[{"data":1,"prerenderedAt":660},["ShallowReactive",2],{"publication-study-anti-corruption-architecture-republic-south-africa":3,"related-study-anti-corruption-architecture-republic-south-africa":200},[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":23,"featured":19,"topics":24,"languages":26,"type":27,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"image":29,"countries":41,"tags":71,"pdf":117,"authors":139},2126,"published",null,"2022-04-27T11:57:17.000Z","2026-05-31T22:51:55.000Z",189,"study-anti-corruption-architecture-republic-south-africa","Study on Anti-Corruption Architecture of the Republic of South Africa","The Basel Institute on Governance participated in several workshops between 8 and 9 October 2012 with key stakeholders of the South African anti-corruption system (Asset Forfeiture Unit of the National Prosecuting Authority, Special Investigating Unit, Department of Public Service Administration, South African Revenue Services, National Treasury, Directorate for Priority Crimes Investigations of the South African Police Services) at a special session hosted by the Anti-Corruption Task Team (ACTT).\n\nThe purpose of these workshops was to present the findings and recommendations of the report produced by the Legal and Case Consultancy Team of the Institute with regards to the South African anti-corruption architecture. The study had been commissioned by GIZ South Africa, with the purpose of providing, among others, an overview of the requirements for the anti-corruption architecture of South Africa and elaborating on the international discourse on the concept of independence of anti-corruption bodies. The study further provided a comparable case studies with five different jurisdictions.\n\nDuring these two days in Pretoria, South Africa, the Legal and Case Consultancy team also had the opportunity to meet with prosecutors and financial investigators to discuss, at an operational level, the asset recovery process in the country. Finally, the Legal and Case Consultancy Team also had the opportunity to meet with the Executive Committee of the Special Investigating Unit to further discuss in detail the findings and recommendations of the report, with a view to assisting the South African Authorities in establishing a cohesive anti-corruption strategy for the country.","","English",2012,"GIZ","2012-01-01",false,[21],"Asset Recovery",[],[],[25],"Asset Recovery and Enforcement",[15],[28],"Report",{"id":30,"storage":31,"filename_disk":32,"filename_download":33,"title":34,"type":35,"created_on":36,"modified_on":36,"charset":7,"filesize":37,"width":38,"height":39,"duration":7,"embed":7,"description":7,"location":7,"tags":7,"metadata":40,"focal_point_x":7,"focal_point_y":7,"tus_id":7,"tus_data":7,"uploaded_on":36},"bc3d5b94-9d31-4457-89c0-74d4c0d29944","local","bc3d5b94-9d31-4457-89c0-74d4c0d29944.jpeg","148e9993-8d9f-49ec-816f-495b730b6844.jpeg","148e9993 8d9f 49ec 816f 495b730b6844","image\u002Fjpeg","2022-05-27T22:27:57.000Z",79892,1200,1653,{},[42],{"id":43,"publications_id":44,"countries_id":65},948,{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":47,"link_internal":48,"link_external":49,"featured":19,"topics":50,"languages":51,"type":52,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":53,"tags":54,"pdf":58,"authors":60},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","3d9ff205-1640-4f34-b5b6-86977f51bbd6",[21],[],[],[25],[15],[28],[43],[55,56,57],5155,5156,5157,[59],2171,[61,62,63,64],2346,2347,2348,2349,{"id":66,"name":67,"code":68,"latitude":69,"longitude":70},243,"South Africa","ZA",-30.55948,22.93751,[72,87,102],{"id":55,"publications_id":73,"tags_id":84},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":74,"link_internal":75,"link_external":76,"featured":19,"topics":77,"languages":78,"type":79,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":80,"tags":81,"pdf":82,"authors":83},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":85,"name":86},982,"Anti-corruption",{"id":56,"publications_id":88,"tags_id":99},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":89,"link_internal":90,"link_external":91,"featured":19,"topics":92,"languages":93,"type":94,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":95,"tags":96,"pdf":97,"authors":98},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":100,"name":101},1193,"Financial investigations",{"id":57,"publications_id":103,"tags_id":114},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":104,"link_internal":105,"link_external":106,"featured":19,"topics":107,"languages":108,"type":109,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":110,"tags":111,"pdf":112,"authors":113},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":115,"name":116},818,"Anti-money laundering",[118],{"id":59,"publications_id":119,"directus_files_id":130},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":120,"link_internal":121,"link_external":122,"featured":19,"topics":123,"languages":124,"type":125,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":126,"tags":127,"pdf":128,"authors":129},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":131,"storage":31,"filename_disk":132,"filename_download":133,"title":133,"type":134,"folder":135,"uploaded_by":45,"created_on":136,"modified_by":7,"modified_on":136,"charset":7,"filesize":137,"width":7,"height":7,"duration":7,"embed":7,"description":138,"location":7,"tags":7,"metadata":7,"focal_point_x":7,"focal_point_y":7,"tus_id":7,"tus_data":7,"uploaded_on":136},"c5d94653-2b8d-4f2c-b31a-6937c2d833ed","c5d94653-2b8d-4f2c-b31a-6937c2d833ed.pdf","south-africa-anti-corruption-architecture.pdf","application\u002Fpdf","67f22e04-d26f-4baa-b91f-acc5f89d87f5","2022-04-27T11:57:18.000Z",1869618,"View PDF",[140,155,170,185],{"id":61,"publications_id":141,"authors_id":152},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":142,"link_internal":143,"link_external":144,"featured":19,"topics":145,"languages":146,"type":147,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":148,"tags":149,"pdf":150,"authors":151},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":153,"name":154,"position":7,"image":7},460,"Pedro Gomes Pereira",{"id":62,"publications_id":156,"authors_id":167},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":157,"link_internal":158,"link_external":159,"featured":19,"topics":160,"languages":161,"type":162,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":163,"tags":164,"pdf":165,"authors":166},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":168,"name":169,"position":7,"image":7},334,"Selvan Lehmann",{"id":63,"publications_id":171,"authors_id":182},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":172,"link_internal":173,"link_external":174,"featured":19,"topics":175,"languages":176,"type":177,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":178,"tags":179,"pdf":180,"authors":181},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":183,"name":184,"position":7,"image":7},479,"Anja Roth",{"id":64,"publications_id":186,"authors_id":197},{"id":5,"status":6,"sort":7,"user_created":45,"date_created":8,"user_updated":46,"date_updated":9,"nid":10,"slug":11,"image":30,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":187,"link_internal":188,"link_external":189,"featured":19,"topics":190,"languages":191,"type":192,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":193,"tags":194,"pdf":195,"authors":196},[21],[],[],[25],[15],[28],[43],[55,56,57],[59],[61,62,63,64],{"id":198,"name":199,"position":7,"image":7},467,"Kodjo Attisso",[201,238,309,350,410,458,521,555,594,622],{"id":202,"slug":203,"title":204,"status":6,"nid":205,"year":206,"body":207,"external":19,"topic":208,"language":15,"type":210,"date_published":212,"image":213,"citation":14,"publisher":214,"link_internal":215,"link_external":216,"authors":217,"countries":222,"tags":223,"pdf":232,"topics":234,"featured":19,"languages":235,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":45,"date_created":236,"user_updated":46,"date_updated":9,"main_points":7,"short_version":7,"subtitle":7,"link":237},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>.",[209,21],"Anti-Money Laundering",[211],"Quick Guide","2024-11-25","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F01dea28f-22b8-47cd-bf86-ddee24683c2b?width=600&height=840","Basel Institute on Governance",[],[],[218],{"authors_id":219},{"id":220,"name":221},327,"Simon Marsh",[],[224,226,228],{"tags_id":225},{"id":100,"name":101},{"tags_id":227},{"id":115,"name":116},{"tags_id":229},{"id":230,"name":231},1374,"Law enforcement",[233],2416,[209,25],[15],"2024-12-05T14:06:47.000Z","\u002Fresources\u002Fpublications\u002Fqg34",{"id":239,"slug":240,"title":241,"status":6,"nid":242,"year":243,"body":244,"external":19,"topic":245,"language":15,"type":247,"date_published":248,"image":249,"citation":14,"publisher":250,"link_internal":251,"link_external":252,"authors":259,"countries":276,"tags":281,"pdf":302,"topics":304,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":45,"date_created":305,"user_updated":46,"date_updated":306,"main_points":307,"short_version":7,"subtitle":7,"link":308},2433,"addressing-conflicts-interest-and-corruption-indonesias-energy-transition","Addressing conflicts of interest and corruption in Indonesia’s energy transition",2936,2026,"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",[246],"Green Corruption",[28],"2026-02-24","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd97f2ca5-300d-45c9-9de9-33152b72f96c?width=600&height=840","U4 Anti-Corruption Resource Centre",[],[253,256],{"url":254,"caption":255},"https:\u002F\u002Fwww.u4.no\u002Fpublications\u002Faddressing-conflicts-of-interest-and-corruption-in-indonesia-s-energy-transition"," View on U4 website",{"url":257,"caption":258},"https:\u002F\u002Fwww.u4.no\u002Fblog\u002Fimproving-anti-corruption-resilience-in-indonesia-s-energy-transition"," Read related U4 blog",[260,264,268,272],{"authors_id":261},{"id":262,"name":263},581,"Robert Forster",{"authors_id":265},{"id":266,"name":267},582,"Aled Williams",{"authors_id":269},{"id":270,"name":271},523,"Lakso Anindito",{"authors_id":273},{"id":274,"name":275},579,"Dr Amanda Cabrejo le Roux",[277],{"countries_id":278},{"id":279,"name":280},99,"Indonesia",[282,284,286,290,294,298],{"tags_id":283},{"id":85,"name":86},{"tags_id":285},{"id":115,"name":116},{"tags_id":287},{"id":288,"name":289},804,"Natural resources",{"tags_id":291},{"id":292,"name":293},1371,"Public governance",{"tags_id":295},{"id":296,"name":297},1236,"Compliance",{"tags_id":299},{"id":300,"name":301},973,"Corruption",[303],2489,[246],"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",{"id":310,"slug":311,"title":312,"status":6,"nid":313,"year":314,"body":315,"external":19,"topic":316,"language":15,"type":317,"date_published":319,"image":320,"citation":321,"publisher":214,"link_internal":322,"link_external":326,"authors":327,"countries":330,"tags":333,"pdf":342,"topics":344,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":345,"sort":7,"user_created":45,"date_created":346,"user_updated":46,"date_updated":347,"main_points":348,"short_version":7,"subtitle":7,"link":349},2428,"cs-12","Case Study 12: Indonesia: a landmark money laundering conviction in a forestry crime case",2874,2025,"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, \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fcase-studies\">ISSN 2813-3900\u003C\u002Fa>. It is licensed for sharing 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\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.",[246],[318],"Case Study","2025-11-25","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fcb6cbdfc-7348-43d5-bfc0-2d3fc41157cd?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>.",[323],{"url":324,"caption":325},"\u002Fresources\u002Fpublications?type=Case%20Study"," View all Case Studies",[],[328],{"authors_id":329},{"id":270,"name":271},[331],{"countries_id":332},{"id":279,"name":280},[334,336,340],{"tags_id":335},{"id":115,"name":116},{"tags_id":337},{"id":338,"name":339},1303,"Environment",{"tags_id":341},{"id":100,"name":101},[343],2483,[246],"\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","2026-06-02T14:08:56.000Z","- 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":351,"slug":352,"title":353,"status":6,"nid":354,"year":243,"body":355,"external":19,"topic":356,"language":15,"type":357,"date_published":359,"image":360,"citation":14,"publisher":214,"link_internal":361,"link_external":371,"authors":375,"countries":380,"tags":393,"pdf":404,"topics":406,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":45,"date_created":407,"user_updated":46,"date_updated":408,"main_points":7,"short_version":7,"subtitle":7,"link":409},2446,"quick-guide-43-corruption-sanctions","Quick Guide 43: Corruption sanctions",2971,"How can governments respond to serious corruption when those responsible are beyond the reach of the law?\n\nWeak institutions, political protection or limited law enforcement capacity can make it difficult to investigate or prosecute powerful individuals suspected of corruption. In response, some governments have turned to corruption sanctions.\n\nCorruption sanctions allow governments to impose restrictions on people suspected of serious corruption even without a criminal conviction.\n\nThis Quick Guide introduces corruption sanctions, explains how they work and highlights both their potential and the concerns they raise.\n\n### About this Quick Guide\n\nYou are free to share and republish this work under a Creative Commons \u003Ca href=\"http:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">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>.",[21],[358],"Quick guide","2026-06-02","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fe0094eda-5362-4227-966b-d676340e21be?width=600&height=840",[362,365,368],{"url":363,"caption":364},"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-62"," Read related Working Paper",{"url":366,"caption":367},"https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F2968"," See related webinar",{"url":369,"caption":370},"https:\u002F\u002Fbaselgovernance.org\u002Fpublications?type=2428"," View all Quick Guides",[372],{"url":373,"caption":374},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=386"," View online on LEARN",[376],{"authors_id":377},{"id":378,"name":379},597,"Dr Anton Moiseienko",[381,385,389],{"countries_id":382},{"id":383,"name":384},225,"Ukraine",{"countries_id":386},{"id":387,"name":388},36,"Canada",{"countries_id":390},{"id":391,"name":392},14,"Australia",[394,398,402],{"tags_id":395},{"id":396,"name":397},1227,"Sanctions",{"tags_id":399},{"id":400,"name":401},843,"Asset recovery",{"tags_id":403},{"id":85,"name":86},[405],2499,[25],"2026-06-04T21:25:14.000Z","2026-06-04T21:40:35.000Z","\u002Fresources\u002Fpublications\u002Fquick-guide-43-corruption-sanctions",{"id":411,"slug":412,"title":413,"status":6,"nid":414,"year":243,"body":415,"external":19,"topic":7,"language":7,"type":416,"date_published":418,"image":419,"citation":420,"publisher":214,"link_internal":421,"link_external":425,"authors":426,"countries":431,"tags":444,"pdf":449,"topics":452,"featured":19,"languages":453,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":46,"date_created":454,"user_updated":46,"date_updated":455,"main_points":7,"short_version":456,"subtitle":7,"link":457},2436,"wp-62","Working Paper 62: Corruption sanctions: What governments need to know",2970,"How can governments respond to serious corruption when those responsible are beyond the reach of the law? Some governments have turned to corruption sanctions to address this issue.\n\nThis Working Paper examines how corruption sanctions – tools that allow governments to impose asset freezes and travel bans on individuals suspected of corruption without any finding of guilt in a court – have evolved over the past decade, and offers recommendations for their more effective and legitimate use.\n\n::: button https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-05\u002F260529_WP-62.pdf\n**Download the Working Paper here**\n:::\n\n### Advantages and limitations of corruption sanctions\n\nCorruption sanctions emerged primarily to address situations where notoriously corrupt individuals enjoy impunity within their own legal systems. Their key strengths lie in their flexibility and versatility:\n\n- they can be applied regardless of any geographical link between the sanctioning state and the alleged corruption, based on relatively low evidentiary thresholds; and \n- they can serve a wide range of objectives – from disrupting and deterring corrupt activity to condemning corruption, facilitating asset recovery and signalling support for another country's law enforcement efforts.\n\nHowever, the paper also highlights important limitations. Corruption sanctions are often wielded without a clear post-imposition strategy. And: their inherent flexibility comes with due process trade-offs, including broad governmental discretion and limited judicial oversight.\n\n### Recommendations\n\nDrawing on an extensive analysis of the experiences of key jurisdictions – including the US, UK, EU, Canada and Australia – the author puts forward nine recommendations for governments on how to design and maintain credible and effective corruption sanctions regimes. These include publishing clear criteria for high-priority targets, strengthening transparency around licensing and delisting decisions, and exploring sanctions against professional enablers in major financial centres.\n\nThe paper is aimed primarily at policymakers but will also be of interest to anti-corruption activists, private-sector financial crime specialists and academics.\n\n### About this paper\n\nThis paper is published as part of the Basel Institute on Governance Working Paper series, ISSN: 2624-9650. You may share or republish it under a Creative Commons [BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002Fdeed.en) International Licence.\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\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",[417],"Working Paper","2026-05-28","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F0b54d63b-364d-478e-b7a6-29c8a4f6333b?width=600&height=840","Moiseienko, Anton. 2026. “Corruption sanctions: What governments need to know.” Working Paper 62, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fresources\u002Fpublications\u002Fwp-62",[422],{"url":423,"caption":424},"\u002Fresources\u002Fpublications?type=Working%20Paper","View all Working Papers",[],[427],{"authors_id":428},{"id":429,"name":430},583,"Anton Moiseienko",[432,436,440,442],{"countries_id":433},{"id":434,"name":435},228,"United States",{"countries_id":437},{"id":438,"name":439},74,"United Kingdom",{"countries_id":441},{"id":387,"name":388},{"countries_id":443},{"id":391,"name":392},[445,447],{"tags_id":446},{"id":400,"name":401},{"tags_id":448},{"id":85,"name":86},[450,451],2490,2491,[25],[15],"2026-06-01T22:10:25.000Z","2026-06-02T14:08:57.000Z","Corruption sanctions allow governments to impose financial and travel\nrestrictions, such as asset freezes and visa bans, on persons (mostly foreigners)\nsuspected of corruption without any finding of guilt in a court of law. Such\nsanctions have emerged over the past decade primarily to address situations\nwhere notoriously corrupt individuals enjoy impunity within their own legal\nsystems. They are also occasionally used to support foreign investigations by\nenabling authorities to swiftly freeze suspected proceeds of corruption.\n\n### Advantages\nCorruption sanctions regimes offer two main advantages that make them a useful\naddition to a government’s anti-corruption arsenal: flexibility and versatility.\n\nThe flexibility of corruption sanctions stems from the relatively low evidentiary\nstandards required to implement them, which are far less exacting than\nthe civil or criminal standards of proof. It also reflects there being no need\nfor any geographical nexus between the sanctioning state and the alleged\ncorruption, such that sanctions can be wielded against anyone involved in\ncorruption anywhere in the world. These features allow governments to resort\nto corruption sanctions in circumstances where conventional law enforcement\naction, such as prosecutions or confiscation proceedings, would be out of\nreach.\n\nThe versatility of such sanctions is a product of the freedom that governments\nenjoy in their imposition. Corruption sanctions can be, and have been, put\nto use to achieve a varied set of objectives. Those include disrupting corrupt\nactivity; deterring would-be corruption or corruption facilitation; condemning\ncorruption; punishing the perpetrators; facilitating asset recovery; or signalling\nsupport for another country’s law enforcement actions.\n\n### Limitations\nThis flexibility and versatility combine to produce a unique and valuable anticorruption tool. However, all too often it is wielded without a clear post-imposition\nstrategy, namely a coherent and credible approach to what the sanctions are\nmeant to achieve once they are in effect; how long they will be kept in place;\nand how they interact with other available law enforcement tools. In some cases,\nthe imposition of sanctions may be predicated on the expectation that other\nmeasures – such as asset confiscation – will follow. In others, they may be a selfstanding response to allegations of serious corruption.\n\nThe inherent flexibility in these tools also comes with due process trade-offs.\nCorruption sanctions regimes grant governments broad powers, including a\nwide discretion in imposing and lifting corruption sanctions or granting licences\nfor transactions that would otherwise be prohibited under such sanctions.\nThese powers are often subject only to light-touch judicial oversight. This has\nunderstandably raised concerns over their vulnerability to errors or, in extreme\ncases, abuse.\n\nTo ensure consistent and credible use of corruption sanctions, policymakers\nshould review applicable evidentiary standards and judicial review rules;\npublish clear criteria outlining what makes for a high-priority target for\ncorruption sanctions; publish clear criteria for sanctions licences and delisting;\nand set out processes and expectations for sanctions dossier submissions from\ncivil society organisations. While all of these measures preserve governments’\nflexibility in the imposition of corruption sanctions, taken together they will go\nsome way towards minimising the risks of politicisation or abuse.\n\n### A useful addition to the anti-corruption toolbox\nAll in all, corruption sanctions have transformed and enriched the anticorruption enforcement landscape. Their evident advantages suggest that\nstates that have not yet done so should consider whether the introduction of\ncorruption sanctions is right for them, and that those states that already have a\nmechanism in place should explore how they can use it to the greatest effect.\nSometimes, governments are reluctant to make full use of corruption sanctions\nfor fears of foreign policy repercussions. But, as the analysis in this paper\nsuggests, such sensitivities can be managed through careful target selection.\n\nIn summary, if designed and implemented transparently and responsibly – not\nas a low-cost substitute for traditional enforcement tools but as a complement\nto them when they are not available – these mechanisms can be used to target\nand challenge otherwise unchecked corruption globally. The analysis in this\npaper, and the recommendations it contains in its conclusion, aim to support\nthis endeavour.","\u002Fresources\u002Fpublications\u002Fwp-62",{"id":459,"slug":460,"title":461,"status":6,"nid":462,"year":243,"body":463,"external":19,"topic":7,"language":7,"type":464,"date_published":465,"image":466,"citation":467,"publisher":214,"link_internal":468,"link_external":475,"authors":482,"countries":491,"tags":496,"pdf":511,"topics":513,"featured":19,"languages":514,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":46,"date_created":515,"user_updated":516,"date_updated":517,"main_points":518,"short_version":7,"subtitle":519,"link":520},2441,"cs-13","Case Study 13: The Beauty Queen case: non-conviction based forfeiture across borders",2937,"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",[318],"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).",[469,472],{"url":470,"caption":471},"\u002Fresources\u002Fnews\u002Fcolombiaguernsey-cooperation-leads-to-successful-non-conviction-based-forfeiture-of-illicit-assets-2716","Read related blog",{"url":473,"caption":474},"\u002Fresources\u002Fpublications","Read related Policy Brief 16",[476,479],{"url":477,"caption":478},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=368","View online on Basel LEARN",{"url":480,"caption":481},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=72","eLearning course: International Cooperation and Mutual Legal Assistance in Criminal Matters",[483,487],{"authors_id":484},{"id":485,"name":486},294,"Oscar Solorzano",{"authors_id":488},{"id":489,"name":490},591,"Diana Cordero",[492],{"countries_id":493},{"id":494,"name":495},47,"Colombia",[497,501,505,507,509],{"tags_id":498},{"id":499,"name":500},1379,"Non-conviction based forfeiture",{"tags_id":502},{"id":503,"name":504},822,"International cooperation",{"tags_id":506},{"id":115,"name":116},{"tags_id":508},{"id":230,"name":231},{"tags_id":510},{"id":400,"name":401},[512],2495,[25],[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":522,"slug":523,"title":524,"status":6,"nid":525,"year":243,"body":526,"external":19,"topic":7,"language":7,"type":527,"date_published":465,"image":529,"citation":7,"publisher":214,"link_internal":530,"link_external":533,"authors":535,"countries":538,"tags":539,"pdf":548,"topics":550,"featured":19,"languages":551,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":46,"date_created":515,"user_updated":46,"date_updated":552,"main_points":7,"short_version":7,"subtitle":553,"link":554},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).",[528],"Policy Brief","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Ff866220c-dddd-41b3-a45e-c2d7992d39e1?width=600&height=840",[531],{"url":473,"caption":532},"Read related Case Study 13",[534],{"url":480,"caption":481},[536],{"authors_id":537},{"id":485,"name":486},[],[540,542,544,546],{"tags_id":541},{"id":499,"name":500},{"tags_id":543},{"id":503,"name":504},{"tags_id":545},{"id":115,"name":116},{"tags_id":547},{"id":230,"name":231},[549],2496,[25],[15],"2026-06-02T14:16:22.000Z","FATF standards and asset recovery practice in Latin America and financial centres","\u002Fresources\u002Fpublications\u002Fpb-16",{"id":556,"slug":557,"title":558,"status":6,"nid":559,"year":314,"body":560,"external":19,"topic":561,"language":15,"type":562,"date_published":564,"image":565,"citation":14,"publisher":566,"link_internal":567,"link_external":568,"authors":572,"countries":577,"tags":580,"pdf":589,"topics":590,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":45,"date_created":591,"user_updated":46,"date_updated":592,"main_points":7,"short_version":7,"subtitle":7,"link":593},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,"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],[563],"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",[],[569],{"url":570,"caption":571},"https:\u002F\u002Fedit.financialcrimelitigators.org\u002Fapi\u002Fassets\u002Fb401d6c9-b0e4-4ab9-ad1f-948c567c6ab3.pdf","Fall 2025 Bulletin of the International Academy of Financial Crime Litigators",[573],{"authors_id":574},{"id":575,"name":576},306,"Andrew Dornbierer",[578],{"countries_id":579},{"id":383,"name":384},[581,583,585],{"tags_id":582},{"id":400,"name":401},{"tags_id":584},{"id":115,"name":116},{"tags_id":586},{"id":587,"name":588},821,"Unexplained wealth",[],[25],"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":595,"slug":596,"title":597,"status":6,"nid":598,"year":314,"body":599,"external":19,"topic":600,"language":15,"type":601,"date_published":602,"image":603,"citation":14,"publisher":214,"link_internal":604,"link_external":607,"authors":608,"countries":613,"tags":614,"pdf":617,"topics":618,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":45,"date_created":619,"user_updated":46,"date_updated":620,"main_points":7,"short_version":7,"subtitle":7,"link":621},2401,"qg40","Quick Guide 40: Financial investigations in a cash economy",2796,"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 \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>.",[21],[211],"2025-04-10","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fc20e0d80-319e-4b14-b187-064f77f9e53a?width=600&height=840",[605],{"url":606,"caption":370},"\u002Fresources\u002Fpublications?type=Quick%20Guide",[],[609],{"authors_id":610},{"id":611,"name":612},562,"Emmanuel Mringo",[],[615],{"tags_id":616},{"id":100,"name":101},[522],[25],"2025-04-14T10:05:14.000Z","2026-06-02T14:08:52.000Z","\u002Fresources\u002Fpublications\u002Fqg40",{"id":623,"slug":624,"title":625,"status":6,"nid":626,"year":314,"body":627,"external":19,"topic":628,"language":15,"type":629,"date_published":630,"image":631,"citation":14,"publisher":214,"link_internal":632,"link_external":638,"authors":639,"countries":644,"tags":647,"pdf":652,"topics":654,"featured":655,"languages":656,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":45,"date_created":657,"user_updated":46,"date_updated":658,"main_points":7,"short_version":7,"subtitle":7,"link":659},2390,"wp-55","Working Paper 55: Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms",2754,"The UK is a global leader in its efforts to target foreign bribery. It is one of the only countries worldwide to use negotiated settlements such as deferred prosecution agreements (DPAs) to resolve cases and extract penalties from corporations that commit corruption abroad. The UK has also laudably committed to using the proceeds of DPAs in foreign bribery cases to compensate the victims of corruption, particularly in countries that suffer its worst effects. \n\nThis paper explores why the UK’s policy of compensating the victims of foreign bribery is not achieving its intended results in practice, and proposes realistic suggestions for improvement to the extant DPA regime.  \n\nIt examines the conceptual, practical and political difficulties inherent in this undertaking, shining a light on how victim compensation operates in the UK and analysing judicial decisions on this issue. Finally, the paper proposes reform recommendations to strengthen the DPA regime to ensure appropriate compensation is made in foreign bribery settlements.\n\n### About this report\n\nThe paper is published as part of the Basel Institute on Governance Working Paper series, ISSN: 2624-9650. You may share or republish it under a Creative Commons \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002Fdeed.en\">BY-NC-ND 4.0\u003C\u002Fa> International Licence.\n\nThe paper 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\nSuggested citation: Hickey, Sam. 2025. ‘Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms.’ Working Paper 55, Basel Institute on Governance. Available at: \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-55\">baselgovernance.org\u002Fpublications\u002Fwp-55.\u003C\u002Fa>\n\nA version of this paper is also published by the *Transnational Criminal Law Review*.",[21],[417],"2025-02-17","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F4e74824b-dfc2-46f0-b2a6-55050955ba46?width=600&height=840",[633,636],{"url":634,"caption":635},"https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fchallenges-compensating-victims-foreign-bribery"," View related blog",{"url":423,"caption":637}," View all Working Papers",[],[640],{"authors_id":641},{"id":642,"name":643},560,"Sam Hickey",[645],{"countries_id":646},{"id":383,"name":384},[648,650],{"tags_id":649},{"id":85,"name":86},{"tags_id":651},{"id":400,"name":401},[653],2431,[25],true,[15],"2025-02-17T17:05:19.000Z","2026-06-02T14:08:51.000Z","\u002Fresources\u002Fpublications\u002Fwp-55",1780676550754]