11-11T13:39:30.000Z","crypto-str-report","Reporting suspicious crypto activity","This report summarises discussions at “Crypto STRs in practice: bridging supervisory expectations and operational realities”, a breakout session organised by the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) and the [Basel Institute on Governance](https:\u002F\u002Fbaselgovernance.org\u002F) at the 2026 [Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fevents\u002F10th-global-conference-on-criminal-finances-and-cryptoassets-2924\u002F).\n\nThis workshop brought together supervisors, FIUs, financial institutions and cryptoasset service providers to discuss the practical challenges of cryptorelated suspicious transaction and activity reporting (STR\u002FSAR) and how its effectiveness can be improved.\n\n**Disclaimer**: The report is an informal summary of workshop discussions. It does not represent\nor imply a common position of workshop participants and has not been adopted, endorsed or approved by the institutions with which individual organisers, moderators or participants are affiliated. Nothing in the report should be interpreted as defining the applicable legal threshold for suspicious transaction or activity reporting, or as legal, regulatory, supervisory or compliance guidance.\n\n**Licence and sharing**: You may share this publication under a Creative Commons [BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002Fdeed.en) International licence.\n\n[Cover image](https:\u002F\u002Fwww.magnific.com\u002Ffree-photo\u002Fcable-stayed-bridge-across-frosty-river_1186423.htm): Designed by bearfotos – [Magnific.com](https:\u002F\u002Fwww.magnific.com) (adapted).","Basel Institute on Governance and The Wolfsberg Group. 2026. \"Reporting suspicious crypto activity: Bridging supervisory expectations and operational realities\". Available at: https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002Fcrypto-str-report.","Basel Institute on Governance","2026-11-11",false,[19],{"caption":20,"url":21},"Download Crypto STR report","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F8db165c2-0a7a-4da8-837c-ebef361a3780\u002FCrypto-STR-report_final.pdf?v=20261111131910000",[23,24,25],"Anti-Money Laundering","Business Integrity Ethics and Compliance","Asset Recovery and Enforcement",[27],"English",[29],"Report",[31,32],"Main page","Basel AML Index","This report summarises discussions among supervisors, FIUs, financial institutions and cryptoasset service providers on the practical challenges of cryptorelated suspicious transaction and activity reporting (STR\u002FSAR), highlighting eight recurring considerations for improving its effectiveness.","","## Executive summary\n\nThis report summarises discussions at “Crypto STRs in practice: bridging supervisory expectations and operational realities”, a breakout session organised by the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) and the [Basel Institute on Governance](https:\u002F\u002Fbaselgovernance.org\u002F) at the 2026 [Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fevents\u002F10th-global-conference-on-criminal-finances-and-cryptoassets-2924\u002F).\n\nThis workshop brought together supervisors, FIUs, financial institutions and cryptoasset service providers to discuss the practical challenges of cryptorelated suspicious transaction and activity reporting (STR\u002FSAR) and how its effectiveness can be improved.\n\nThe discussions highlighted eight recurring considerations that participants regarded as relevant to improving the effectiveness of suspicious crypto activity reporting. Their application remains subject to the applicable legal and regulatory framework and to reporting entities’ risk-based assessments.\n\n1. **Judge STRs\u002FSARs by their intelligence value, not their volume.** A good report is one that competent authorities can act on. Large volumes of reports that contain limited contextual or intelligence value may place pressure on both reporting entities and authorities and make prioritisation more difficult. Improving report quality can help authorities identify and analyse the most relevant information, while recognising that reports of limited apparent value in isolation may become significant when combined with other information.\n\n2. **Alerts and red flags are only a starting point.** Red flags, alerts and risk scores are a starting point for analysis, not a reason to file. Reporting entities should use professional judgement and report when the information supports a genuine suspicion. Reporting simply to avoid criticism, or because questions remain open, adds little value.\n\n3. **Explain the reasoning behind the suspicion.** The most valuable reports give a clear narrative: why the activity is suspicious, what was reviewed, what steps were taken and how the evidence led to the conclusion. Relevant context matters more than including every piece of available information.\n\n4. **Get the data right and make it machine-readable.** Accurate identifiers, complete transaction data and structured formats such as XML allow FIUs to link reports, including across borders. These formats should cover all relevant persons, entities, transactions and accounts, including cryptoasset accounts. A report of limited value on its own can become significant when combined with information held elsewhere.\n\n5. **Use blockchain analytics alongside other sources.** There was broad agreement that these tools should support, rather than replace, human analysis and decision-making. The tools are valuable, but attribution can be incomplete, data quality varies and providers’ methods differ. The strongest reports combine analytics with customer due diligence, transaction monitoring, behavioural indicators and open-source research. Where permitted by the applicable reporting framework, and where useful and proportionate, participants considered that relevant extracts or information explaining the analytics output may help the receiving FIU understand the basis of the assessment.\n\n6. **Make analytics more transparent and pursue common standards.** Participants favoured developing standards on governance, taxonomy and explainability of blockchain analytics tools. This would improve comparability without stifling innovation.\n\n7. **Join up the picture through cooperation.** Banks see fiat flows and customer profiles, CASPs see platform and on-chain activity, and authorities see across reports. Public-private and private-to-private dialogue, especially between banks and CASPs, helps close these gaps within legal limits. Public authorities have a role in building trust and facilitating that dialogue.\n\n8. **Feedback improves reporting over time.** Case-by-case feedback is hard for stretched FIUs. Other channels can still help reporting entities learn what is useful and reduce defensive reporting, including typology and negative typology publications, thematic guidance, periodic quality feedback and structured dialogue.\n\n**A question mark remains around how far should reporting entities trace historical cryptoasset activity.** Participants agreed that a proportionate approach is needed, but there was no common position on what that means in practice.\n\nA typical case is a bank receiving funds from a MiCA-licensed CASP where the source of wealth is understood and there are no red flags. A licence is relevant but not decisive.\n\nRelated questions concern how much information institutions can reasonably request from customers, some of whom are reluctant to disclose wallet details for privacy and security reasons, and whether that reluctance should itself be treated as a risk indicator.\n\nDeveloping that guidance – and continuing to work through the challenges and good practices indicated above to enhance their application in practice – is a joint task for public authorities and reporting entities. Initiatives and networks such as the Global Conference on Criminal Finances and Cryptoassets, the Wolfsberg Group and the [Europol Financial Intelligence Public-Private Partnership (EFIPPP)](https:\u002F\u002Fefippp.eu\u002F) are powerful forums to take that work forward.","Bridging supervisory expectations and operational realities",[],[39,43,47],{"tags_id":40},{"id":41,"name":42},867,"Financial crime",{"tags_id":44},{"id":45,"name":46},1193,"Financial investigations",{"tags_id":48},{"id":49,"name":50},854,"Virtual assets",[52],{"directus_files_id":53},{"id":54,"filename_download":55,"title":56,"description":7,"modified_on":57,"uploaded_on":58},"8db165c2-0a7a-4da8-837c-ebef361a3780","Crypto-STR-report_final.pdf","Reporting suspicious crypto activity - Crypto STR report","2026-11-11T13:19:10.000Z","2026-11-11T13:17:07.000Z",[],[],{"id":62},"820b929d-d670-4b04-b6c1-dbf972f8d2d0",{"id":64},"8ee65b7b-c807-4a83-94cc-5fabd75b43b2",[],{},[68,113,147,191,228,287,352,386,431,473],{"id":69,"slug":70,"title":71,"status":6,"nid":7,"year":7,"body":72,"external":17,"topic":7,"language":7,"type":73,"date_published":75,"image":76,"citation":77,"publisher":15,"link_internal":78,"link_external":7,"authors":85,"countries":86,"tags":87,"pdf":100,"topics":102,"featured":17,"languages":103,"summary":104,"programme":7,"area":7,"websites":105,"pdf_text":7,"sort":7,"user_created":8,"date_created":106,"user_updated":8,"date_updated":107,"main_points":34,"short_version":108,"subtitle":109,"og_image":110,"translations_publications":111,"link":112},2476,"pb-18-cryptoasset-management","Policy Brief 18: Managing seized cryptoassets","In September 2026, asset management practitioners, prosecutors, police and private-sector specialists from 17 countries met in Luxembourg to discuss how to manage seized cryptoassets.\n\nCo-organised by the Luxembourg Bureau de gestion des avoirs and Basel Institute on Governance, the roundtable was held under the Chatham House rule on the sidelines of the [10th Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002Flearning\u002Fevents\u002F10th-global-conference-on-criminal-finances-and-cryptoassets-2924). This publication emerges from that roundtable.\n\nThe document is structured around eight questions, because the focus is on questions that asset management practitioners need to consider rather than one-size-fits-all answers that do not exist. Laws, institutions and resources differ, as the examples given by participants demonstrate. Technical terms are explained in the glossary at the end.\n\nThe discussions confirmed that managing cryptoassets should be framed within the lifecycle of a case, from pre-seizure planning to disposal. Decisions taken at one stage can have significant consequences at later stages.\n\nThe diagram below shows the main stages in managing a seized cryptoasset, indicating the most relevant questions for each.\n\n![](https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fassets\u002Ffb14c631-3971-442c-aa86-835662e2019e)\n\n## About this publication\nThis publication is part of the Basel Institute on Governance Policy Brief series [ISSN 2624-9669](https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002F?type=Policy+Brief). It is a Diamond Open Access publication, also hosted on the Basel University Library’s open publishing platform [eterna](https:\u002F\u002Feterna.unibas.ch\u002F) as part of our Basel Institute on Governance Policy Brief Journal, with DOI: [10.12685\u002Fbigpb.18.1-20](https:\u002F\u002Fdoi.org\u002F10.12685\u002Fbigpb.18.1-20).\n\nYou may share this publication under a Creative Commons [BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F) International licence.\n\nAround 50 participants from the public and private sectors, representing 17 jurisdictions, took part in the roundtable on which the publication is based. The organisers thank all participants for sharing their experience so openly during the roundtable and in consultations on the draft. \n\n**Disclaimer**: The document does not necessarily represent the views of the moderators, the organisers or participants’ institutions, or the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.",[74],"Policy Brief","2026-11-09","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Fad665f0c-ea7b-46c2-9905-2f7033af2301?format=webp&quality=90&width=600&height=840","Basel Institute on Governance. 2026. ‘Managing seized cryptoassets’. Policy Brief 18, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002Fpb-18-cryptoasset-management.\n",[79,82],{"url":80,"caption":81},"https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F708fcda9-2daa-4cc5-a4b9-c5fd69dc5677\u002FPolicy-Brief-18_cryptoasset-management.pdf?v=20261109104838000","Download Policy Brief 18",{"url":83,"caption":84},"https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002Fqg41","Read related Quick Guide to managing seized and confiscated assets",[],[],[88,90,94,96],{"tags_id":89},{"id":41,"name":42},{"tags_id":91},{"id":92,"name":93},858,"Asset management",{"tags_id":95},{"id":49,"name":50},{"tags_id":97},{"id":98,"name":99},843,"Asset recovery",[101],2579,[25],[27],"This Policy Brief outlines eight practical lessons for jurisdictions to consider when establishing a system for managing seized cryptoassets. Asset management practitioners, prosecutors, police and private-sector specialists from 17 countries contributed to these lessons at a roundtable in September 2026.",[31],"2026-11-05T10:57:46.000Z","2026-11-11T12:20:19.000Z","## Key messages at a glance\n\n1. **The fundamental principles of asset management continue to apply.** Cryptoassets should be managed lawfully, securely, transparently and with the objective of preserving value. The particular characteristics of cryptoassets require those principles to be adapted, especially in relation to custody, control, volatility, technical expertise and timing.\n2. **Preparation and early coordination are critical.** Authorities should involve the relevant asset management expertise as early as possible and establish custody, decision-making and communication arrangements before a seizure occurs.\n3. **There is no one-size-fits-all model.** The right arrangements depend on national legislation, institutional structures, available expertise and the assets involved. They also need to evolve: a model that works immediately after seizure may not suit months or years later, so authorities should be able to adapt.\n4. **Security is a governance issue as much as a technical one.** Multi-person approval, role-based access, key protection, audit trails, business continuity, data protection and clear liability arrangements are essential safeguards.\n5. **Preserving value requires active decision-making.** Authorities need clear criteria and responsibilities for deciding whether assets should be held, converted or sold. Where interim-sale powers exist, they should be matched by the institutional capacity to monitor markets and act within the relevant timeframes.\n6. **Public authorities should retain responsibility for decisions concerning seized assets.** Private-sector providers can provide valuable technical and operational support, but outsourcing should not result in a loss of public control or accountability.\n7. **Choose the right route to sell and return.** There is no single way to sell or return a cryptoasset. The sale method should suit the asset, its liquidity and the amount at stake, and the process should be auditable. Authorities must also decide whether owners and victims receive the asset itself or its value, bearing in mind that many victims have no wallet.\n8. **Cooperation is a practical capability.** Networks of asset management offices, asset recovery offices and other practitioners can provide contacts, expertise, training and support for difficult cases. Building these networks can reduce duplication and help authorities develop solutions that are proportionate to their needs.","Practical lessons from an international roundtable","769e5ce5-e838-4e19-85ab-8eb6fc516ce0",[],"\u002Fresources\u002Fpublications\u002Fpb-18-cryptoasset-management",{"id":114,"slug":115,"title":116,"status":6,"nid":117,"year":118,"body":119,"external":17,"topic":120,"language":122,"type":123,"date_published":124,"image":125,"citation":34,"publisher":126,"link_internal":127,"link_external":131,"authors":132,"countries":133,"tags":134,"pdf":137,"topics":139,"featured":17,"languages":140,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":141,"date_created":142,"user_updated":143,"date_updated":144,"main_points":7,"short_version":7,"subtitle":7,"og_image":7,"translations_publications":145,"link":146},2349,"race-against-time-europol-basel-institute-governance-recommendations-preventing-and","A race against time: Europol – Basel Institute on Governance recommendations on preventing and combating the criminal use of cryptocurrencies",2619,2024,"These recommendations follow the 7th Global Conference on Criminal Finances and Cryptocurrencies on 26–27 October 2023. The conference was co-organised by Europol and the Basel Institute on Governance and took place in hybrid format at Europol’s headquarters in The Hague, Netherlands. \n\nThe five recommendations highlight the need for accelerated action in order to combat the use of crypto assets, as well the allocation of more resources, better training and better collaboration.\n\nThey are to: \n\n\n- Accelerate innovation for investigative and monitoring tools \n- Boost enforcement capacity and training\n- Reorganise to foster collaboration and prioritisation \n- Engage proactively in multi-sector collaborations  \n- Consider the whole chain, from prevention to facilitators \n",[23,121],"Asset Recovery","en",[29],"2024-05-08","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F0de3625e-aacc-4db2-93f0-2e17d0a32c75?format=webp&quality=90&width=600&height=840","Europol and Basel Institute on Governance",[128],{"url":129,"caption":130},"\u002Fresources\u002Fnews\u002Fshaping-an-international-response-against-the-criminal-misuse-of-cryptocurrencies-2525"," View conference summary",[],[],[],[135],{"tags_id":136},{"id":49,"name":50},[138],2388,[23,25],[27],"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","2024-05-08T10:04:39.000Z","dfef11db-1bc6-47e9-a61d-93443995484b","2026-09-10T09:04:40.000Z",[],"\u002Fresources\u002Fpublications\u002Frace-against-time-europol-basel-institute-governance-recommendations-preventing-and",{"id":148,"slug":149,"title":150,"status":6,"nid":151,"year":118,"body":152,"external":17,"topic":153,"language":122,"type":154,"date_published":156,"image":157,"citation":34,"publisher":15,"link_internal":158,"link_external":162,"authors":166,"countries":171,"tags":172,"pdf":183,"topics":185,"featured":17,"languages":186,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":141,"date_created":187,"user_updated":143,"date_updated":188,"main_points":7,"short_version":7,"subtitle":7,"og_image":7,"translations_publications":189,"link":190},2378,"qg34","Quick Guide 34: Public-private partnerships for financial intelligence sharing",2724,"Financial intelligence is the staple food of investigations into corruption, money laundering and other financial crimes.\n\nMuch financial intelligence is held by private-sector institutions such as banks and other financial service providers. How does that get into the hands of law enforcement, where it can trigger or inform investigations? And how can we improve the system?\n\nThis Quick Guide gives a brief introduction to public-private partnerships or platforms for financial intelligence sharing. It sets out how they work in practice, and how they can improve the sharing of targeted, useful information between law enforcement and financial institutions.\n\n### About this Quick Guide\n\nYou are free to share and republish this work under a [Creative Commons BY-NC-ND 4.0 Licence](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F). It is part of the Basel Institute on Governance Quick Guide series, [ISSN 2673-5229](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428).",[23,121],[155],"Quick Guide","2024-11-25","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F01dea28f-22b8-47cd-bf86-ddee24683c2b?format=webp&quality=90&width=600&height=840",[159],{"url":160,"caption":161},"\u002Fresources\u002Fpublications?type=Quick%20Guide","View all Quick Guides",[163],{"url":164,"caption":165},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=249","View online on LEARN",[167],{"authors_id":168},{"id":169,"name":170},327,"Simon Marsh",[],[173,175,179],{"tags_id":174},{"id":45,"name":46},{"tags_id":176},{"id":177,"name":178},818,"Anti-money laundering",{"tags_id":180},{"id":181,"name":182},1374,"Law enforcement",[184],2416,[23,25],[27],"2024-12-05T14:06:47.000Z","2026-09-10T09:04:44.000Z",[],"\u002Fresources\u002Fpublications\u002Fqg34",{"id":192,"slug":193,"title":194,"status":6,"nid":195,"year":196,"body":197,"external":17,"topic":198,"language":122,"type":199,"date_published":200,"image":201,"citation":34,"publisher":15,"link_internal":202,"link_external":208,"authors":211,"countries":216,"tags":217,"pdf":220,"topics":222,"featured":17,"languages":223,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":141,"date_created":224,"user_updated":143,"date_updated":225,"main_points":7,"short_version":7,"subtitle":7,"og_image":7,"translations_publications":226,"link":227},2401,"qg40","Quick Guide 40: Financial investigations in a cash economy",2796,2025,"Despite the increasing use of digital payment methods, cash is still king in many economies – including criminal economies. It remains the most-used payment option across Africa, the Middle East and Latin America, and accounted for over USD 7.6 trillion in consumer expenditures throughout 2022.\n\nThat’s a challenge when investigating financial crimes. How can you “follow the money” without records of bank transfers, debit or credit card payments, or digital wallet transactions?\n\nThis Quick Guide explains the specific challenges involved in conducting financial investigations in a cash economy. It outlines how law enforcement can use traditional investigative methods to successfully uncover the financial affairs of a suspect.\n\n### About this Quick Guide\n\nYou are free to share and republish this work under a [Creative Commons BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F) Licence. It is part of the Basel Institute on Governance Quick Guide series, [ISSN 2673-5229](https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002F?type=Quick+Guide).",[121],[155],"2025-04-10","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Fc20e0d80-319e-4b14-b187-064f77f9e53a?format=webp&quality=90&width=600&height=840",[203,206],{"url":204,"caption":205},"https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F806b8f90-3ca3-4f36-9584-421a485f04c1\u002FQG40-FI-in-cash-economy.pdf?v=20250414100514000","Download PDF",{"url":160,"caption":207}," View all Quick Guides",[209],{"url":210,"caption":165},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=286",[212],{"authors_id":213},{"id":214,"name":215},562,"Emmanuel Mringo",[],[218],{"tags_id":219},{"id":45,"name":46},[221],2442,[25],[27],"2025-04-14T10:05:14.000Z","2026-09-10T09:04:48.000Z",[],"\u002Fresources\u002Fpublications\u002Fqg40",{"id":229,"slug":230,"title":231,"status":6,"nid":232,"year":118,"body":233,"external":17,"topic":234,"language":122,"type":235,"date_published":237,"image":238,"citation":239,"publisher":15,"link_internal":240,"link_external":246,"authors":247,"countries":252,"tags":257,"pdf":278,"topics":280,"featured":281,"languages":282,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":141,"date_created":283,"user_updated":143,"date_updated":284,"main_points":7,"short_version":7,"subtitle":7,"og_image":7,"translations_publications":285,"link":286},2366,"wp-54","Working Paper 54: Targeting illicit wealth through non-conviction based forfeiture: Identifying human rights and other standards for Latin America",2701,"This Working Paper explores the wide variety of non-conviction based (NCB) forfeiture laws in Latin America, with a special focus on the region’s predominant model, *Extinción de dominio*.\n\nIt argues that NCB forfeiture legislation, which allows for the recovery of stolen assets outside of criminal proceedings, can contribute significantly to a state’s criminal policy response to rampant economic and organised crime.\n\nThe paper emphasises the importance of critically reviewing and harmonising domestic practices of NCB forfeiture around emerging standards, so that they can reach their large potential in asset recovery. Ensuring their alignment with international human rights and other recognised norms and procedural rules ultimately builds trust, lends legitimacy and fosters judicial cooperation in international NCB forfeiture cases.\n\n### About this report\n\nThe paper is based on experience gained through the Basel Institute’s [International Centre for Asset Recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery) (ICAR), which since 2006 has supported partner countries in investigating, prosecuting and recovering assets arising from grand corruption and other crimes.\n\nThis paper is published as part of the Basel Institute on Governance Working Paper series, [ISSN: 2624-9650](https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002F?type=Working+Paper). It is a Diamond Open Access publication, also hosted on the Basel University Library’s open publishing platform [eterna](https:\u002F\u002Feterna.unibas.ch\u002F) as part of our Basel Institute on Governance Working Paper Journal, with DOI: [10.12685\u002Fbigwp.2024.54.61](https:\u002F\u002Fdoi.org\u002F10.12685\u002Fbigwp.2024.54.61).\n\nYou may share or republish the Working Paper under a Creative Commons [CC BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002Fdeed.en) International License.\n",[121],[236],"Working Paper","2024-09-30","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F37616510-2f1f-4ab6-9405-845433d6fa3b?format=webp&quality=90&width=600&height=840","Solórzano, Oscar. 2024. ‘Targeting illicit wealth through non-conviction based forfeiture: Identifying human rights and other standards for Latin America.’ Working Paper 54, Basel Institute on Governance. Available at: baselgovernance.org\u002Fpublications\u002Fwp-54.",[241,243],{"url":242,"caption":205},"https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F4b18c9e5-e24b-4cdc-901e-7b7261631542\u002FWP54.pdf?v=20241003160511000",{"url":244,"caption":245},"\u002Fresources\u002Fpublications?type=Working%20Paper"," View all Working Papers",[],[248],{"authors_id":249},{"id":250,"name":251},294,"Oscar Solorzano",[253],{"countries_id":254},{"id":255,"name":256},171,"Peru",[258,260,264,266,270,274],{"tags_id":259},{"id":98,"name":99},{"tags_id":261},{"id":262,"name":263},932,"Human rights",{"tags_id":265},{"id":41,"name":42},{"tags_id":267},{"id":268,"name":269},967,"Organised crime",{"tags_id":271},{"id":272,"name":273},1379,"Non-conviction based forfeiture",{"tags_id":275},{"id":276,"name":277},1215,"Illicit financial flows",[279],2404,[25],true,[27],"2024-10-03T16:05:11.000Z","2026-09-10T09:04:43.000Z",[],"\u002Fresources\u002Fpublications\u002Fwp-54",{"id":288,"slug":289,"title":290,"status":6,"nid":291,"year":292,"body":293,"external":17,"topic":7,"language":122,"type":294,"date_published":296,"image":297,"citation":298,"publisher":15,"link_internal":299,"link_external":303,"authors":307,"countries":312,"tags":321,"pdf":332,"topics":335,"featured":281,"languages":337,"summary":339,"programme":7,"area":7,"websites":340,"pdf_text":7,"sort":7,"user_created":341,"date_created":342,"user_updated":8,"date_updated":343,"main_points":344,"short_version":7,"subtitle":7,"og_image":7,"translations_publications":345,"link":351},2443,"cs-14","Case Study 14: Madagascar: a landmark conviction for money laundering linked to environmental crime",2948,2026,"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.\n\n### About this Case Study\n\nThis publication is part of the Basel Institute on Governance Case Study series, [ISSN 2813-3900](https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002F?type=Case+Study). It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License ([CC BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F)).\n\nPhoto: [Studio Sifaka](https:\u002F\u002Fwww.studiosifaka.org\u002Farticles\u002Factualites\u002Fitem\u002F8084-plus-de-mille-tortues-et-pres-d-une-cinquantaine-de-lemuriens-vivants-saisis-en-thailande.html) \u002F khaosodenglish (used with permission).\n\nThe 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](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption).\n\nThe development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.\n\nThe 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.\n",[295],"Case Study","2026-03-31","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Fea8361c6-bffd-4cfd-9119-7bc822b39af7?format=webp&quality=90&width=600&height=840","Rakotondramanana, Joseph. 2026. “Madagascar: a landmark conviction for money laundering linked to environmental crime.” Case Study 14, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-14",[300],{"url":301,"caption":302},"\u002Fresources\u002Fpublications?type=Case%20Study","View all Case Studies",[304],{"url":305,"caption":306},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=369","View online on Basel LEARN",[308],{"authors_id":309},{"id":310,"name":311},567,"Joseph Rakotondramanana",[313,317],{"countries_id":314},{"id":315,"name":316},139,"Madagascar",{"countries_id":318},{"id":319,"name":320},213,"Thailand",[322,326,330],{"tags_id":323},{"id":324,"name":325},1303,"Environment",{"tags_id":327},{"id":328,"name":329},879,"Money laundering",{"tags_id":331},{"id":45,"name":46},[333,334],2497,2532,[336],"Green Corruption",[27,338],"French","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.",[31],"3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-06-01T22:10:26.000Z","2026-10-13T11:55:25.000Z","- In 2024, Thai authorities carried out the country's largest ever single wildlife seizure, intercepting 48 lemurs and more than 1,000 tortoises endemic to Madagascar.\n- The seizure triggered a joint Thai-Malagasy investigation that traced smuggling routes through Indonesia, uncovered a transnational criminal network and led to arrests in both countries, the freezing of bank accounts and the confiscation of vehicles and vessels.\n- In 2025, the Anti-Corruption Court in Antananarivo convicted 10 individuals for trafficking in protected species, money laundering and criminal conspiracy. Sentences of up to 10 years in prison were handed down, alongside approximately USD 8.7 million in customs penalties and damages. This is the first time Madagascar has applied the offence of money laundering to a wildlife trafficking case.\n- Training on financial investigations by the Basel Institute on Governance, together with the facilitation of information exchange and peer learning among enforcement practitioners, contributed to this landmark result. The Malagasy authorities are now better equipped to overcome structural challenges in applying a “follow-the-money” approach to organised environmental crime, including limited technical expertise, insufficient resources and the complexity of cross-border financial investigations.",[346],{"title":347,"body":348,"summary":7,"slug":349,"language":350},"Case Study 14: Madagascar: une condamnation historique pour blanchiment de capitaux lié à un crime environnemental","Cette étude de cas montre comment la coopération internationale et l’approche « suivre l’argent » ont permis de mettre au jour un réseau criminel transnational impliqué dans le trafic d’espèces menacées conduisant à la première condamnation pour blanchiment de capitaux lié au trafic d’espèces sauvages à Madagascar.\n\n## À propos de cette étude de cas\nCette publication fait partie de la série d’études de cas du Basel Institute on Governance, [ISSN\n2813-3900](https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002F?type=Case+Study). Elle est sous licence Creative Commons Attribution-Non-Commercial-NoDerivatives 4.0 International ([CC BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F)).\n\nLa réalisation de cette publication a été financée par le Fonds « Illegal Wildlife Trade (IWT) Challenge Fund ».\n\nLe contenu relève de la seule responsabilité de l’auteur et ne reflète pas nécessairement la position officielle du Basel Institute on Governance, de ses donateurs et partenaires, ni de l’Université de Bâle.","cs-14-fr","fr","\u002Fresources\u002Fpublications\u002Fcs-14",{"id":353,"slug":354,"title":355,"status":6,"nid":356,"year":196,"body":357,"external":17,"topic":358,"language":122,"type":359,"date_published":360,"image":361,"citation":34,"publisher":15,"link_internal":362,"link_external":365,"authors":372,"countries":373,"tags":374,"pdf":378,"topics":380,"featured":281,"languages":381,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":141,"date_created":382,"user_updated":143,"date_updated":383,"main_points":7,"short_version":7,"subtitle":7,"og_image":7,"translations_publications":384,"link":385},2429,"basel-aml-index-2025","Basel AML Index 2025",2893,"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.\n\nThe 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:\n\n- Quality of AML\u002FCFT\u002FCPF framework\n- Corruption and fraud risks\n- Financial transparency and standards\n- Public transparency and accountability\n- Political and legal risks\n\n### Key messages and trends in 2025\n\n**1\\. The 2025 Public Edition includes 177 countries and jurisdictions.** Myanmar, Haiti and the Democratic Republic of the Congo receive the highest risk scores, while Finland, Iceland and San Marino have the lowest.\n\n**2\\. The global average risk score decreased marginally from 5.30 to 5.28**, a statistically insignificant change. More than half of jurisdictions improved their scores, while 43 percent worsened. Overall, results indicate a levelling-out of global money laundering risk, with improvements in some higher-risk jurisdictions offset by declines among traditionally lower-risk countries.\n\n**3\\. Results across risk domains are mixed.** There are modest improvements in the quality of AML\u002FCFT\u002FCPF frameworks and small reductions in corruption risks, alongside weaker financial transparency, growing concerns over public accountability and continued regional variation in political and legal risks.\n\n**4\\. The report also examines emerging challenges**, including approaches to identifying lower-risk jurisdictions and assessing structural vulnerabilities related to virtual assets. It highlights the continued importance of addressing underlying weaknesses – such as corruption, weak supervision and poor enforcement – that enable financial crime across both traditional and virtual asset sectors.\n\nThe Basel AML Index is developed and maintained by the Basel Institute on Governance through its [International Centre for Asset Recovery](https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F25) (ICAR).",[23,121],[29],"2025-12-08","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F19665416-644c-4110-9642-07b31f849971?format=webp&quality=90&width=600&height=840",[363],{"url":364,"caption":205},"https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Facda2850-9664-4c95-87b8-c978baf7a5c6\u002FBasel-AML-Index-2025.pdf?v=20251208110534000",[366,369],{"url":367,"caption":368},"https:\u002F\u002Findex.baselgovernance.org\u002F"," View Basel AML Index website",{"url":370,"caption":371},"https:\u002F\u002Findex.baselgovernance.org\u002Fnews\u002Fbasel-aml-index-2025-reveals-uneven-progress-global-fight-against-financial-crime","Read 2025 press release",[],[],[375],{"tags_id":376},{"id":377,"name":32},1346,[379],2484,[23,25],[27],"2025-12-08T11:05:33.000Z","2026-09-10T09:04:53.000Z",[],"\u002Fresources\u002Fpublications\u002Fbasel-aml-index-2025",{"id":387,"slug":388,"title":389,"status":6,"nid":390,"year":196,"body":391,"external":17,"topic":392,"language":122,"type":393,"date_published":394,"image":395,"citation":396,"publisher":15,"link_internal":397,"link_external":402,"authors":405,"countries":410,"tags":415,"pdf":422,"topics":424,"featured":17,"languages":425,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":426,"sort":7,"user_created":141,"date_created":427,"user_updated":143,"date_updated":383,"main_points":428,"short_version":7,"subtitle":7,"og_image":7,"translations_publications":429,"link":430},2428,"cs-12","Case Study 12: Indonesia: a landmark money laundering conviction in a forestry crime case",2874,"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.\n\n### About this Case Study\n\nThis publication is part of the Basel Institute on Governance Case Study series, [ISSN 2813-3900](https:\u002F\u002Fbaselgovernance.org\u002Fcase-studies). It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License [CC BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F).\n\nThe development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.\n\nThe 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.",[336],[295],"2025-11-25","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Fcb6cbdfc-7348-43d5-bfc0-2d3fc41157cd?format=webp&quality=90&width=600&height=840","Anindito, Lakso. 2025. “Indonesia: a landmark money laundering conviction in a forestry crime case.” Case Study 12, Basel Institute on Governance. Available at: \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-12\">baselgovernance.org\u002Fpublications\u002Fcs-12\u003C\u002Fa>.",[398,400],{"url":399,"caption":205},"https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F0a13876e-31fd-4a52-8dc6-5b8700a9a731\u002FCase-Study-12-Indonesia-ML-conviction.pdf?v=20251125170534000",{"url":301,"caption":401}," View all Case Studies",[403],{"url":404,"caption":306},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=336",[406],{"authors_id":407},{"id":408,"name":409},523,"Lakso Anindito",[411],{"countries_id":412},{"id":413,"name":414},99,"Indonesia",[416,418,420],{"tags_id":417},{"id":177,"name":178},{"tags_id":419},{"id":324,"name":325},{"tags_id":421},{"id":45,"name":46},[423],2483,[336],[27],"\u003C!-- image -->\n\n## Case Study 12\n\n## November 2025\n\n## Indonesia: a landmark money laundering conviction in a forestry crime case\n\nHow 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.\n\nLakso Anindito , Team Leader Indonesia, Green Corruption programme, Basel Institute on Governance\n\n\u003C!-- image -->\n\n## Key points\n\n- → In a case of illegal logging in Alas Purwo National Park, investigators of Indonesia's Ministry of Environment and Forestry 1  obtained their first money laundering conviction.\n- → This achievement was made possible through a 2021 Constitutional Court decision extending the power to pursue  money laundering offences  to  investigators in  charge of predicate offences, in this case timber trafficking.  This  power  was  previously  limited  to investigators of traditional law enforcement agencies, including the police and the Corruption Eradication Commission.\n- → Training  and  technical  assistance  by  the  Green Corruption  programme  of  the  Basel  Institute  on Governance contributed to strengthening law\n\n- enforcement capacities to effectively handle money laundering cases and track illicit financial flows tied to environmental crimes.\n- → Sustained coordination and collaboration among the Ministry, Indonesia's Financial Intelligence Unit and the Attorney General's Office were pivotal in applying the follow-the-money approach to the illegal logging case.\n- → Businessman  Supono  was  convicted  initially  of illegally trading rosewood and later of laundering approximately USD 127,000 he had obtained through log  trading.  In  both  cases,  he  was  sentenced  to prison and ordered to pay a fine.\n- → Although the amount of money laundered in this case and the imposed fines were relatively modest, the case set a precedent for integrating financial crime investigations into environmental enforcement. This paves the way for future, larger-scale prosecutions by investigators of environmental agencies.\n\n## The case\n\n- 1. In 2021, investigators at the Ministry of Environment and Forestry started investigating indications of illegal logging in Alas Purwo National Park in Banyuwangi, East Java. National Park staff had caught a transporter carrying illegally logged rosewood (sonokeling) .\n- 2 . The  investigation  began  with  an  effort  to  identify who  was  benefiting  from  the  illegal  activities.  A businessman named Supono was later identified as the beneficiary. He was the person who orchestrated the transport of the rosewood logs.\n- 3. In 2022, the Banyuwangi District Court convicted Supono of intentionally transporting and owning forest products (logs of 31 rosewood trees sourced from Alas Purwo National Park) without permit. 2 The Court sentenced Supono to two years in prison and a fine of IDR 500 million (approx. USD 29,900). This first case was pursued purely on the basis of forestry crime charges.\n- 4. The Ministry's investigators continued to pursue the case using a follow-the-money approach to trace the proceeds of the crime. They applied this approach in close collaboration with the Financial Intelligent Unit (PPATK), which contributed key information, and in coordination with the Attorney General's Office. The financial investigation revealed:\n- a. Supono carried out suspicious financial transactions with two sawmill companies, PT Aji Sono and PT Amruu. His later statement during the court  proceedings  disclosed  that  the  logs  he was  trading  with  these  two  companies  were sourced not only from Alas Purwo National Park, but also from other locations, including Lampung, Sulawesi and Sumbawa.\n- b. Between 2020 and 2022, Supono gained approximately USD 127,000 from trading logs with PT Aji Sono (IDR 1,454,440,000) and PT Amruu (IDR 670,980,800).\n\n- c. To conceal the origins of the illegal proceeds, the  two  companies  transferred  the  money for their log purchases to the bank account of Supono's son, which was effectively controlled by Supono himself.\n- d. Supono then moved the money from his son's bank  account  to  his  own  account  in  smaller transactions, both via direct transfer and via cash withdrawal and manual deposits.\n- e. Supono integrated the proceeds of crime with money  he  had  loaned  from  the  bank  in  2020 (when he had no specific need for a bank loan). He then used the illicit funds to pay back the loan. He used this 'loan-back' method to disguise the proceeds of crime as legitimate money from the bank and other unrelated business activities.\n- f. Among other things, Supono used the money from the logging business to buy land.\n- 5. In 2024,  the  Banyuwangi  District  Court  issued its decision No. 11\u002FPid.Sus\u002F2024\u002FPN Byw 3  declaring Supono  guilty  of  money  laundering.  The  Court sentenced  Supono  to  one  year  and  three  months in  prison  and  a  fine  of  IDR  50  million  (approx. USD 3,000). The proceeds of the crime as such were not recovered.\n\nThe illegal logging and money laundering scheme uncovered by investigators of Indonesia's Ministry of Environment and Forestry.\n\n\u003C!-- image -->\n\n## Legal background\n\n- · In  2010,  Indonesia  enacted  the  new  AntiMoney Laundering Law No. 8\u002F2010. 4 It provides  a legal  framework  for  tracing  and prosecuting illicit financial flows, including those  linked  to  environmental  crimes .  This marked a major step towards integrating  financial investigation tools into law enforcement efforts against  money  laundering.  However,  initially, only investigators of traditional law enforcement authorities  were  authorised  to  use  this  law, including from police, the Attorney General's Office, the Corruption Eradication Commission, the National Narcotics Agency, the tax authority and customs.\n- · A  landmark  decision  came  in  2021  when the  Constitutional  Court  issued  its  Decision\n\nNo. 15\u002FPUU-XIX\u002F2021. 5 This authorised investigators in charge of predicate offences, including from natural resources and environmental  authorities,  to  investigate not only environmental  crimes  such  as timber trafficking but also the related money laundering offences .\n\n- · The  Ministry  of  Environment  and  Forestry initiated  several strategic  actions  to  utilise its expanded powers . For example, it reached an  agreement  with  the  Indonesian  Financial Intelligence Unit to develop a joint investigation team. The Ministry also set its investigators the target of handling environmental cases using a  follow-the-money  approach,  and  started collaborating with the Attorney General's Office.\n\n## What can we learn from this case?\n\n## Laws and their interpretation are important….\n\nThe Constitutional Court's 2021 Decision is an important example of how a legal framework can be interpreted to  maximise its effectiveness in practice. In this case, the decision granted investigators from environmental agencies - in addition to investigators from traditional law enforcement agencies - the legal authority to pursue money laundering offences linked to environmental crimes.\n\nIt  empowered investigators to expand their scope and approach, laying the groundwork for more comprehensive enforcement in the future.\n\n## … but using laws in practice requires training and 'learning by doing'\n\nDespite their new powers, the investigators still faced difficulties in tracing illicit financial flows and understanding complex financial transactions linked to environmental crimes. They lacked knowledge and practice in gathering financial intelligence, using investigative technology and cooperating with other agencies domestically or abroad.\n\nOngoing training in financial analysis and intelligence gathering can equip investigators with the necessary skills, tools and networks to tackle money laundering activities, including those linked to environmental crimes.\n\nA  'learning  by  doing'  approach  helps  -  i.e.  applying new skills in realistic case investigations, together with counterparts from other agencies.\n\n## The value of hands-on, inter-agency training\n\nAs part of an Illegal Wildlife Trade (IWT) Challenge  Fund  project, 6   the  Green  Corruption team of  the  Basel  Institute  on  Governance  has trained Indonesian law enforcement agencies to effectively  handle  money  laundering  cases  and track illicit financial flows tied to illegal logging and wildlife-related crimes with the follow-themoney approach.\n\nThe training brought together investigators and prosecutors  from  key  government  agencies, including from the Ministry of Environment and Forestry, Ministry of Marine Affairs and Fisheries, Attorney General's Office and Financial Intelligence Unit. Participants formed inter-agency groups and collaborated on a realistic case scenario, with each person contributing based on their respective role. The training used practical tools and exercises to explain how criminals conceal money and other assets through shell companies, business fronts, real estate investments and tax havens.\n\nBesides training, the Basel Institute also supported the Ministry of Environment and Forestry in developing  guidelines  to  handle  money  laundering cases,  providing  technical  knowledge  on  the investigation process.\n\nIt  was  just  a  few  months  after  the  training  that the Ministry's investigators, in collaboration with the  Attorney  General's  Office  and  the  Financial Intelligence Unit, achieved their first successful convictions for money laundering related to forest crimes.\n\n## Real cases - even when modest - can have a big impact\n\nThis case set a precedent for integrating financial crime investigations into environmental crime cases.\n\nEven  though  the  amount  of  money  laundered  in  this particular case was relatively low - and the fines Supono was sentenced to pay were a small fraction of that amount - the case has opened the door to tackling more complex, high-value cases in the future.\n\nThis first case also played an important role in helping the Ministry of Environment and Forestry's investigators to:\n\n- · shift their perspective from investigating illegal logging crimes only to handling money laundering offences; and\n- · move  from  a  general  understanding  of  money laundering in theory to handling real-life cases in practice.\n\nWhile training and guidelines were necessary to support the process, the real case itself served as a critical opportunity to identify both obstacles and solutions in applying the follow-the-money approach.\n\n## Both leaders and frontline investigators need to take action\n\nEvery natural resource trafficking case has a potential for exploring money laundering due to the amount of money involved in this type of crime.\n\nA  successful  investigation  requires  initiative from investigators and support from decision-makers. In this case of illegal logging in Alas Purwo National Park:\n\n- · The Ministry of Environment and Forestry's Director General and Director of Investigation encouraged investigators to adopt the follow-the-money approach.\n- · At the technical level, investigators put this encouragement  into  action,  demonstrating  their commitment  to  following  the  money  in  existing predicate crime cases.\n\n## Inter-agency collaboration is vital\n\nCoordination between the relevant agencies from the outset of the investigation has been pivotal to concluding the case successfully. The mutual understanding between counterparts from the Ministry of Environment and Forestry, Attorney General's Office and Financial Intelligence Unit provided a strong foundation for the enforcement process.\n\n## Keywords\n\n\u003C!-- image -->\n\nIndonesia\n\nEnvironmental crimes\n\nIllegal logging\n\nMoney laundering\n\nFinancial investigation\n\n## About this Case Study\n\nThis 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  Licence (CC BY-NC-ND 4.0).\n\nSuggested citation: Anindito, Lakso. 2025. 'Indonesia: a  landmark  money  laundering  conviction  in  a  forestry crime case.' Case Study 12, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002F cs-12.\n\n## Acknowledgment and disclaimer\n\n\u003C!-- image -->\n\nThe  development  of  this  publication  was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.\n\nThe 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.\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->","2025-11-25T17:05:34.000Z","- In a case of illegal logging in Alas Purwo National Park, investigators of Indonesia’s Ministry of Environment and Forestry obtained their first money laundering conviction.\n- This achievement was made possible through a 2021 Constitutional Court decision extending the power to pursue money laundering offences to investigators in charge of predicate offences, in this case timber trafficking. This power was previously limited to investigators of traditional law enforcement agencies, including the police and the Corruption Eradication Commission.\n- Training and technical assistance by the Green Corruption programme of the Basel Institute on Governance contributed to strengthening law enforcement capacities to effectively handle money laundering cases and track illicit financial flows tied to environmental crimes.\n- Sustained coordination and collaboration among the Ministry, Indonesia’s Financial Intelligence Unit and the Attorney General’s Office were pivotal in applying the follow-the-money approach to the illegal logging case.\n- Businessman Supono was convicted initially of illegally trading rosewood and later of laundering approximately USD 127,000 he had obtained through log trading. In both cases, he was sentenced to prison and ordered to pay a fine.\n- Although the amount of money laundered in this case and the imposed fines were relatively modest, the case set a precedent for integrating financial crime investigations into environmental enforcement. This paves the way for future, larger-scale prosecutions by investigators of environmental agencies.",[],"\u002Fresources\u002Fpublications\u002Fcs-12",{"id":432,"slug":433,"title":434,"status":6,"nid":7,"year":7,"body":435,"external":17,"topic":7,"language":7,"type":436,"date_published":437,"image":438,"citation":7,"publisher":15,"link_internal":439,"link_external":443,"authors":447,"countries":448,"tags":449,"pdf":462,"topics":464,"featured":17,"languages":465,"summary":466,"programme":7,"area":7,"websites":467,"pdf_text":7,"sort":7,"user_created":8,"date_created":468,"user_updated":8,"date_updated":469,"main_points":7,"short_version":7,"subtitle":7,"og_image":470,"translations_publications":471,"link":472},2466,"business-integrity-in-motion-6th-international-ca-conference-report","Business integrity in motion: Report from the 6th International Collective Action Conference","The 6th International Collective Action Conference (ICAC 2026) took place on 9–10 June 2026 in Basel, Switzerland. It was hosted by the Basel Institute on Governance under the motto \"Business integrity in motion\". This short report summarises the conference highlights.\n\nThe conference's 6th edition brought together around 150 participants from business, civil society, government and academia to explore how Collective Action can help address complex business integrity challenges in an increasingly uncertain global environment.\n\nOver one and a half days, participants shared practical experiences, lessons learned and emerging approaches to collaboration across sectors and stakeholder groups. The programme featured plenary discussions, interactive sessions and peer exchange opportunities covering a wide range of topics, including supply chain integrity, SME engagement, the role of boards, digitalisation and the link between corruption and human rights.\n\nA highlight of the conference was the presentation of the International Collective Action Awards 2026, celebrating outstanding contributions to advancing Collective Action and business integrity.\n\nThe conference reinforced a central theme that resonated throughout the discussions: trust is both a prerequisite for effective collaboration and one of its most valuable outcomes.\n\n## About this report and acknowledgements\n\nThe report is free to share or republish under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International licence ([CC BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002Fdeed.en)).\n\nPhoto by Masi Kaddour\u002FPandeo.\n\nThe Basel Institute on Governance thanks the Siemens Integrity Initiative for supporting the conference’s 6th edition, as well as the conference sponsors AtkinsRéalis and Koenig & Bauer Banknote Solutions SA.\n\nThe full list of presenters and sessions can be found on the conference pages of the [B20 Collective Action Hub](https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fevents\u002Ficac-2026).\n",[29],"2026-09-23","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F2daa38c0-cce2-42b0-b06f-7785b0da3937?format=webp&quality=90&width=600&height=840",[440],{"url":441,"caption":442},"https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fnews\u002Fkeeping-business-integrity-in-motion-collective-action","Read related ICAC 2026 blog",[444],{"url":445,"caption":446},"https:\u002F\u002Fcollective-action.com\u002Fget-involved\u002Fevents\u002Ficac-2026","Conference page on the B20 Collective Action Hub",[],[],[450,454,458],{"tags_id":451},{"id":452,"name":453},909,"Collective Action",{"tags_id":455},{"id":456,"name":457},830,"Business integrity",{"tags_id":459},{"id":460,"name":461},982,"Anti-corruption",[463],2568,[453,24],[27],"The 6th International Collective Action Conference (ICAC 2026) took place on 9–10 June 2026 in Basel, Switzerland. The conference brought together participants across sectors to explore how Collective Action can help address complex business integrity challenges in an increasingly uncertain global environment. The conference report presents the highlights.",[31,453],"2026-09-23T09:01:44.000Z","2026-09-30T07:21:26.000Z","fe722d24-f978-4585-9d5f-b5cfe7b65216",[],"\u002Fresources\u002Fpublications\u002Fbusiness-integrity-in-motion-6th-international-ca-conference-report",{"id":474,"slug":475,"title":476,"status":6,"nid":7,"year":7,"body":477,"external":17,"topic":7,"language":122,"type":478,"date_published":479,"image":480,"citation":7,"publisher":481,"link_internal":482,"link_external":492,"authors":496,"countries":525,"tags":528,"pdf":535,"topics":537,"featured":17,"languages":539,"summary":541,"programme":7,"area":7,"websites":542,"pdf_text":7,"sort":7,"user_created":8,"date_created":543,"user_updated":143,"date_updated":544,"main_points":7,"short_version":545,"subtitle":7,"og_image":546,"translations_publications":547,"link":548},2448,"la-extincion-de-dominio-instrumentos-internacionales","La extinción de dominio en el marco de los estándares e instrumentos internacionales","Non-conviction based asset forfeiture has become a key tool for recovering illicit assets and supporting contemporary criminal policy against organised crime, corruption and transnational financial crime. Across seven chapters, this publication (in Spanish) connects international standards with Peruvian practice.\n\nIt explores the foundations of non-conviction based asset forfeiture from various angles:\n- Non-conviction based forfeiture in the Vienna, Palermo and Mérida Conventions\n- The alignment of Peru’s non-conviction based forfeiture model – Extinción de dominio – with the United Nations Office on Drugs and Crime (UNODC) Model Law\n- Its compatibility with the Recommendations of the Financial Action Task Force (FATF), specifically Recommendation 4 on confiscation and provisional measures\n- The operational challenges of managing seized assets to preserve their value in light of FATF Recommendation 4\n- Non-conviction based asset forfeiture as a preventive mechanism, with lessons from Italian preventive confiscation\n- A comparative analysis of U.S. civil forfeiture and Peru’s Extinción de dominio\n- Peru’s Extinción de dominio and constitutional property rights, with insights from the regional Latin American experience\n\nGrounded in domestic practice and addressing the effects of recent legislative amendments, the publication offers judges, prosecutors, legislators and scholars a timely guide to applying, interpreting and strengthening asset forfeiture in line with international commitments.\n\nThis is the third issue in a series of publications on the use of Peru’s Extinción de dominio legislation. It is a collaborative effort of asset recovery experts of the Basel Institute on Governance under the [Programa GFP Subnacional](https:\u002F\u002Fwww.gfpsubnacional.pe\u002F) (Subnational Public Finance Management programme in Peru), funded by the Swiss SECO Cooperation.\n\n- Foreword by Sergio Jiménez Niño, Thematic Coordinator of the Asset Recovery Component, Programa GFP Subnacional\n- Preface by Oscar Solórzano, Head, Latin America ICAR\n",[29],"2026-06-12","https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F0636208c-72f4-46c1-9ace-cc72e8f79ea8?format=webp&quality=90&width=600&height=840","Programa GFP Subnacional – Basel Institute on Governance",[483,486,489],{"url":484,"caption":485},"https:\u002F\u002Fbaselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Fc5aea639-e1c8-4f33-bcd2-1cc8965c068c\u002FPublicacion_Extincion-Dominio_instrumentos_internacionales.pdf?v=20260716155833000","Download PDF (Spanish)",{"url":487,"caption":488},"https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002Fla-extincion-del-dominio-de-bienes-instrumentalizados\u002F","Read the first issue of the series (in Spanish)",{"url":490,"caption":491},"https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002Fla-extincion-de-dominio-desde-sus-principios\u002F","Read the second issue of the series (in Spanish)",[493],{"url":494,"caption":495},"https:\u002F\u002Fwww.gfpsubnacional.pe\u002Fpublicacion\u002Fla-extincion-de-dominio-en-el-marco-de-los-estandares-e-instrumentos-internacionales\u002F","Access this publication via Programa GFP website",[497,501,505,509,513,517,521],{"authors_id":498},{"id":499,"name":500},544,"Sergio Jiménez",{"authors_id":502},{"id":503,"name":504},600,"Jhanira Morales",{"authors_id":506},{"id":507,"name":508},542,"Walther Delgado",{"authors_id":510},{"id":511,"name":512},601,"Joseph Domínguez",{"authors_id":514},{"id":515,"name":516},545,"Sergio Rodriguez",{"authors_id":518},{"id":519,"name":520},602,"Deily Pereda",{"authors_id":522},{"id":523,"name":524},603,"Michel Risco",[526],{"countries_id":527},{"id":255,"name":256},[529,531,533],{"tags_id":530},{"id":272,"name":273},{"tags_id":532},{"id":92,"name":93},{"tags_id":534},{"id":98,"name":99},[536],2557,[25,538],"Public Financial Management",[540],"Spanish","Non-conviction based asset forfeiture has become a key tool for recovering illicit assets and supporting contemporary criminal policy against organised crime, corruption and transnational financial crime. Across seven chapters, this publication (in Spanish) connects international standards with Peruvian practice.",[31],"2026-07-16T16:05:53.000Z","2026-10-20T09:54:22.000Z","**Chapter summaries in English:**\n\n## Chapter 1: Non-conviction based forfeiture in United Nations conventions\nAuthor: Sergio Jiménez Niño\n\nChapter 1 explores whether Peru’s Extinción de dominio has a direct treaty basis in United Nations conventions. It argues that the Vienna and Palermo Conventions do not recognise non-conviction-based forfeiture as they focus on criminal confiscation linked to prosecution. In Vienna, proposals for forfeiture without conviction were expressly rejected to protect property rights and the presumption of innocence. Although the Mérida Convention mentions the concept, it remains an optional international cooperation measure where prosecution is impossible due to death, flight or absence of the offender.\n\nThe chapter concludes that Peru’s regime is not treaty-mandated, but this does not affect the constitutional validity or policy legitimacy of Peru's Legislative Decree 1373 on Extinción de dominio.\n\n## Chapter 2: The Peruvian non-conviction based model in the light of the UNODC Model Law\nAuthor: Jhanira Morales Aniceto\n\nChapter 2 compares Peru’s Extinción de dominio regime with the UNODC Model Law, a non-binding soft law instrument for asset recovery. The analysis focuses on four main elements: the property-based nature of the forfeiture, procedural autonomy, the concept of illicit activity and temporal scope.\n\nWhile both frameworks treat forfeiture is an action in rem directed at assets, recent Peruvian reforms have caused significant divergences. Peru now applies more conditional autonomy, narrows illicit activity to criminal conduct and imposes temporal limits, including restrictions on retrospective application. Consequently, Peru exhibits a selective adoption of the UNODC Model Law. This does not, however, constitute a breach of international obligations, since the Model Law is not binding.\n\n## Chapter 3: Extinción de dominio in Peru: compliance, gaps and the reform agenda within the framework of the FATF recommendations\nAuthor: Walther Javier Delgado Tovar\n\nChapter 3 assesses Peru’s non-conviction based forfeiture framework against Financial Action Task Force (FATF) Recommendation 4 on confiscation and provisional measures, and its interpretive notes. It notes that, although FATF standards are non-binding soft law, weak implementation can expose countries to greylisting or blacklisting, with serious economic and reputational consequences.\n\nThe analysis finds that Peru broadly complies with FATF standards, but identifies important gaps. Recent legislative amendments and Constitutional Court rulings have weakened the autonomy and scope of Extinción de dominio, while issues remain around victim compensation, transaction suspension measures and recognition of foreign forfeiture orders. To maintain a priority policy on asset recovery, the author advocates for legislative reforms that ensure a consistent, human rights-compliant application of asset forfeiture with and without conviction.\n\n## Chapter 4: Preserving the value of assets seized in asset forfeiture proceedings: with reference to FATF Recommendation 4\nAuthor: Joseph Domínguez Miñano\n\nChapter 4 looks at the management and preservation of seized assets in Peru in light of FATF Recommendation 4. It argues that managing seized asset is a key component of asset recovery, and that poor asset management can cause assets to depreciate, deteriorate or create liabilities for the state in cases where the assets must later be returned.\n\nThe analysis focuses on PRONABI, Peru’s specialised body for managing seized and forfeited assets. Identified challenges include limited use of early sale mechanisms, institutional overload and the lack of uniform technical criteria, especially for depreciating assets such as vehicles. It calls for stronger guidelines, better return protocols and improved institutional capacity to preserve the assets’ economic value effectively.\n\n## Chapter 5: The forfeiture of illicit proceeds as a preventive measure: Reflections based on the Italian anti-Mafia confiscation system\nAuthor: Sergio Rodríguez Salinas\n\nChapter 5 examines Peru’s Extinción de dominio through a preventive lens, referencing Italy’s anti-mafia confisca di prevenzione. It argues that organised crime operates as an economic enterprise, using illicit proceeds to accumulate wealth, reinvest and sustain criminal structures. This justifies preventive measures aimed at neutralising the economic danger posed by certain assets.\n\nDrawing on the Italian preventive confiscation model, the chapter proposes understanding Peru’s non-conviction based forfeiture as a preventive mechanism rather than a punitive power. This helps explain its autonomy from criminal proceedings and absence of a prior conviction, but also sets limits: its legitimacy depends on a clear link to organised crime, serious corruption and systemic criminal financing.\n\n## Chapter 6: Extinción de dominio and civil forfeiture\nAuthor: Deily Pereda Rodríguez\n\nChapter 6 compares US civil forfeiture with Peru’s Extinción de dominio as mechanisms for recovering assets without a criminal conviction. It outlines the US distinction between administrative, criminal and civil forfeiture, noting that civil forfeiture operates as an autonomous in rem process. While both the US and Peruvian regimes target illicit assets, recent Peruvian reforms have compromised procedural autonomy of Extinción de dominio by generally requiring a prior final criminal judgement.\n\nThe chapter identifies lessons for Peru. It highlights the value of using recovered assets to compensate victims and warns against revenue-driven incentives such as those criticised in the US Equitable Sharing Program. Ultimately, it advocates for an approach that prioritises victims’ rights and maintains the integrity of the constitutional rule of law.\n\n## Chapter 7: Extinción de dominio and property rights in Peru: a constitutional analysis in the light of regional experience\nAuthor: Michel Risco Solis\n\nChapter 7 explores whether Peru’s Extinción de dominio is compatible with the constitutional right to property. It argues that express constitutional recognition of Peru’s asset forfeiture regime is not necessary, because the Constitution protects only property rights that are lawfully acquired and exercised in line with the legal order, the common good and the social function of property. Moreover, the right to property is not understood as an absolute guarantee over any form of property. The chapter maintains that Extinción de dominio targets assets of illicit origin or destination that fall outside constitutional protection.\n\nRegional experience also shows that express inclusion of asset forfeiture in the constitution, as in Colombia or Mexico, may broaden the scope of state intervention, but is not required for the mechanism’s validity.\n","9373147f-6613-466d-bc86-2654c923f4fd",[],"\u002Fresources\u002Fpublications\u002Fla-extincion-de-dominio-instrumentos-internacionales",1794404998588]