[{"data":1,"prerenderedAt":644},["ShallowReactive",2],{"publication-quick-guide-28-money-laundering-through-gambling-industry":3,"related-quick-guide-28-money-laundering-through-gambling-industry":169},[4],{"id":5,"status":6,"sort":7,"date_created":8,"date_updated":9,"nid":10,"slug":11,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":20,"link_internal":22,"link_external":26,"featured":19,"topics":30,"languages":32,"type":33,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"image":35,"countries":46,"tags":47,"pdf":90,"authors":133},2229,"published",null,"2022-09-08T22:04:02.000Z","2026-06-02T14:09:01.000Z",2283,"quick-guide-28-money-laundering-through-gambling-industry","Quick Guide 28: Money laundering through the gambling industry","This quick guide sets out how criminals abuse the gambling industry to launder illicit funds. It includes numerous recent case studies to illustrate different ways of laundering money in casinos, online gambling websites, bars and clubs, as well as physical and online sports betting services.\n\nThe guide also looks at what gambling businesses and public authorities can do to better prevent and detect money laundering in this industry.\n\n### About this Quick Guide\n\nThis work is licensed under a \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License\u003C\u002Fa>. It is part of the Basel Institute on Governance Quick Guide series, \u003Ca href=\"https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428\">ISSN 2673-5229\u003C\u002Fa>.","","English",2022,"Basel Institute on Governance","2022-09-09",false,[21],"Asset Recovery",[23],{"url":24,"caption":25},"\u002Fresources\u002Fpublications?type=Quick%20Guide"," View all Quick Guides",[27],{"url":28,"caption":29},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=150"," View on Basel LEARN (html)",[31],"Asset Recovery and Enforcement",[15],[34],"Quick Guide",{"id":36,"storage":37,"filename_disk":38,"filename_download":39,"title":40,"type":41,"created_on":8,"modified_on":8,"charset":7,"filesize":42,"width":43,"height":44,"duration":7,"embed":7,"description":7,"location":7,"tags":7,"metadata":45,"focal_point_x":7,"focal_point_y":7,"tus_id":7,"tus_data":7,"uploaded_on":8},"99ab83e1-666d-4705-b8dc-6214b40274b9","local","99ab83e1-666d-4705-b8dc-6214b40274b9.jpg?itok=qJu63vzb","Pages-from-QG28-gambling.jpg?itok=qJu63vzb","Pages from QG28 gambling.jpg","image\u002Fjpeg",57491,500,707,{},[],[48,73],{"id":49,"publications_id":50,"tags_id":70},4389,{"id":5,"status":6,"sort":7,"user_created":51,"date_created":8,"user_updated":52,"date_updated":9,"nid":10,"slug":11,"image":36,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":53,"link_internal":54,"link_external":56,"featured":19,"topics":58,"languages":59,"type":60,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":61,"tags":62,"pdf":64,"authors":67},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","3d9ff205-1640-4f34-b5b6-86977f51bbd6",[21],[55],{"url":24,"caption":25},[57],{"url":28,"caption":29},[31],[15],[34],[],[49,63],4808,[65,66],2269,2270,[68,69],2455,2456,{"id":71,"name":72},879,"Money laundering",{"id":63,"publications_id":74,"tags_id":87},{"id":5,"status":6,"sort":7,"user_created":51,"date_created":8,"user_updated":52,"date_updated":9,"nid":10,"slug":11,"image":36,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":75,"link_internal":76,"link_external":78,"featured":19,"topics":80,"languages":81,"type":82,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":83,"tags":84,"pdf":85,"authors":86},[21],[77],{"url":24,"caption":25},[79],{"url":28,"caption":29},[31],[15],[34],[],[49,63],[65,66],[68,69],{"id":88,"name":89},818,"Anti-money laundering",[91,113],{"id":65,"publications_id":92,"directus_files_id":105},{"id":5,"status":6,"sort":7,"user_created":51,"date_created":8,"user_updated":52,"date_updated":9,"nid":10,"slug":11,"image":36,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":93,"link_internal":94,"link_external":96,"featured":19,"topics":98,"languages":99,"type":100,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":101,"tags":102,"pdf":103,"authors":104},[21],[95],{"url":24,"caption":25},[97],{"url":28,"caption":29},[31],[15],[34],[],[49,63],[65,66],[68,69],{"id":106,"storage":37,"filename_disk":107,"filename_download":108,"title":108,"type":109,"folder":110,"uploaded_by":51,"created_on":8,"modified_by":7,"modified_on":8,"charset":7,"filesize":111,"width":7,"height":7,"duration":7,"embed":7,"description":112,"location":7,"tags":7,"metadata":7,"focal_point_x":7,"focal_point_y":7,"tus_id":7,"tus_data":7,"uploaded_on":8},"09f5a6a5-40d5-41a5-92b9-b26f933e8dc5","09f5a6a5-40d5-41a5-92b9-b26f933e8dc5.pdf","QG28-gambling.pdf","application\u002Fpdf","67f22e04-d26f-4baa-b91f-acc5f89d87f5",1065131,"PDF: Quick Guide 28: Money laundering through the gambling industry",{"id":66,"publications_id":114,"directus_files_id":127},{"id":5,"status":6,"sort":7,"user_created":51,"date_created":8,"user_updated":52,"date_updated":9,"nid":10,"slug":11,"image":36,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":115,"link_internal":116,"link_external":118,"featured":19,"topics":120,"languages":121,"type":122,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":123,"tags":124,"pdf":125,"authors":126},[21],[117],{"url":24,"caption":25},[119],{"url":28,"caption":29},[31],[15],[34],[],[49,63],[65,66],[68,69],{"id":128,"storage":37,"filename_disk":129,"filename_download":130,"title":130,"type":109,"folder":110,"uploaded_by":51,"created_on":8,"modified_by":7,"modified_on":8,"charset":7,"filesize":131,"width":7,"height":7,"duration":7,"embed":7,"description":132,"location":7,"tags":7,"metadata":7,"focal_point_x":7,"focal_point_y":7,"tus_id":7,"tus_data":7,"uploaded_on":8},"c0acb748-9e74-4f5d-8137-46b148450ad2","c0acb748-9e74-4f5d-8137-46b148450ad2.pdf","QG28-further-reading.pdf",66743," View recommended reading list on gambling and money laundering",[134,151],{"id":68,"publications_id":135,"authors_id":148},{"id":5,"status":6,"sort":7,"user_created":51,"date_created":8,"user_updated":52,"date_updated":9,"nid":10,"slug":11,"image":36,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":136,"link_internal":137,"link_external":139,"featured":19,"topics":141,"languages":142,"type":143,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":144,"tags":145,"pdf":146,"authors":147},[21],[138],{"url":24,"caption":25},[140],{"url":28,"caption":29},[31],[15],[34],[],[49,63],[65,66],[68,69],{"id":149,"name":150,"position":7,"image":7},510,"Isys Lam",{"id":69,"publications_id":152,"authors_id":165},{"id":5,"status":6,"sort":7,"user_created":51,"date_created":8,"user_updated":52,"date_updated":9,"nid":10,"slug":11,"image":36,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":153,"link_internal":154,"link_external":156,"featured":19,"topics":158,"languages":159,"type":160,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":161,"tags":162,"pdf":163,"authors":164},[21],[155],{"url":24,"caption":25},[157],{"url":28,"caption":29},[31],[15],[34],[],[49,63],[65,66],[68,69],{"id":166,"name":167,"position":7,"image":168},306,"Andrew Dornbierer","89aae58b-3e50-4375-9b9b-5b31370dab64",[170,204,258,295,362,396,436,480,527,574],{"id":171,"slug":172,"title":173,"status":6,"nid":174,"year":175,"body":176,"external":19,"topic":177,"language":15,"type":179,"date_published":180,"image":181,"citation":14,"publisher":17,"link_internal":182,"link_external":183,"authors":187,"countries":190,"tags":191,"pdf":196,"topics":199,"featured":19,"languages":200,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":51,"date_created":201,"user_updated":52,"date_updated":202,"main_points":7,"short_version":7,"subtitle":7,"link":203},2276,"quick-guide-29-money-laundering-and-sanctions-evasion-using-art-market","Quick Guide 29: Money laundering and sanctions evasion using the art market",2428,2023,"The art market is often described as ‘niche’. In reality, it is a significant trade industry: sales of art and antiques by dealers and auction houses reached an estimated USD 65.1 billion in 2021. And like many industries of this size, it attracts people seeking to abuse it to launder proceeds of crime or evade sanctions.\n\nThis quick guide briefly explains the unique characteristics of the art market that make it vulnerable to this type of abuse. It also outlines steps that jurisdictions can take to prevent and combat abuse of the sector for illicit purposes.\n\n### About this Quick Guide\n\nThis work is licensed under a \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License\u003C\u002Fa>. It is part of the Basel Institute on Governance Quick Guide series, \u003Ca href=\"https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428\">ISSN 2673-5229\u003C\u002Fa>.",[178,21],"Anti-Money Laundering",[34],"2023-04-12","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F8029c862-8f97-4c17-8c3d-570ea42a1ba4?width=600&height=840",[],[184],{"url":185,"caption":186},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=176"," View on Basel LEARN",[188],{"authors_id":189},{"id":166,"name":167},[],[192,194],{"tags_id":193},{"id":71,"name":72},{"tags_id":195},{"id":88,"name":89},[197,198],2312,2313,[178,31],[15],"2023-04-12T10:04:20.000Z","2026-05-31T22:52:11.000Z","\u002Fresources\u002Fpublications\u002Fquick-guide-29-money-laundering-and-sanctions-evasion-using-art-market",{"id":10,"slug":205,"title":206,"status":6,"nid":207,"year":175,"body":208,"external":19,"topic":209,"language":15,"type":211,"date_published":213,"image":214,"citation":14,"publisher":17,"link_internal":215,"link_external":222,"authors":223,"countries":228,"tags":237,"pdf":250,"topics":252,"featured":19,"languages":254,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":51,"date_created":255,"user_updated":52,"date_updated":256,"main_points":7,"short_version":7,"subtitle":7,"link":257},"research-case-3","Research Case Study 3: Exposing the networks behind transnational corruption and money laundering schemes",2454,"Corruption is increasingly understood as a form of collective, social behaviour. It slips easily across borders and involves sophisticated financial strategies and transactions to launder the stolen money. \n\nYet the nexus between corruption and money laundering is poorly understood. So too are the structures, functions and mechanisms that enable these crimes.\n\nWe applied analytical tools to reveal the complex networks behind a corruption and money laundering scheme involving Odebrecht and Peru’s former president. The insights can support strategic approaches to fight transnational corruption.",[210],"Public Governance",[212],"Research Case Study","2023-05-31","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fca5d66b9-58f2-42fd-afa6-1d3224f01f9d?width=600&height=840",[216,219],{"url":217,"caption":218},"\u002Fresources\u002Fpublications\u002Fworking-paper-36-revealing-networks-behind-corruption-and-money-laundering-schemes"," View related Working Paper",{"url":220,"caption":221},"\u002Fresources\u002Fpublications?type=Research%20Case%20Study"," View all research case studies",[],[224],{"authors_id":225},{"id":226,"name":227},304,"Jacopo Costa",[229,233],{"countries_id":230},{"id":231,"name":232},171,"Peru",{"countries_id":234},{"id":235,"name":236},29,"Brazil",[238,240,244,248],{"tags_id":239},{"id":71,"name":72},{"tags_id":241},{"id":242,"name":243},1309,"Informality",{"tags_id":245},{"id":246,"name":247},1373,"Corruption prevention",{"tags_id":249},{"id":88,"name":89},[251],2318,[253],"Corruption Prevention and Public Governance",[15],"2023-05-31T10:04:29.000Z","2026-06-02T14:09:06.000Z","\u002Fresources\u002Fpublications\u002Fresearch-case-3",{"id":259,"slug":260,"title":261,"status":6,"nid":262,"year":263,"body":264,"external":19,"topic":265,"language":15,"type":266,"date_published":267,"image":268,"citation":14,"publisher":17,"link_internal":269,"link_external":270,"authors":271,"countries":276,"tags":277,"pdf":288,"topics":290,"featured":19,"languages":291,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":51,"date_created":292,"user_updated":52,"date_updated":293,"main_points":7,"short_version":7,"subtitle":7,"link":294},2378,"qg34","Quick Guide 34: Public-private partnerships for financial intelligence sharing",2724,2024,"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 \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">Creative Commons BY-NC-ND 4.0 Licence\u003C\u002Fa>. It is part of the Basel Institute on Governance Quick Guide series, \u003Ca href=\"https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428\">ISSN 2673-5229\u003C\u002Fa>.",[178,21],[34],"2024-11-25","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F01dea28f-22b8-47cd-bf86-ddee24683c2b?width=600&height=840",[],[],[272],{"authors_id":273},{"id":274,"name":275},327,"Simon Marsh",[],[278,282,284],{"tags_id":279},{"id":280,"name":281},1193,"Financial investigations",{"tags_id":283},{"id":88,"name":89},{"tags_id":285},{"id":286,"name":287},1374,"Law enforcement",[289],2416,[178,31],[15],"2024-12-05T14:06:47.000Z","2026-05-31T22:51:55.000Z","\u002Fresources\u002Fpublications\u002Fqg34",{"id":296,"slug":297,"title":298,"status":6,"nid":299,"year":300,"body":301,"external":19,"topic":7,"language":7,"type":302,"date_published":304,"image":305,"citation":306,"publisher":17,"link_internal":307,"link_external":314,"authors":321,"countries":330,"tags":335,"pdf":352,"topics":354,"featured":19,"languages":355,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":52,"date_created":356,"user_updated":357,"date_updated":358,"main_points":359,"short_version":7,"subtitle":360,"link":361},2441,"cs-13","Case Study 13: The Beauty Queen case: non-conviction based forfeiture across borders",2937,2026,"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.\n\nThe 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.\n\n[**Download Case Study here**](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-05\u002FCase-Study-13_Beauty-Queen.pdf)\n\nOn 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.\n\nThe 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.\n\nOn 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.\n\nThis marked Colombia’s first successful international recovery through non-conviction based forfeiture.\n\nThis 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.\n\nThe interaction between the authorities in both jurisdictions offers valuable lessons and examples of good practices.\n\n**Main takeaways of the case:**\n\n- Early and trust-based international cooperation is decisive\n- Non-conviction based forfeiture is indispensable when criminal routes are closed\n- Identifying beneficial ownership is central to effective asset recovery\n- Direct enforcement of foreign forfeiture orders increases efficiency and legal certainty\n- Asset sharing agreements strengthen cooperation incentives\n\nThe Case Study can be read alongside [Policy Brief 16](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-16): \"Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres\".\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 BYNC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F)).\n\nThe Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery.\n\nThis 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.\n\n**Disclaimer**: This Case Study is intended for general informational purposes and does not constitute and\u002For 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.\n",[303],"Case Study","2026-03-31","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F6f1661b8-eab6-4ce0-902d-f6c97f85dd29?width=600&height=840","Solórzano, Oscar, and Diana Cordero. 2026. ‘The Beauty Queen case: non-conviction based forfeiture of criminal assets across borders. Lessons learned from Colombia–Guernsey cooperation.’ Case Study 13, Basel Institute on Governance. Available at: [baselgovernance.org\u002Fpublications\u002Fcs-13](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-13).",[308,311],{"url":309,"caption":310},"\u002Fresources\u002Fnews\u002Fcolombiaguernsey-cooperation-leads-to-successful-non-conviction-based-forfeiture-of-illicit-assets-2716","Read related blog",{"url":312,"caption":313},"\u002Fresources\u002Fpublications","Read related Policy Brief 16",[315,318],{"url":316,"caption":317},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=368","View online on Basel LEARN",{"url":319,"caption":320},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=72","eLearning course: International Cooperation and Mutual Legal Assistance in Criminal Matters",[322,326],{"authors_id":323},{"id":324,"name":325},294,"Oscar Solorzano",{"authors_id":327},{"id":328,"name":329},591,"Diana Cordero",[331],{"countries_id":332},{"id":333,"name":334},47,"Colombia",[336,340,344,346,348],{"tags_id":337},{"id":338,"name":339},1379,"Non-conviction based forfeiture",{"tags_id":341},{"id":342,"name":343},822,"International cooperation",{"tags_id":345},{"id":88,"name":89},{"tags_id":347},{"id":286,"name":287},{"tags_id":349},{"id":350,"name":351},843,"Asset recovery",[353],2495,[31],[15],"2026-06-01T22:10:26.000Z","b0662e2a-864d-4888-a1b7-4342b7570b30","2026-06-02T14:22:13.000Z","- Early and trust-based international cooperation is decisive\n- Non-conviction based forfeiture is indispensable when criminal routes are closed\n- Identifying beneficial ownership is central to effective asset recovery\n- Direct enforcement of foreign forfeiture orders increases efficiency and legal certainty\n- Asset sharing agreements strengthen cooperation incentives","Lessons learned from Colombia–Guernsey cooperation","\u002Fresources\u002Fpublications\u002Fcs-13",{"id":363,"slug":364,"title":365,"status":6,"nid":366,"year":300,"body":367,"external":19,"topic":7,"language":7,"type":368,"date_published":304,"image":370,"citation":7,"publisher":17,"link_internal":371,"link_external":374,"authors":376,"countries":379,"tags":380,"pdf":389,"topics":391,"featured":19,"languages":392,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":52,"date_created":356,"user_updated":52,"date_updated":393,"main_points":7,"short_version":7,"subtitle":394,"link":395},2442,"pb-16","Policy Brief 16: Enforcing foreign non-conviction based forfeiture orders",2947,"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.\n\n[**Download Policy Brief here**](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-03\u002FPolicy-Brief-16_Enforcing-foreign-NCBF-orders.pdf)\n\nRevisions 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.\n\nThrough 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.\n\nIn 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.\n\nThe 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.\n\nThis Policy Brief can be read alongside [Case Study 13](http:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-13): “The Beauty Queen case: non-conviction based forfeiture across borders. Lessons learned from Colombia–Guernsey cooperation.”\n\n### About this Policy Brief\n\nThis publication is part of the Basel Institute on Governance Policy Brief series [ISSN 2624-9669](https:\u002F\u002Fbaselgovernance.org\u002Fpublications?type\\[]=257). You may freely share or republish it under a Creative Commons [BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F) licence.\n\nIt 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.\n\n**Disclaimer**: This Policy Brief is intended for general informational purposes and does not constitute and\u002For 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.\n\n**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\u002Fpublications\u002Fpb-16](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-16).",[369],"Policy Brief","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Ff866220c-dddd-41b3-a45e-c2d7992d39e1?width=600&height=840",[372],{"url":312,"caption":373},"Read related Case Study 13",[375],{"url":319,"caption":320},[377],{"authors_id":378},{"id":324,"name":325},[],[381,383,385,387],{"tags_id":382},{"id":338,"name":339},{"tags_id":384},{"id":342,"name":343},{"tags_id":386},{"id":88,"name":89},{"tags_id":388},{"id":286,"name":287},[390],2496,[31],[15],"2026-06-02T14:16:22.000Z","FATF standards and asset recovery practice in Latin America and financial centres","\u002Fresources\u002Fpublications\u002Fpb-16",{"id":397,"slug":398,"title":399,"status":6,"nid":400,"year":401,"body":402,"external":19,"topic":403,"language":15,"type":404,"date_published":406,"image":407,"citation":14,"publisher":408,"link_internal":409,"link_external":410,"authors":414,"countries":417,"tags":422,"pdf":431,"topics":432,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":51,"date_created":433,"user_updated":52,"date_updated":434,"main_points":7,"short_version":7,"subtitle":7,"link":435},2424,"back-action-how-uk-reviving-unexplained-wealth-orders-academy-bulletin","Back in Action: How the UK is reviving unexplained wealth orders (The Academy Bulletin)",2864,2025,"In an article published in the Fall 2025 issue of the Bulletin of the \u003Ca href=\"https:\u002F\u002Ffinancialcrimelitigators.org\u002F\">International Academy of Financial Crime Litigators\u003C\u002Fa>, Andrew Dornbierer explores the revival of unexplained wealth orders (UWOs) in the United Kingdom.\n\nIntroduced 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.\n\nIn 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.\n\nThis 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.\n\nThis 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.",[21],[405],"Article","2025-11-03","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc313d2fa-3e1c-43ab-b40e-3e418d819df1?width=600&height=840","International Academy of Financial Crime Litigators",[],[411],{"url":412,"caption":413},"https:\u002F\u002Fedit.financialcrimelitigators.org\u002Fapi\u002Fassets\u002Fb401d6c9-b0e4-4ab9-ad1f-948c567c6ab3.pdf","Fall 2025 Bulletin of the International Academy of Financial Crime Litigators",[415],{"authors_id":416},{"id":166,"name":167},[418],{"countries_id":419},{"id":420,"name":421},225,"Ukraine",[423,425,427],{"tags_id":424},{"id":350,"name":351},{"tags_id":426},{"id":88,"name":89},{"tags_id":428},{"id":429,"name":430},821,"Unexplained wealth",[],[31],"2025-11-03T11:05:50.000Z","2026-05-29T22:23:01.000Z","\u002Fresources\u002Fpublications\u002Fback-action-how-uk-reviving-unexplained-wealth-orders-academy-bulletin",{"id":437,"slug":438,"title":439,"status":6,"nid":440,"year":175,"body":441,"external":19,"topic":442,"language":15,"type":443,"date_published":444,"image":445,"citation":14,"publisher":17,"link_internal":446,"link_external":450,"authors":454,"countries":459,"tags":460,"pdf":473,"topics":475,"featured":19,"languages":476,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":51,"date_created":477,"user_updated":52,"date_updated":478,"main_points":7,"short_version":7,"subtitle":7,"link":479},2295,"pb-12","Policy Brief 12: De-risking of Russian clients: best intentions, unintended consequences",2480,"After the Russian invasion of Ukraine and the wide-reaching sanctions which ensued, many Western financial institutions began to de-risk Russian clients. Dealing with Russian clients, in many cases, has become expensive from a compliance point of view and toxic from the reputational side.\n\nHowever, the de-risking of unsanctioned Russian individuals may have a significant impact on the fight against financial crime by potentially causing:\n\n\n- an increase in the use of shadow\u002Funregulated channels of moving money;\n- a withdrawal of funds away from the European zone to sanctioned countries or non-cooperative jurisdictions;\n- severe burdens on the investigation of financial crimes (especially in relation to Russian assets and investments) and on international cooperation in criminal matters;\n- increased opportunities for enablers, such as unscrupulous lawyers and accountants, to take advantage of the situation.\n\n\nThis Policy Brief outlines the current situation and suggests how to better manage risk without having a negative impact on the fight against financial crime.\n\n### About this Policy Brief\n\nThis publication is part of the Basel Institute on Governance Policy Brief series, \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications?type[]=257\">ISSN 2624-9669\u003C\u002Fa> and relates to the Basel AML Index of money laundering risk.\n\nYou may freely share or republish it under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (\u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa>). Suggested citation: Boguslavska, Kateryna. 2023. ‘De-risking of Russian clients: best intentions, unintended consequences.’ Policy Brief 12, Basel Institute on Governance, \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12\">https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12\u003C\u002Fa>.",[178,21],[369],"2023-06-30","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F8013d7b0-82aa-46f8-bde7-a8790f71a59e?width=600&height=840",[447],{"url":448,"caption":449},"\u002Fresources\u002Fpublications?type=Policy%20Brief"," View all Policy Briefs",[451],{"url":452,"caption":453},"https:\u002F\u002Findex.baselgovernance.org\u002F"," Visit Basel AML Index website",[455],{"authors_id":456},{"id":457,"name":458},301,"Kateryna Boguslavska",[],[461,463,467,471],{"tags_id":462},{"id":88,"name":89},{"tags_id":464},{"id":465,"name":466},1236,"Compliance",{"tags_id":468},{"id":469,"name":470},1227,"Sanctions",{"tags_id":472},{"id":286,"name":287},[474],2333,[178,31],[15],"2023-06-30T08:38:07.000Z","2026-06-02T14:09:08.000Z","\u002Fresources\u002Fpublications\u002Fpb-12",{"id":481,"slug":482,"title":483,"status":6,"nid":484,"year":16,"body":485,"external":19,"topic":486,"language":15,"type":487,"date_published":489,"image":490,"citation":14,"publisher":17,"link_internal":491,"link_external":495,"authors":499,"countries":506,"tags":511,"pdf":520,"topics":522,"featured":19,"languages":523,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":51,"date_created":524,"user_updated":52,"date_updated":525,"main_points":7,"short_version":7,"subtitle":7,"link":526},2232,"wp-41","Working Paper 41: Targeting unexplained wealth in British Columbia",2288,"The final recommendation of the Commission of Inquiry into Money Laundering in British Columbia (‘the Commission’) urged the government to legislate an unexplained wealth order (‘UWO’) as part of a wider approach to counter the prevalence of money laundering and proceeds of crime in the province.\n\nThis document analyses the feasibility of this recommendation. It:\n\n\n- **briefly explains the concept of unexplained wealth** and how it can be targeted through legislative instruments;\n- **outlines the reasons** for which the Commissioner proposed a UWO for British Columbia;\n- **explains how a UK-style UWO works** and assess the probability that a mechanism of this kind would successfully recover unexplained wealth in British Columbia; \n- **addresses the constitutional issues** that may arise if a UK-style UWO was introduced, as outlined by former Supreme Court Justice, the Honourable Thomas A. Cromwell C.C., in his annexed opinion to the report;\n- **explains other legislative options** that target unexplained wealth (including those in Western Australia and Ireland) and assess their constitutional compatibility and potential effectiveness as compared to a UK-style UWO;\n- **explores the legal rights issues** that may arise if either a UK-style UWO or a traditional UWO was introduced; and\n- **outlines the legislative safeguards** that could be put in place to reduce the risk that any such mechanisms would negatively impact on established legal rights.\n\n\n### About and acknowledgements\n\nThis document has been prepared by experts working with the Basel Institute on Governance, an independent not-for-profit organisation dedicated to countering corruption and other financial crimes, and the Vancouver Anti-Corruption Institute, an organisation devoted to anti-corruption efforts and legislative change. The collaboration was facilitated by the International Academy of Financial Crime Litigators, an independent, non-partisan global centre that shapes and advances financial crime litigation practices for the future.\n\n### Open-access licence and citation\n\nThe publication is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. It is licensed for sharing and republishing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (\u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa>).\n\nSuggested citation: Dornbierer, Andrew, and Jeffrey Simser. 2022. “Targeting unexplained wealth in British Columbia: An analysis of Recommendation 101 of the Final Report of the Commission of Inquiry into Money Laundering in British Columbia.” Working Paper 41, Basel Institute on Governance. Available at: baselgovernance.org\u002Fpublications\u002Fwp-41",[178,21],[488],"Working Paper","2022-10-03","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fffb4289a-9a4b-434e-92bb-f85b8268c774?width=600&height=840",[492],{"url":493,"caption":494},"\u002Fresources\u002Fnews\u002Ftargeting-unexplained-wealth-in-british-columbia-and-beyond-new-analysis-2287"," See related blog: Targeting unexplained wealth in British Columbia and beyond – new analysis",[496],{"url":497,"caption":498},"https:\u002F\u002Fillicitenrichment.baselgovernance.org\u002F"," See Illicit Enrichment, an open-access book and database on laws to target unexplained wealth",[500,502],{"authors_id":501},{"id":166,"name":167},{"authors_id":503},{"id":504,"name":505},511,"Jeffrey Simser",[507],{"countries_id":508},{"id":509,"name":510},36,"Canada",[512,514,516],{"tags_id":513},{"id":429,"name":430},{"tags_id":515},{"id":88,"name":89},{"tags_id":517},{"id":518,"name":519},1215,"Illicit financial flows",[521],2274,[178,31],[15],"2022-10-03T16:04:07.000Z","2026-06-02T14:09:02.000Z","\u002Fresources\u002Fpublications\u002Fwp-41",{"id":528,"slug":529,"title":530,"status":6,"nid":531,"year":300,"body":532,"external":19,"topic":7,"language":7,"type":533,"date_published":304,"image":534,"citation":535,"publisher":17,"link_internal":536,"link_external":540,"authors":543,"countries":548,"tags":557,"pdf":566,"topics":568,"featured":19,"languages":570,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":52,"date_created":356,"user_updated":357,"date_updated":571,"main_points":572,"short_version":7,"subtitle":7,"link":573},2443,"cs-14","Case Study 14: Madagascar: a landmark conviction for money laundering linked to environmental crime",2948,"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\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\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",[303],"https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fea8361c6-bffd-4cfd-9119-7bc822b39af7?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",[537],{"url":538,"caption":539},"\u002Fresources\u002Fpublications?type=Case%20Study","View all Case Studies",[541],{"url":542,"caption":317},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=369",[544],{"authors_id":545},{"id":546,"name":547},567,"Joseph Rakotondramanana",[549,553],{"countries_id":550},{"id":551,"name":552},139,"Madagascar",{"countries_id":554},{"id":555,"name":556},213,"Thailand",[558,562,564],{"tags_id":559},{"id":560,"name":561},1303,"Environment",{"tags_id":563},{"id":71,"name":72},{"tags_id":565},{"id":280,"name":281},[567],2497,[569],"Green Corruption",[15],"2026-06-02T21:14:32.000Z","- 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.","\u002Fresources\u002Fpublications\u002Fcs-14",{"id":575,"slug":576,"title":577,"status":6,"nid":578,"year":300,"body":579,"external":19,"topic":580,"language":15,"type":581,"date_published":583,"image":584,"citation":14,"publisher":585,"link_internal":586,"link_external":587,"authors":594,"countries":611,"tags":616,"pdf":637,"topics":639,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":51,"date_created":640,"user_updated":52,"date_updated":641,"main_points":642,"short_version":7,"subtitle":7,"link":643},2433,"addressing-conflicts-interest-and-corruption-indonesias-energy-transition","Addressing conflicts of interest and corruption in Indonesia’s energy transition",2936,"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.\n\n\u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-02\u002FAddressing-conflicts-of-interest-and-corruption-in-indonesia-s-energy-transition_U4-Issue.pdf\">Download publication here\u003C\u002Fa>.\n\n### About the paper\n\nConflicts 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.\n\nThe 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.\n\nPotential pathways to greater anti-corruption resilience lie in improvements to beneficial ownership transparency and strengthening regulation, monitoring and sanctioning of conflict of interest violations.\n",[569],[582],"Report","2026-02-24","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd97f2ca5-300d-45c9-9de9-33152b72f96c?width=600&height=840","U4 Anti-Corruption Resource Centre",[],[588,591],{"url":589,"caption":590},"https:\u002F\u002Fwww.u4.no\u002Fpublications\u002Faddressing-conflicts-of-interest-and-corruption-in-indonesia-s-energy-transition"," View on U4 website",{"url":592,"caption":593},"https:\u002F\u002Fwww.u4.no\u002Fblog\u002Fimproving-anti-corruption-resilience-in-indonesia-s-energy-transition"," Read related U4 blog",[595,599,603,607],{"authors_id":596},{"id":597,"name":598},581,"Robert Forster",{"authors_id":600},{"id":601,"name":602},582,"Aled Williams",{"authors_id":604},{"id":605,"name":606},523,"Lakso Anindito",{"authors_id":608},{"id":609,"name":610},579,"Dr Amanda Cabrejo le Roux",[612],{"countries_id":613},{"id":614,"name":615},99,"Indonesia",[617,621,623,627,631,633],{"tags_id":618},{"id":619,"name":620},982,"Anti-corruption",{"tags_id":622},{"id":88,"name":89},{"tags_id":624},{"id":625,"name":626},804,"Natural resources",{"tags_id":628},{"id":629,"name":630},1371,"Public governance",{"tags_id":632},{"id":465,"name":466},{"tags_id":634},{"id":635,"name":636},973,"Corruption",[638],2489,[569],"2026-02-27T15:11:31.000Z","2026-05-23T20:08:18.000Z","- Corruption and conflicts of interest are embedded in the energy transition process due to the strong links between political power, private wealth (especially from extractive industries) and public office holders.\n- Existing anti-corruption regulations are often vague, fragmented across different legal instruments, and suffer from inconsistent enforcement, which creates loopholes susceptible to manipulation.\n- Progress in renewable energy uptake is slowed by the enduring influence and interests of fossil fuel incumbents who benefit from subsidies that keep coal an artificially cheap and viable energy source.\n- The Just Energy Transition Partnership is vulnerable to misallocations due to concentrated decision-making power, limited transparency in project selection and insufficient involvement of national anti-corruption bodies and civil society in its planning.\n- Improving transparency of beneficial ownership and strengthening the monitoring and sanctioning of conflict of interest violations are possible pathways to build greater anti-corruption resilience, though these institutional efforts alone are insufficient to fully address state capture dynamics.","\u002Fresources\u002Fpublications\u002Faddressing-conflicts-interest-and-corruption-indonesias-energy-transition",1780676581880]