[{"data":1,"prerenderedAt":555},["ShallowReactive",2],{"publication-working-paper-33-worms-eye-view-wildlife-trafficking-uganda-path-least-resistance":3,"related-working-paper-33-worms-eye-view-wildlife-trafficking-uganda-path-least-resistance":164},[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":23,"link_external":27,"featured":19,"topics":28,"languages":30,"type":31,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"image":33,"countries":44,"tags":72,"pdf":73,"authors":96},1832,"published",null,"2022-04-27T11:54:04.000Z","2026-06-02T14:08:45.000Z",1892,"working-paper-33-worms-eye-view-wildlife-trafficking-uganda-path-least-resistance","Working Paper 33: A worm’s-eye view of wildlife trafficking in Uganda – the path of least resistance","This Working Paper is a key output of the Basel Institute's \u003Ca href=\"\u002Fnode\u002F665\">Green Corruption\u003C\u002Fa> programme, a multi-disciplinary engagement that targets environmental degradation through tested anti-corruption, asset recovery and governance methods. The research is funded by PMI Impact as part of a wider project on intelligence-led on financial crime in illegal wildlife trade (IWT).\n\nThe fight against wildlife trafficking is a global one. Wildlife trafficking constitutes the fourth-largest form of illicit trade flow in the world. Its prevalence is often explained in economic terms: it is a “low-risk, high-profit” trade. Global efforts are therefore directed at increasing the “costs” of wildlife trafficking and reducing the rewards.\n\nHowever, rational cost-benefit calculations by individuals seeking personal economic gain do not fully explain why wildlife trafficking is so prevalent. Nor, therefore, will it be solved by passing new laws and strengthening law enforcement alone. Scholars as well as development and law enforcement practitioners increasingly recognise the importance of considering the way in which the local context and socio-cultural structures (so-called behavioural drivers) influence the behaviours of individuals and their propensity to engage in wildlife trafficking.\n\nThis social context is not only an anchor for decision-making but also influences the strategies through which wildlife trafficking is organised. Individuals are part of informal networks. Social connections in and between the networks facilitate the transportation of wildlife products from poachers to buyers across vast geographical spaces. Public officials can be part of such networks too. In such cases those individuals, rather than enforcing the law, use their position to cover up the trafficking of wildlife products out of parks, cities and ports in East Africa.\n\nThis approach of emphasising context-sensitive behavioural drivers anchors the research activities that the Public Governance division is leading in Uganda as part of the wider programme of work of the Institute. Uganda is a hub for wildlife trafficking in East Africa. High volumes of wild animal products are transported into, through and out of Uganda using various methods and strategies. Taking a worm’s-eye perspective, the research aims to provide further understanding on:\n\n\n- Why wildlife trafficking happens, by focusing on the economic and behavioural drivers of wildlife trafficking and the role of the broader governance environment in generating increased corruption risks in public offices mandated to prevent and combat wildlife trafficking.\n- How wildlife trafficking happens, by focusing on the role and strategies employed by informal networks of poachers, middlemen and buyers to transport high volumes of wildlife products into, through and out of Uganda.\n\n\nThe findings are based on 47 interviews with Ugandan-based and international anti-IWT experts (IGOs, NGOs, academics and public officials) and 8 focus group discussions with wildlife conservation and anti-corruption experts in Kampala, members of reformed poachers’ networks in Western Uganda, and individuals living around a wildlife habitat in Northern Uganda. Together, these provide context-specific insights on the drivers and facilitators of wildlife trafficking in Uganda. The present report synthesises their observations and aims to contribute to the development of evidence-informed approaches to curbing the trade.\n\n### About this Working Paper\n\nThis paper is part of the Basel Institute on Governance Working Paper Series, \u003Ca href=\"https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type[]=255\">ISSN: 2624-9650\u003C\u002Fa>.\n\nThis report was funded by PMI IMPACT, a grant award initiative of Philip Morris International (PMI). In the performance of their research, the authors maintained full independence from PMI. The views and opinions expressed in this document are those of the authors and do not necessarily reflect the views of PMI. Neither PMI, nor any of its affiliates, nor any person acting on their behalf may be held responsible for any use which may be made of the information contained herein.","","English",2020,"Basel Institute on Governance","2020-10-07",false,[21,22],"Green Corruption","Public Governance",[24],{"url":25,"caption":26},"\u002Fresources\u002Fpublications?type=Working%20Paper"," View all Working Papers",[],[21,29],"Corruption Prevention and Public Governance",[15],[32],"Working Paper",{"id":34,"storage":35,"filename_disk":36,"filename_download":37,"title":38,"type":39,"created_on":8,"modified_on":8,"charset":7,"filesize":40,"width":41,"height":42,"duration":7,"embed":7,"description":7,"location":7,"tags":7,"metadata":43,"focal_point_x":7,"focal_point_y":7,"tus_id":7,"tus_data":7,"uploaded_on":8},"64a4646e-8d60-4667-a98f-766b8da54220","local","64a4646e-8d60-4667-a98f-766b8da54220.jpg","Pages-from-WP33-Wildlife-trafficking-in-Uganda.jpg","Cover page of WP 33","image\u002Fjpeg",276632,2471,3509,{},[45],{"id":46,"publications_id":47,"countries_id":66},804,{"id":5,"status":6,"sort":7,"user_created":48,"date_created":8,"user_updated":49,"date_updated":9,"nid":10,"slug":11,"image":34,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":50,"link_internal":51,"link_external":53,"featured":19,"topics":54,"languages":55,"type":56,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":57,"tags":58,"pdf":59,"authors":61},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","3d9ff205-1640-4f34-b5b6-86977f51bbd6",[21,22],[52],{"url":25,"caption":26},[],[21,29],[15],[32],[46],[],[60],1870,[62,63,64,65],2015,2016,2017,2018,{"id":67,"name":68,"code":69,"latitude":70,"longitude":71},226,"Uganda","UG",1.37333,32.29028,[],[74],{"id":60,"publications_id":75,"directus_files_id":87},{"id":5,"status":6,"sort":7,"user_created":48,"date_created":8,"user_updated":49,"date_updated":9,"nid":10,"slug":11,"image":34,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":76,"link_internal":77,"link_external":79,"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},[21,22],[78],{"url":25,"caption":26},[],[21,29],[15],[32],[46],[],[60],[62,63,64,65],{"id":88,"storage":35,"filename_disk":89,"filename_download":90,"title":90,"type":91,"folder":92,"uploaded_by":48,"created_on":93,"modified_by":7,"modified_on":93,"charset":7,"filesize":94,"width":7,"height":7,"duration":7,"embed":7,"description":95,"location":7,"tags":7,"metadata":7,"focal_point_x":7,"focal_point_y":7,"tus_id":7,"tus_data":7,"uploaded_on":93},"074148b4-2c9b-4880-86e3-34a0ecd60b45","074148b4-2c9b-4880-86e3-34a0ecd60b45.pdf","WP33-Wildlife-trafficking-in-Uganda.pdf","application\u002Fpdf","67f22e04-d26f-4baa-b91f-acc5f89d87f5","2022-04-27T11:54:05.000Z",830272,"View PDF",[97,114,131,147],{"id":62,"publications_id":98,"authors_id":110},{"id":5,"status":6,"sort":7,"user_created":48,"date_created":8,"user_updated":49,"date_updated":9,"nid":10,"slug":11,"image":34,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":99,"link_internal":100,"link_external":102,"featured":19,"topics":103,"languages":104,"type":105,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":106,"tags":107,"pdf":108,"authors":109},[21,22],[101],{"url":25,"caption":26},[],[21,29],[15],[32],[46],[],[60],[62,63,64,65],{"id":111,"name":112,"position":7,"image":113},303,"Saba Kassa","a34de431-6c31-4ddd-8727-12c10dfed9ad",{"id":63,"publications_id":115,"authors_id":127},{"id":5,"status":6,"sort":7,"user_created":48,"date_created":8,"user_updated":49,"date_updated":9,"nid":10,"slug":11,"image":34,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":116,"link_internal":117,"link_external":119,"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},[21,22],[118],{"url":25,"caption":26},[],[21,29],[15],[32],[46],[],[60],[62,63,64,65],{"id":128,"name":129,"position":7,"image":130},304,"Jacopo Costa","90469998-3598-471d-9499-48b19f557c7d",{"id":64,"publications_id":132,"authors_id":144},{"id":5,"status":6,"sort":7,"user_created":48,"date_created":8,"user_updated":49,"date_updated":9,"nid":10,"slug":11,"image":34,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":133,"link_internal":134,"link_external":136,"featured":19,"topics":137,"languages":138,"type":139,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":140,"tags":141,"pdf":142,"authors":143},[21,22],[135],{"url":25,"caption":26},[],[21,29],[15],[32],[46],[],[60],[62,63,64,65],{"id":145,"name":146,"position":7,"image":7},358,"Robert Lugolobi",{"id":65,"publications_id":148,"authors_id":160},{"id":5,"status":6,"sort":7,"user_created":48,"date_created":8,"user_updated":49,"date_updated":9,"nid":10,"slug":11,"image":34,"title":12,"body":13,"citation":14,"language":15,"year":16,"publisher":17,"date_published":18,"external":19,"topic":149,"link_internal":150,"link_external":152,"featured":19,"topics":153,"languages":154,"type":155,"area":7,"programme":7,"websites":7,"summary":7,"pdf_text":7,"main_points":7,"short_version":7,"subtitle":7,"countries":156,"tags":157,"pdf":158,"authors":159},[21,22],[151],{"url":25,"caption":26},[],[21,29],[15],[32],[46],[],[60],[62,63,64,65],{"id":161,"name":162,"position":7,"image":163},295,"Claudia Baez Camargo","efaca248-6b57-4e2e-af40-614056eb022c",[165,199,235,270,313,356,392,446,498,531],{"id":166,"slug":167,"title":168,"status":6,"nid":169,"year":170,"body":171,"external":19,"topic":172,"language":15,"type":173,"date_published":175,"image":176,"citation":14,"publisher":177,"link_internal":178,"link_external":179,"authors":183,"countries":190,"tags":191,"pdf":192,"topics":194,"featured":19,"languages":195,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":196,"user_updated":49,"date_updated":197,"main_points":7,"short_version":7,"subtitle":7,"link":198},2319,"translating-political-economy-insights-conservation-practice-six-step-guide","Translating political economy insights into conservation practice: a six-step guide",2540,2023,"This guide suggests six steps for bringing political economy analysis findings into a theory of change for a project or programme.\n\nIt aims to provide a practical means for conservationists to navigate political economy in contexts where they work. While a theory of change explains the logic of a project, a political economy analysis, which looks at the influence of power, helps get to the heart of what needs to change for a project to work. But practitioners often find it challenging to use political economy analysis in practice. \n\nThe aim of conservation is to safeguard people and nature. Theories of change articulate what needs to change to deliver on that aim, along with the kinds of things that need to happen to get to that change – *what needs to be different.*\n\nUnderstanding more about who has power – to make change, to impede change – and how they get and use that power helps to clarify the conditions that need to change in order to achieve results.\n\n### About the TNRC project\n\nThe \u003Ca href=\"https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-about-the-project\">TNRC project\u003C\u002Fa> seeks to improve biodiversity conservation outcomes by helping practitioners to address the threats posed by corruption to wildlife, fisheries and forests. TNRC harnesses existing knowledge, generates new evidence, and supports innovative policy and practice for more effective anti-corruption programming on the ground.\n\nA USAID-funded project, TNRC is implemented by a consortium of leading organisations in anti-corruption, natural resource management, and conservation: World Wildlife Fund (WWF), the U4 Anti-Corruption Resource Centre at the Chr. Michelsen Institute, TRAFFIC, and the Terrorism, Transnational Crime and Corruption Center (TraCCC) at George Mason University.\n\nThis publication is made possible by the generous support of the American people through the United States Agency for International Development (USAID). The contents are the responsibility of the author(s) and do not necessarily reflect the views of USAID, the United States Government, or individual TNRC consortium members.",[21,22],[174],"Guidelines","2023-11-22","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fdd7c3fec-b214-4620-b4d7-e2ead8e0c17a?width=600&height=840","Targeting Natural Resource Corruption (TNRC) project",[],[180],{"url":181,"caption":182},"https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-guide-translating-political-economy-insights-into-conservation-practice-a-six-step-guide-to-using-peas-to-design-and-test-theories-of-change-for-interventions-to-protect-and-defend-nature?p=2c9219&v=1&hours=1000","View on TNRC website",[184,188],{"authors_id":185},{"id":186,"name":187},530,"Micol Martini",{"authors_id":189},{"id":111,"name":112},[],[],[193],2358,[21,29],[15],"2023-11-22T11:04:41.000Z","2026-05-29T22:22:43.000Z","\u002Fresources\u002Fpublications\u002Ftranslating-political-economy-insights-conservation-practice-six-step-guide",{"id":200,"slug":201,"title":202,"status":6,"nid":203,"year":170,"body":204,"external":19,"topic":205,"language":15,"type":206,"date_published":208,"image":209,"citation":14,"publisher":17,"link_internal":210,"link_external":214,"authors":215,"countries":218,"tags":219,"pdf":228,"topics":230,"featured":19,"languages":231,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":232,"user_updated":49,"date_updated":233,"main_points":7,"short_version":7,"subtitle":7,"link":234},2311,"research-case-4","Research case study 4: Deconstructing a criminal network involved in illegal wildlife trade between East Africa and Southeast Asia ",2518,"The illegal wildlife trade threatens biodiversity and security worldwide. Criminal networks pocket billions of dollars in illicit profits from stripping the world bare of endangered species and corrupting politicians and public officials in the process.\n\nYet there is very little empirical evidence on the role of both ordinary citizens and criminal networks in the illegal wildlife trade. Our research aims to fill this gap.\n\nWe used social network analysis and network ethnography techniques to study the criminal network of a wildlife trafficker based in East Africa. The insights can bolster law enforcement efforts aimed at identifying and dismantling wildlife trafficking networks.",[21,22],[207],"Research Case Study","2023-10-11","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F19e03984-8caf-4871-8d80-b7226ea6403c?width=600&height=840",[211],{"url":212,"caption":213},"\u002Fresources\u002Fpublications?type=Research%20Case%20Study"," View all research case studies",[],[216],{"authors_id":217},{"id":128,"name":129},[],[220,224],{"tags_id":221},{"id":222,"name":223},1303,"Environment",{"tags_id":225},{"id":226,"name":227},1309,"Informality",[229],2347,[21,29],[15],"2023-10-11T16:04:41.000Z","2026-06-02T14:08:41.000Z","\u002Fresources\u002Fpublications\u002Fresearch-case-4",{"id":236,"slug":237,"title":238,"status":6,"nid":239,"year":240,"body":241,"external":19,"topic":242,"language":15,"type":243,"date_published":244,"image":245,"citation":14,"publisher":177,"link_internal":246,"link_external":247,"authors":250,"countries":261,"tags":262,"pdf":263,"topics":265,"featured":19,"languages":266,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":267,"user_updated":49,"date_updated":268,"main_points":7,"short_version":7,"subtitle":7,"link":269},2253,"how-political-economy-analysis-can-support-corruption-risk-assessments-strengthen-law","How political economy analysis can support corruption risk assessments to strengthen law enforcement against wildlife crimes",2333,2022,"As part of a collaboration with the \u003Ca href=\"http:\u002F\u002Ftnrcproject.org\u002F\">Targeting Natural Resource Corruption\u003C\u002Fa> (TNRC) project, the Basel Institute on Governance undertook political economy analyses in three countries in Latin America and Africa.\n\nThe purpose was to understand why corruption risks may emerge in investigations and prosecutions of illegal wildlife trade (IWT) cases. The analyses complemented the findings of \u003Ca href=\"http:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwhere-are-weakest-links-illegal-wildlife-trade-enforcement-chain-lessons-corruption\">corruption risks assessments\u003C\u002Fa> conducted in the three countries and focused on the IWT law enforcement process.\n\nThe experience showed that political economy analyses can help practitioners better understand corruption risks in a specific context. This understanding helps practitioners to design and implement corruption risk mitigation measures that take prevailing political and power dynamics into account. In particular, it helps to identify windows of opportunity for addressing corruption risks and highlight strategically important stakeholders that may support or oppose the intervention.\n\nBased on the research, this Practice Note:\n\n\n- summarises the value added and key insights gained by complementing the corruption risk assessments with political economy analyses;\n- explains the lessons learned from the experience of implementing the analyses;\n- offers practical guidance to natural resource management and conservation practitioners interested in incorporating a similar approach in the design of corruption risk mitigation measures.\n\n\nThe paper was developed by the Basel Institute's \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance\">Public Governance\u003C\u002Fa> team together with the \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption\">Green Corruption programme\u003C\u002Fa> as part of a wider research collaboration between the Basel Institute and TNRC project consortium. \n\n### About the TNRC project\n\nThe TNRC project seeks to improve biodiversity conservation outcomes by helping practitioners to address the threats posed by corruption to wildlife, fisheries and forests. TNRC harnesses existing knowledge, generates new evidence, and supports innovative policy and practice for more effective anti-corruption programming on the ground.\n\nA USAID-funded project, TNRC is implemented by a consortium of leading organizations in anti-corruption, natural resource management, and conservation: World Wildlife Fund (WWF), the U4 Anti-Corruption Resource Centre at the Chr. Michelsen Institute, TRAFFIC, and the Terrorism, Transnational Crime and Corruption Center (TraCCC) at George Mason University.",[21,22],[],"2022-12-15","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F72d4cda9-af95-421b-bb64-782e1e010fea?width=600&height=840",[],[248],{"url":249,"caption":182},"https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-practice-note-how-political-economy-analysis-can-support-corruption-risk-assessments-to-strengthen-law-enforcement-against-wildlife-crimes",[251,253,255,259],{"authors_id":252},{"id":111,"name":112},{"authors_id":254},{"id":128,"name":129},{"authors_id":256},{"id":257,"name":258},354,"Cosimo Stahl",{"authors_id":260},{"id":161,"name":162},[],[],[264],2295,[21,29],[15],"2022-12-15T11:04:13.000Z","2026-05-29T22:23:10.000Z","\u002Fresources\u002Fpublications\u002Fhow-political-economy-analysis-can-support-corruption-risk-assessments-strengthen-law",{"id":271,"slug":272,"title":273,"status":6,"nid":274,"year":240,"body":275,"external":19,"topic":276,"language":15,"type":277,"date_published":280,"image":281,"citation":14,"publisher":282,"link_internal":283,"link_external":284,"authors":288,"countries":295,"tags":296,"pdf":306,"topics":308,"featured":19,"languages":309,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":310,"user_updated":49,"date_updated":311,"main_points":7,"short_version":7,"subtitle":7,"link":312},2195,"wp-39","Working Paper 39: Behavioural drivers of corruption facilitating illegal wildlife trade – Problem analysis and state of the field review",2210,"This Problem Analysis is a review of the efficacy and opportunities for using social norm and behaviour change (SNBC) approaches to combat illegal wildlife trade (IWT) and other natural resource-related corruption.\n\nBehavioural science is a rich and expansive field that has received prominent coverage in recent years for the promise it offers as a foundational yet underutilised approach to achieving biodiversity conservation. Extensive literature shows how SNBC initiatives can help combat diverse corruption problems, although for those related to natural resource management the evidence for doing so is sparse.\n\nThis report synthesises the available information and suggests the next steps to redress this current lack of evidence. It seeks to:\n\n\n- Understand what SNBC approaches might or might not work in fighting corruption.\n- Identify entry points for designing SNBC interventions that can effectively reduce corruption related to IWT.\n\n\n### About and acknowledgements\n\nThis Analysis has been produced in association with the Targeting Natural Resource Corruption (TNRC) project. The TNRC project is working to improve biodiversity outcomes by helping practitioners to address the threats posed by corruption to wildlife, fisheries and forests. TNRC harnesses existing knowledge, generates new evidence, and supports innovative policy and practice for more effective anti-corruption programming. Learn more at \u003Ca href=\"https:\u002F\u002Ftnrcproject.org\">tnrcproject.org\u003C\u002Fa>.\n\nThis publication is made possible by the generous support of the American people through the United States Agency for International Development (USAID). The contents are the responsibility of the authors and do not necessarily reflect the views of USAID, the United States Government, or individual TNRC consortium members.\n\nThe publication is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. It is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).\n\nSuggested citation: Baez Camargo, Claudia, and Gayle Burgess. 2022. “Behavioural drivers of corruption facilitating illegal wildlife trade: Problem analysis and state of the field review.” Working Paper 39, Basel Institute on Governance. Available at: \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-39\">https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-39\u003C\u002Fa>",[21,22],[278,279],"Article","Report","2022-06-01","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F9f6e8d24-9468-43cb-949d-bdbd25d35adb?width=600&height=840","Basel Institute on Governance; TRAFFIC",[],[285],{"url":286,"caption":287},"https:\u002F\u002Fbaselgovernance.zoom.us\u002Fwebinar\u002Fregister\u002FWN_VUh1-aisS-Su1Cuwc8vWlA"," Register for virtual event - 27 June 2022",[289,291],{"authors_id":290},{"id":161,"name":162},{"authors_id":292},{"id":293,"name":294},501,"Gayle Burgess",[],[297,300,302],{"tags_id":298},{"id":46,"name":299},"Natural resources",{"tags_id":301},{"id":222,"name":223},{"tags_id":303},{"id":304,"name":305},848,"Behavioural science",[307],2234,[21,29],[15],"2022-06-09T13:42:35.000Z","2026-05-31T22:52:04.000Z","\u002Fresources\u002Fpublications\u002Fwp-39",{"id":314,"slug":315,"title":316,"status":6,"nid":317,"year":240,"body":318,"external":19,"topic":319,"language":15,"type":320,"date_published":321,"image":322,"citation":14,"publisher":323,"link_internal":324,"link_external":331,"authors":335,"countries":344,"tags":345,"pdf":350,"topics":351,"featured":19,"languages":352,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":353,"user_updated":49,"date_updated":354,"main_points":7,"short_version":7,"subtitle":7,"link":355},1766,"determinants-and-drivers-wildlife-trafficking-qualitative-analysis-uganda","Determinants and drivers of wildlife trafficking: A qualitative analysis in Uganda",2163,"The article analyses drivers and determinants of illicit wildlife trade (IWT), targeting those factors that support the participation of individuals in poaching and transportation of wildlife goods.\n\nThese factors are often explained in economic and institutional terms. Recently, scholars have started to recognise the importance of socio-cultural and behavioural drivers in influencing the individual propensity to engage in wildlife trafficking. The goal is clarifying how behavioural drivers may spur individuals to engage in these phenomena. The research provides further understanding on why wildlife trafficking happens by focusing on the role of the socio-economic context, the broader governance environment, and behavioural drivers associated with sociality and stereotypes in spurring participation in IWT.\n\nThe research is based on fieldwork in Uganda, specifically on 47 interviews with Ugandan-based and international anti-IWT experts and eight focus group discussions with wildlife conservation and anti-corruption experts in Kampala, members of reformed poachers’ networks in Western Uganda, and individuals living around a wildlife habitat in northern Uganda.\n\nThe findings highlight that illicit wildlife trade is spurred by the wish for financial resources (economic factors) and weak governance (quality of governance), and it is justified by mental models, that is, the behavioural drivers such as socio-contextual and normative mechanisms. The research shows the importance of reflecting on the role that behavioural drivers, including sociality and shared understandings of IWT, play in influencing the propensity of individuals to engage in poaching and the early stages of wildlife trafficking.\n\n### Acknowledgement and citation\n\nThis publication arose out of a collaboration between the Basel Institute's \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance\">Public Governance\u003C\u002Fa> and \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption\">Green Corruption\u003C\u002Fa> teams. The research presented in this publication forms part of a two-year project aimed at stopping corruption from fuelling illegal wildlife trade between East Africa and Southeast Asia.\n\nThis research was funded by PMI IMPACT, a grant award initiative of Philip Morris International (PMI). In the performance of their research, the authors maintained full independence from PMI. The views and opinions expressed in this document are those of the authors and do not necessarily reflect the views of PMI. Neither PMI, nor any of its affiliates, nor any person acting on their behalf may be held responsible for any use which may be made of the information contained herein.\n\nCitation: Saba Kassa, Claudia Baez-Camargo, Jacopo Costa & Robert Lugolobi (2022) Determinants and Drivers of Wildlife Trafficking: A Qualitative Analysis in Uganda, *Journal of International Wildlife Law & Policy*, DOI: \u003Ca href=\"https:\u002F\u002Fdoi.org\u002F10.1080\u002F13880292.2021.2019381\">10.1080\u002F13880292.2021.2019381\u003C\u002Fa>",[21,22],[278],"2022-01-13","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F0f25db65-39c2-4fad-babd-d553fd271acc?width=600&height=840","Journal of International Wildlife Law & Policy",[325,328],{"url":326,"caption":327},"\u002Fresources\u002Fpublications\u002Fworking-paper-33-worms-eye-view-wildlife-trafficking-uganda-path-least-resistance"," Related publication: Working Paper 33: A worm’s-eye view of wildlife trafficking in Uganda – the path of least resistance",{"url":329,"caption":330},"\u002Fresources\u002Fpublications\u002Fpolicy-brief-5-curbing-wildlife-trafficking-uganda-lessons-practitioners"," Related publication: Policy Brief 5: Curbing wildlife trafficking in Uganda: lessons for practitioners",[332],{"url":333,"caption":334},"https:\u002F\u002Fdoi.org\u002F10.1080\u002F13880292.2021.2019381","Access article via Taylor & Francis Online",[336,338,340,342],{"authors_id":337},{"id":111,"name":112},{"authors_id":339},{"id":161,"name":162},{"authors_id":341},{"id":128,"name":129},{"authors_id":343},{"id":145,"name":146},[],[346,348],{"tags_id":347},{"id":222,"name":223},{"tags_id":349},{"id":304,"name":305},[],[21,29],[15],"2022-04-27T11:53:21.000Z","2026-06-02T14:09:05.000Z","\u002Fresources\u002Fpublications\u002Fdeterminants-and-drivers-wildlife-trafficking-qualitative-analysis-uganda",{"id":357,"slug":358,"title":359,"status":6,"nid":360,"year":240,"body":361,"external":19,"topic":362,"language":15,"type":363,"date_published":364,"image":365,"citation":14,"publisher":366,"link_internal":367,"link_external":368,"authors":375,"countries":378,"tags":379,"pdf":386,"topics":387,"featured":19,"languages":388,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":389,"user_updated":49,"date_updated":390,"main_points":7,"short_version":7,"subtitle":7,"link":391},1769,"structures-functions-and-flows-iwt-deconstructing-criminal-network-between-east-africa","Structures, functions and flows of IWT: deconstructing a criminal network between East Africa and Southeast Asia",2156,"The paper investigates the role of criminal networks in fostering illegal wildlife trade (IWT), and how these relational structures interact with transnational organized crime. The paper frames these topics within the debate around the opportunistic or organized nature of IWT. The aim is to understand how chaotic behaviors can transform into an ordered and organized strategy.\n\nSocial network analysis (SNA) and network ethnography were conducted to explore the crime network surrounding a wildlife trafficker based in East Africa. The empirical results suggest that criminal networks operate as \"machine of order\" that transform opportunistic behaviors at the micro level into ordered strategies at the macro level.\n\nEmpirical results also suggest that organized crime has an important role in making the process of transforming opportunistic into organized behaviours more efficient and more effective.\n\n### Acknowledgement and citation\n\nThis publication arose out of a collaboration between the Basel Institute's \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance\">Public Governance\u003C\u002Fa> and \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption\">Green Corruption\u003C\u002Fa> teams. The research presented in this publication forms part of a two-year project aimed at stopping corruption from fuelling illegal wildlife trade between East Africa and Southeast Asia.\n\nThis research was funded by PMI IMPACT, a grant award initiative of Philip Morris International (PMI). In the performance of their research, the authors maintained full independence from PMI. The views and opinions expressed in this document are those of the authors and do not necessarily reflect the views of PMI. Neither PMI, nor any of its affiliates, nor any person acting on their behalf may be held responsible for any use which may be made of the information contained herein.\n\nCitation: Costa, J. Structures, functions and flows of IWT: deconstructing a criminal network between East Africa and Southeast Asia. *Crime Law Soc Change* (2022). \u003Ca href=\"https:\u002F\u002Fdoi.org\u002F10.1007\u002Fs10611-021-10009-8\">https:\u002F\u002Fdoi.org\u002F10.1007\u002Fs10611-021-10009-8\u003C\u002Fa>",[21,22],[278],"2022-01-08","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F5363c185-1d3b-46af-a1ff-d0a28819f2b1?width=600&height=840","Crime, Law and Social Change",[],[369,372],{"url":370,"caption":371},"https:\u002F\u002Frdcu.be\u002FcEzfQ","View article (full text, no download)",{"url":373,"caption":374},"https:\u002F\u002Fdoi.org\u002F10.1007\u002Fs10611-021-10009-8"," Log in to Springer Link to download article",[376],{"authors_id":377},{"id":128,"name":129},[],[380,382],{"tags_id":381},{"id":222,"name":223},{"tags_id":383},{"id":384,"name":385},967,"Organised crime",[],[21,29],[15],"2022-04-27T11:53:23.000Z","2026-05-29T22:23:13.000Z","\u002Fresources\u002Fpublications\u002Fstructures-functions-and-flows-iwt-deconstructing-criminal-network-between-east-africa",{"id":393,"slug":394,"title":395,"status":6,"nid":396,"year":397,"body":398,"external":19,"topic":399,"language":15,"type":400,"date_published":401,"image":402,"citation":403,"publisher":17,"link_internal":404,"link_external":408,"authors":409,"countries":418,"tags":419,"pdf":436,"topics":440,"featured":19,"languages":7,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":441,"sort":7,"user_created":48,"date_created":442,"user_updated":49,"date_updated":443,"main_points":7,"short_version":444,"subtitle":7,"link":445},2431,"wp-61","Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond",2881,2025,"At the 8th session of the Conference of the States Parties to the United Nations Convention against Corruption (UNCAC), in December 2019, States Parties adopted a resolution recognising the relationship between corruption and environmental crimes.\n\nResolution 8\u002F12 – *Preventing and combating corruption as it relates to crimes that have an impact on the environment* – is a landmark Resolution. With its 23 operative paragraphs (OPs), it underlies the importance of addressing corruption linked to crimes that have an impact on the environment. It urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.\n\n*Saplings of hope* presents an updated overview of emerging and promising prevention and enforcement actions, initiatives and measures implemented by UNCAC States Parties to combat corruption as it pertains to crimes that have an impact on the environment. It focuses specifically on initiatives from 2024 and 2025.\n\nThe Working Paper also underscores the valuable contributions made by non-state actors, in particular civil society, academia and the media, in this collective endeavour.\n\nFinally, it makes the case for a paradigm shift, moving from \"corruption as it relates to crimes that have an impact on the environment\" to \"**corruption that has an impact on the environment**\". The shift is necessary, because corruption can harm the environment without being linked to a crime that has an impact on the environment. Section 5 thus explores two interconnected issues which have a devastating impact on the environment: corruption linked to climate finance and renewable energy as well as corruption tied to the exploitation of critical minerals.\n\n### About this Working Paper\n\nThis report is part of the Green Corruption programme at the Basel Institute on Governance and was prepared in the context of the 11th Conference of the States Parties to the UN Convention against Corruption in Doha, Qatar, from 14–19 December 2025.\n\nIt provides an update to Working Paper 50, 'Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8\u002F12’, which was prepared in the context of CoSP10 in Atlanta, Georgia, US in 2023.\n\nThe report is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. You may share or republish the report under a Creative Commons \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa> licence.\n\nIt was made possible by the generous support of the Principality of Liechtenstein.\n\nThe contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n\n",[21],[32],"2025-12-11","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002F85b2c8ec-9f32-46b0-81ec-ea6143ac15b2?width=600&height=840","Lemaître, Sophie. 2025. ‘Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond.’ Working Paper 61, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-61.",[405],{"url":406,"caption":407},"\u002Fresources\u002Fpublications\u002Fwp-50"," View related Working Paper 50",[],[410,414],{"authors_id":411},{"id":412,"name":413},578,"Dr Sophie Lemaître",{"authors_id":415},{"id":416,"name":417},579,"Dr Amanda Cabrejo le Roux",[],[420,422,426,430,434],{"tags_id":421},{"id":222,"name":223},{"tags_id":423},{"id":424,"name":425},1373,"Corruption prevention",{"tags_id":427},{"id":428,"name":429},1374,"Law enforcement",{"tags_id":431},{"id":432,"name":433},1375,"Civil society",{"tags_id":435},{"id":46,"name":299},[437,438,439],2485,2486,2487,[21],"\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n## Saplings of hope\n\n## Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond\n\nSophie Lemaître and Amanda Cabrejo le Roux | December 2025\n\n\u003C!-- image -->\n\n## About this report\n\nAdopted in 2019, UNCAC Resolution 8\u002F12 Preventing and combating corruption as it relates to crimes that have an impact on the environment - urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.\n\nSaplings of hope provides an updated overview of emerging and promising initiatives across the world since the adoption of Resolution 8\u002F12, focusing on progress in 2024 and 2025.\n\nThis report is part of the Green Corruption programme at the Basel Institute on Governance. It was prepared in the context of the 11th Conference of the States Parties to the UN Convention against Corruption in Doha, Qatar, from 14-19 December 2025.\n\nIt provides an update to Working Paper 50, 'Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8\u002F12' , which was prepared in the context of CoSP10 in Atlanta, Georgia, US in 2023.\n\nThe report is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. You may share or republish the Working Paper under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).\n\nIt was made possible by the generous support of the Principality of Liechtenstein.\n\nThe contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n\nSuggested citation: Lemaître, Sophie, and Amanda Cabrejo le Roux. 2025. 'Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond.' Working Paper 61, Basel Institute on Governance. Available at: baselgovernance.org\u002Fpublications\u002Fwp-61.\n\n## About the authors\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n## Dr Sophie Lemaître, main author\n\nAnti-corruption and natural resources expert\n\nDr Sophie Lemaître is a lawyer by training with experience in anti-corruption issues, natural resources sector, and lawfare. She worked for various organisations and NGOs at the national and international level, including CIRAD, the Food and Agriculture Organisation of the United Nations, Sherpa and U4 Anti-Corruption Resource Centre.\n\nSophie holds a PhD degree in Law from the University of Rennes 1 (France) on illicit financial flows within the extractive industries. She also holds a Master's degree in International Business Law from the University of Toulouse (France) as well as an LL.M. in International and European Environmental Law and Policy from University College London (United Kingdom).\n\nEmail: sophie.lemaitre34@gmail.com\n\n## Dr Amanda Cabrejo le Roux\n\nSenior Specialist and Deputy Director of the Green Corruption programme, Basel Institute on Governance\n\nDr Amanda Cabrejo le Roux leads the implementation of the Basel Institute's Green Corruption activities in Africa, Asia and South America. She also leads research efforts and the involvement of the Green Corruption programme in the Countering Environmental Corruption Practitioners Forum.\n\nAmanda holds a PhD in International and Comparative Criminal Law from the Sorbonne Law School (University Paris I PantheonSorbonne). She also holds an LL.M. in International Criminal Law (University of Amsterdam\u002FColumbia Law School), Master's degrees in French Law and Comparative Criminal Law (Sorbonne Law School) and Spanish Law (Universidad Complutense), and Bachelor's degrees in History (University Paris 1) and Anthropology (University Paris 8).\n\nEmail: amanda.cabrejo@baselgovernance.org\n\n## Acknowledgements\n\nThis report benefited from contributions of numerous individuals who shared their expertise, insights and views during interviews and made themselves promptly available.\n\nThe authors would like to express their gratitude to: Paulus K. Noa from the AntiCorruption Commission Namibia; Jacob Phelps from Conservation-Litigation.org; Lisa Hartevelt from Wildlife Justice Commission; Laurent Szymkowiak from the World Customs Organization; Maria Adomeit, Daniela Sota Valdivia and Beatrice Fantacci from the United Nations Office on Drugs and Crimes; Liisa Kytola from the Thomson Reuters Foundation; Nicole Byrd and Andrea Crosta from Earth League International; John Mugendi from Kenya Wildlife Service; Alina Blaga-Smith from WWF and Jim Mtafya from the Malawi Anti-Corruption Bureau. Without their inputs, the report would not have been possible.\n\nThe authors are also grateful for the colleagues of the Green Corruption programme of the Basel Institute on Governance for their support, insights and first-hand experience in implementing corruption prevention and enforcement interventions with our government partners: Lakso Anindito, Aldo Bautista, Svitlana Lutsiuk and Joseph Rakotondramanana.\n\n## Executive summary\n\nAdopted in 2019, UNCAC Resolution 8\u002F12 Preventing and combating corruption as it relates to crimes that have an impact on the environment - urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.\n\nIn 2023, the Basel Institute on Governance published its Working Paper 50, Seedlings of hope , providing a panorama of emerging and promising initiatives across the world since the adoption of Resolution 8\u002F12. The purpose of the updated report Saplings of hope is to highlight what progress has been achieved since then.\n\n## Corruption prevention measures\n\nStates have implemented a host of initiatives to strengthen integrity systems. Most commonly, this included the revision and adoption of internal control policies, more dedicated risk management efforts, including through the establishment of corruption prevention committees, and a range of capacity building efforts to strengthen environmental agencies' ability to mitigate their own corruption risks, such as workshops on ethics codes and other integrity measures. Whistleblower protection programmes were increasingly designed, implemented and promoted. Corruption risk assessments were conducted in sectors such as wildlife management, forestry and fisheries.\n\nPromising corruption prevention interventions include:\n\n- · Conducting regular corruption perception and experience surveys among staff . This can help assess both progress and the effectiveness of corruption prevention measures. It can also create baselines against which to measure progress. Not enough interventions and reform efforts start with such a baseline, which means they then struggle to assess progress.\n- · Involving high-level management and leadership at each stage of the corruption prevention approach. This can help develop ownership and accountability. Explaining how integrity efforts support the strategic and political priorities of the leadership is crucial to achieve this. It requires adapting technocratic approaches to be relevant to the institutional leadership.\n- · Stipulating a mandatory budget for corruption prevention across ministries, agencies and departments. This can help ensure that minimal investments in integrity and anti-corruption activities are effectively prioritised and implemented. Sanctions for not respecting the mandatory budget should be imposed.\n- · Launching awareness-raising campaigns to promote knowledge of anti-corruption measures. This is an important first step to their effective implementation.\n\n- · Developing whistleblowing mechanisms . They can help increase reporting and detection of corruption. To achieve their potential, whistleblower mechanisms require a strong system, reliable protections and an institutional culture that welcomes such feedback.\n- · Peer-to-peer learning for government representatives from different countries and institutions to exchange on corruption prevention actions. This can be relevant, as anti-corruption officials often struggle with similar institutional challenges. Peer exchanges can help people and institutions to learn from each other's successes and challenges and jointly identify effective mitigation measures.\n\n## Enforcement actions\n\nSeveral countries have investigated and prosecuted corruption cases linked to crimes that have an impact on the environment. Financial investigations and money laundering legislation are more frequently used to tackle these crimes. The systematic seizure and confiscation of assets is still just beginning, as is the creation of multi-agency and interdisciplinary task forces, nationally and internationally. However, enforcement actions on corruption as it relates to crimes that have an impact on the environment are still limited.\n\nPromising enforcement interventions include:\n\n- · Assessing the economic, social and environmental losses from cases of corruption linked to crimes that have an impact on the environment and using these to calculate associated penalties and fines - can help compensate and restore some of the harm done. Combining calculations of losses due to corruption with those of losses due to the environmental crimes can result in stiffer sentences and penalties.\n- · Seizing and confiscating proceeds and instrumentalities of crime (bank accounts, real estate, vehicles, machineries, etc.) through the diverse legal instruments available in jurisdictions can help ensure that crime does not pay. It also removes the resources needed to continue activities that harm the environment, thereby halting ongoing destruction.\n- · Exploring legal avenues outside the anti-corruption field can help strengthen enforcement. These include legislation on money laundering and tax offences as well as the social re-use of seized and confiscation assets, sanctions and visa bans.\n\n## Essential role of civil society and the media\n\nAlongside States, civil society organisations and the media have played an essential role in increasing our understanding of the relationship between corruption and crimes that have an impact on the environment.\n\nTheir efforts span investigative reporting, publishing evidence-based research, capacity building, creating networks to bridge the gap between anti-corruption and environmental practitioners, as well as initiating strategic litigation cases. Their involvement is all the more commendable given that they are facing an increasingly repressive environment.\n\n## The way forward\n\nAs this Working Paper highlights, various activities are taking place to tackle corruption linked to crimes that have an impact on the environment. The paper picks out those that show significant promise. The diversity of engagements is laudable, but it is far from the scale needed to make a systemic difference to both societal corruption and environmental challenges. States Parties need to adapt and scale up initiatives that are effective or look promising, by, among other things:\n\n- · Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources.\n- · Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment.\n- · Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms.\n- · Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment.\n- · Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment.\n- · Making use of legal frameworks and testing new legal avenues to hold individuals and legal persons accountable, including through asset recovery and remedies to repair the damage.\n- · Engaging in platforms for representatives from governments, civil society and other stakeholder groups to exchange experiences and know-how in tackling corruption that has an impact on the environment.\n- · Sharing knowledge , case law, success stories, etc.\n- · Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity.\n\n- · Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related issues.\n\nAs these initiatives have now been conducted for six years, there is a sufficient body to scrutinise their effectiveness and efficiency. It is therefore essential to rigorously assess these measures , especially in an environment of increasingly scarce financial resources.\n\n## Addressing corruption that has an impact on the environment\n\nThe Working Paper also makes a case for moving from the concept of 'corruption as it relates to crimes that have an impact on the environment' to ' corruption that has an impact on the environment ' .\n\nFocusing solely on corruption linked to crimes that have an impact on the environment overlooks situations where corruption causes environmental harm without an associated criminal offence. It does not take into consideration pressing issues such as corruption linked to climate finance, renewable energy and the exploitation of critical minerals.\n\nAdopting a holistic approach is crucial to address all forms of corruption that affect the environment, and thus to protect the environment and people.\n\n## Acronyms and abbreviations\n\nACAMS\n\nAssociation of Certified Anti-Money Laundering Specialists\n\nAI\n\nArtificial intelligence\n\nCIJ\n\nCentre for Investigative Journalism\n\nCITES\n\nConvention on International Trade in Endangered Species of Wild Fauna and Flora\n\nDRC\n\nDemocratic Republic of the Congo\n\nEITI\n\nExtractive Industries Transparency Initiative\n\nFINTRAC\n\nFinancial Transactions and Reports Analysis Centre of Canada\n\nGUARD Wildlife\n\nGlobal United Action to Reduce and Dismantle Wildlife Crime\n\nICJ\n\nInternational Consortium of Investigative Journalists\n\nIIC\n\nInstitutional Integrity Committee\n\nNRGI\n\nNatural Resource Governance Institute\n\nOP\n\nOperative paragraph of a UN Resolution\n\nSANParks\n\nSouth African National Parks\n\nSOP\n\nStandard operating procedure\n\nSTR\n\nSuspicious transaction report\n\nUNCAC\n\nUnited Nations Convention against Corruption\n\nUNODC\n\nUnited Nations Office on Drugs and Crime\n\nWCO\n\nWorld Customs Organization\n\nTable of contents\n\n| Executive summary ��������������������������������������������������������������������������������������������������5                                                    | Executive summary ��������������������������������������������������������������������������������������������������5                                                    |    |\n|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|\n| 1  Introduction   ��������������������������������������������������������������������������������������������������������������������������������������������������     | 1  Introduction   ��������������������������������������������������������������������������������������������������������������������������������������������������     | 12 |\n| 1.1                                                                                                                                                                      | What are crimes that have an impact on the environment?                                                                                                                  | 13 |\n| 1.2                                                                                                                                                                      | Corruption and crimes that have an impact on the environment  15                                                                                                         |    |\n| 1.3                                                                                                                                                                      | Purpose and structure of the report                                                                                                                                      | 16 |\n| 2  Prevention   ������������������������������������������������������������������������������������������������������������������������������������������������������   | 2  Prevention   ������������������������������������������������������������������������������������������������������������������������������������������������������   | 18 |\n| 2.1                                                                                                                                                                      | Promoting ethical practices, integrity and transparency (OP 6)                                                                                                           | 18 |\n| 2.2                                                                                                                                                                      | International Centre for Asset Recovery (ICAR)                                                                                                                           | 21 |\n| 2.3                                                                                                                                                                      | Assessing and mitigating corruption risks (OP 15)                                                                                                                        | 22 |\n| 3  Enforcement   ������������������������������������������������������������������������������������������������������������������������������������������������        | 3  Enforcement   ������������������������������������������������������������������������������������������������������������������������������������������������        | 26 |\n| 3.1                                                                                                                                                                      | Prosecuting corruption cases and holding legal and natural  persons accountable (OP 4, 9, 11)                                                                            | 27 |\n| 3.2                                                                                                                                                                      | Using anti-money laundering legislation and financial  investigation techniques (OP 11)                                                                                  | 29 |\n| 3.3                                                                                                                                                                      | Seizing and confiscating assets (OP 3 and 4)                                                                                                                             | 31 |\n| 3.4                                                                                                                                                                      | Strengthening cooperation (OP 10)                                                                                                                                        | 32 |\n| 3.5                                                                                                                                                                      | Making use of legal instruments available (OP 5)                                                                                                                         | 35 |\n| 4  Civil society and the media as key actors   ������������������������������������������������������������������������                                                  | 4  Civil society and the media as key actors   ������������������������������������������������������������������������                                                  | 37 |\n| 4.1                                                                                                                                                                      | Raising awareness through investigative journalism                                                                                                                       | 37 |\n| 4.2                                                                                                                                                                      | Strengthening knowledge with practitioner-oriented   research and learning                                                                                               | 39 |\n| 4.3                                                                                                                                                                      | Building bridges between anti-corruption and environmental  practitioners                                                                                                | 40 |\n| 4.4                                                                                                                                                                      | Initiating litigation for lasting change                                                                                                                                 | 42 |\n| 5  A paradigm shift for corruption and the environment   �������������������������������������������                                                                     | 5  A paradigm shift for corruption and the environment   �������������������������������������������                                                                     | 44 |\n| 5.1                                                                                                                                                                      | Corruption linked to climate finance and renewable energy                                                                                                                | 44 |\n|                                                                                                                                                                          | Corruption and critical minerals                                                                                                                                         | 46 |\n| 5.2  Conclusion   ����������������������������������������������������������������������������������������������������������������������������������������������������   | 5.2  Conclusion   ����������������������������������������������������������������������������������������������������������������������������������������������������   | 49 |\n| References   ����������������������������������������������������������������������������������������������������������������������������������������������������������� | References   ����������������������������������������������������������������������������������������������������������������������������������������������������������� | 54 |\n\n| Annex 1 - Relevant resources   �������������������������������������������������������������������������������������������������������������� 60                        |    |\n|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|\n| Resource hubs, learning platforms and tools                                                                                                                             | 60 |\n| Main publications since 2019 providing a global overview of  corruption, money laundering and financial crimes linked to crimes  that have an impact on the environment | 61 |\n| Annex 2 - Initiatives from the 2023  Seedlings of hope  report   ��������������������������������                                                                       | 64 |\n\n## 1 Introduction\n\nAt the 8th session of the Conference of the States Parties to the United Nations Convention against Corruption (UNCAC), in December 2019, States Parties adopted, for the first time, a resolution recognising the relationship between corruption and environmental crimes.1\n\nResolution 8\u002F12 Preventing and combating corruption as it relates to crimes that have an impact on the environment - is a landmark Resolution.2 With its 23 operative paragraphs (OPs), it underlies the importance of addressing corruption linked to crimes that have an impact on the environment. It urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment. Since then, several related resolutions have been passed (Box 1).\n\n## Box 1: A growing body of UN Resolutions addressing the link between corruption and crimes that have an impact on the environment\n\nFollowing the adoption of Resolution 8\u002F12, several other United Nations processes have adopted a similar approach such as:\n\n- · December 2020: Resolution 10\u002F6 Preventing and combating crimes that affect the environment falling within the scope of the United Nations Convention against Transnational Organized Crime -by the Conference of the Parties to the United Nations Convention against Transnational Organized Crime.3\n- · December 2021: Resolution 76\u002F185 Preventing and combating crimes that affect the environment - by the United Nations General Assembly.4\n- · October 2024: Resolution 12\u002F4 Enhancing measures to prevent and combat crimes that affect the environment falling within the scope of the United Nations Convention against Transnational Organized Crim e - by the Conference of the Parties to the United Nations Convention against Transnational Organized Crime.5\n- 1 It should be noted that at the 17th meeting of the Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) in 2016, States adopted Resolution 17.6 on Prohibiting, preventing, detecting and countering corruption, which facilitates activities conducted in violation of the Convention . This Resolution is nevertheless narrower in scope than Resolution 8\u002F12 of UNCAC in so far as the former focuses on corruption linked to violations of CITES while the latter covers a wider range of crimes that have an impact on the environment.\n- 2 Read the full text of Resolution 8\u002F12 at: https:\u002F\u002Fwww.unodc.org\u002Fdocuments\u002Ftreaties\u002FUNCAC\u002FCOSP\u002Fsession8\u002FV2006805e. pdf\n- 3 See: https:\u002F\u002Fwww.unodc.org\u002Fdocuments\u002Ftreaties\u002FUNTOC\u002FCOP\u002FSESSION\\_10\u002FResolutions\u002FResolution\\_10\\_6\\_-\\_English.pdf\n- 4 See: https:\u002F\u002Fdigitallibrary.un.org\u002Frecord\u002F3954773?ln=en\n- 5 See: https:\u002F\u002Fwww.unodc.org\u002Fdocuments\u002Ftreaties\u002FCOP12\u002FResolutions\u002FE\u002FResolution\\_12\\_4.pdf\n\n- · May 2025: Resolution on Tackling illicit trafficking in wild fauna and flora, including timber and timber products, the illegal mining of and illicit trafficking in minerals and precious metals, the illicit trafficking in waste and other crimes that affect the environment - by the UN Commission on Crime Prevention and Criminal Justice (CCPCJ).6\n\nIt is also worth highlighting Resolution 048\u002F052 on Crimes that Affect the Environment adopted by the International Union for Conservation of Nature at its World Conservation Congress in October 2025.7\n\n## 1�1 What are crimes that have an impact on the environment?\n\n'Environmental crimes' , 'crimes that affect the environment' , 'crimes related to the environment' , 'crimes that have an impact on the environment' and 'nature crimes' are terms that refer to the same reality: criminal activities that have a detrimental effect on the environment.\n\nThese terms are nevertheless rarely defined. When they are, the definitions often revolve around lists of specific offences or categories of offences that harm the environment rather than providing a comprehensive global definition.\n\nFor example, Resolution 8\u002F12 does not explicitly specify the meaning or the scope of what constitutes a crime that has an impact on the environment, leaving room for interpretation. It does, however, mention various criminal activities, e.g. illegally obtained natural resources and illicitly trafficked waste.\n\nOn the other hand, Resolution 76\u002F185 provides an initial outline of what these crimes entail. According to the Resolution, crimes that affect the environment encompass activities such as 'illicit trafficking in wildlife, including, inter alia, flora and fauna as protected by the Convention on International Trade in Endangered Species of Wild Fauna and Flora, in timber and timber products, in hazardous wastes and other wastes and in precious metals, stones and other minerals, as well as, inter alia, poaching' .\n\nThe lack of a universally agreed-upon definition reflects the fact that countries have different perspectives on the matter. They have also not yet reached a common understanding of what the term 'environment' encompasses. As there is no global consensus on a specific definition, this report will refer to crimes that have an impact on the environment as covering any offences (e�g� a breach of legislation, an unlawful act or conduct) that result in harm or pose a risk to the environment such as:\n\n- · Wildlife trafficking\u002Fwildlife crimes\n- · Crimes in the forestry sector\n- · Crimes in the fisheries sector\n- · Illegal mining and trafficking of metals and minerals\n- · Waste trafficking\n- · Air, water, noise and soil pollution\n- · Illegal trade of hydrofluorocarbons or ozone-depleting substances\n\nCrimes that have an impact on the environment are among the most lucrative criminal activities in the world (see Figure 1 for an estimate per crime category). However, finding recent and reliable statistics is challenging. Hence, the true extent of the financial gains made from these crimes is difficult to ascertain. These estimates may well, in fact, underestimate the actual criminal revenues.\n\nSources: World Atlas of Illicit Flows , Interpol, RHIPTO, and The Global Initiative against Transnational Organized Crime (2018, 15).\n\n\u003C!-- image -->\n\nCrimes that have an impact on the environment have disastrous consequences that extend far beyond the illicit profits generated by these activities. They significantly impact, and are detrimental to, the environment, public health and safety, and social and economic development.\n\nFor example, the World Bank estimated that governments lose between USD 7 and 12 billion annually in potential tax revenue. Nevertheless, measuring in financial terms the true cost and loss for the environment and human beings is extremely difficult.\n\n## 1�2 Corruption and crimes that have an impact on the environment\n\nThere is no universally agreed-upon definition of corruption. The UNCAC defines corruption by enumerating various categories of offences such as bribery, embezzlement, abuse of functions, trading in influence, money laundering and illicit enrichment. Transparency International's widely used definition describes corruption more broadly as the abuse of entrusted power for private gain.\n\nCorruption plays a crucial role in facilitating crimes that have an impact on the environment. Research and reporting by the United Nations Office on Drugs and Crime (UNODC), civil society organisations, academia and journalists have highlighted the connection between corruption and crimes that have an impact on the environment (see Section 4 and Annex 1). Adjudicated cases also provide information on this issue.\n\nThe analysis of this evidence shows that corruption linked to crimes that have an impact on the environment takes many forms. For example:\n\n- · bribery to obtain a CITES export permit for poached protected species or to be awarded a waste import permit;\n- · bribery to prevent inspection or control in a protected area, at border controls, etc.;\n- · bribery to be released from custody, to avoid prosecution and conviction or to receive minimal sanctions for crimes that have an impact on the environment.\n\nIn fact, corrupt practices facilitate all aspects of crimes that have an impact on the environment (Figure 2). They involve multiple actors from public officials to companies and organised crime.\n\nMeasuring the scale of corruption linked to crimes that have an impact on the environment is, however, challenging.8 This is due to the complexity and clandestine nature of corruption, along with the wide range of corrupt acts involved in enabling crimes that have an impact on the environment.\n\nIn 2016, Interpol estimated the global cost of corruption in the forestry sector to be around USD 29 billion (Interpol 2016). To the authors' knowledge, this is the only attempt at measuring corruption as it relates to crimes that have an impact on the environment.\n\nFigure 2: Intrinsic link between corruption and crimes that have an impact on the environment\n\n\u003C!-- image -->\n\n## Crimes that affect the environment\n\n\u003C!-- image -->\n\n## 1�3 Purpose and structure of the report\n\nIn 2021, UNODC published an overview of the efforts made by UNCAC States Parties to prevent and counter corruption related to crimes that have an impact on the environment at the national and international levels (UNODC 2021).\n\nTwo years later, in 2023, it appeared important to take stock and assess progress ahead of the 10th Conference of the States Parties to the UN Convention against Corruption which took place in Atlanta, Georgia, US, from 11-15 December 2023. Therefore, the Basel Institute on Governance provided a panorama of emerging initiatives across the world since the adoption of Resolution 8\u002F12.9 By showcasing the actions taken by UNCAC States Parties as well as civil society, academia and the media, the report aimed at encouraging States to expand their efforts and share their progress.\n\nThe present Working Paper builds on our 2023 report. It provides an overview of prevention and enforcement actions, initiatives and measures implemented by UNCAC States Parties in 2024 and 2025 to combat corruption as it pertains to crimes that have an impact on the environment.\n\nSpecifically, Section 2 focuses on prevention and Section 3 on enforcement actions. Section 4 underscores the valuable contributions made by non-state actors, in particular civil society organisations, academia and the media in this collective endeavour. Section 5 highlights main trends and marks a crucial\n\nchange from the 2023 report. Indeed, it makes the case that time has come for a paradigm shift moving from 'corruption as it relates to crimes that have an impact on the environment' to 'corruption that has an impact on the environment' . The Conclusion includes a list of promising initiatives for corruption prevention and enforcement.\n\n## Caveat\n\nThe report is based on publicly available information and relies on desk-based research as well as insights shared by experts interviewed between 16 October and 24 November 2023 as well as between 20 October and 28 November 2025. It does not aim to provide an exhaustive list of actions and measures taken by UNCAC States Parties, civil society organisations, the media and academia to prevent and combat corruption in relation to crimes that have an impact on the environment.\n\nFurthermore, the report does not assess whether these actions can be considered as 'good practices' . Given that many of these interventions are still in their early stages of implementation, it would be premature to draw final conclusions. Further research and monitoring are needed to assess the impacts of these measures in addressing corruption linked to crimes that have an impact on the environment.\n\nNonetheless, the report does present various ongoing and promising initiatives that can serve as inspiration and guidance for States and other stakeholders seeking to explore new strategies and adopt similar approaches to address this critical challenge.\n\n## 2 Prevention\n\nFigure 3: Operative paragraphs of Resolution 8\u002F12 relating to prevention\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nOP 6: Strengthen anti-corruption frameworks, promote ethical practices, integrity and transparency, and endeavour to prevent conflicts of interest\n\nOP 12: Establish confidential complaint systems, whistle-blower protection programmes, including protected reporting systems, and effective witness protection measures\n\nOP 7: Ensure integrity throughout the entire crime prevention and criminal justice system\n\nOP 15: Take measures to assess and mitigate corruption risks along the value chains\n\nOP 8: Promote the active participation of non-State actors in preventing corruption and raising awareness\n\nResolution 8\u002F12 includes five operative paragraphs focusing on prevention measures to reduce corrupt practices. This report provides examples of interventions and initiatives taken by States in three areas: promoting ethical practices (OP 6), establishing whistleblowing protection programmes (OP 12) and assessing and mitigating corruption risks (OP 15).\n\n## 2�1 Promoting ethical practices, integrity and transparency (OP 6)\n\nStrengthening integrity and ethical practices within governmental institutions and agencies tasked with preventing crimes that have an impact on the environment is essential for building strong institutions that can effectively tackle corruption linked to the environment. Over the last six years, States have taken various initiatives to promote a culture of integrity, in particular by involving leadership and toplevel management in the implementation of corruption prevention measures and by developing public officials' skills and adherence to shared ethical values, standards of conduct and principles.\n\nSince the publication of the report in 2023, Kenya Wildlife Service ,10 with support from UNODC, has continued working towards fostering a culture of integrity among its over 6,000 staff members. It has organised eight training sessions on integrityrelated issues such as the corruption prevention committees,11 the corruption risk assessment matrix, the integrity office, etc.\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nIn 2024, Kenya Wildlife Service adopted its 2024-2028 strategic plan in which accountability and integrity were defined as two of the organisation's core values. It also created a gift register, setting clear rules on thresholds and types of gifts allowed. Moreover, in July 2025, it updated its corruption risk assessment matrix to reflect the current corruption risks across various departments. The institution also plans to conduct a new corruption perception and experience survey in 2026 to measure progress and changes since 2019. 12  This upcoming survey will help Kenya Wildlife Service to assess the effectiveness of its corruption prevention initiatives.\n\nIn addition to Kenya Wildlife Service, other institutions have taken steps to promote ethical practices in Kenya. For example, in 2024, Kenya Fisheries Service , with support from UNODC, developed a corruption prevention policy that includes, among other aspects, a code of conduct and a whistleblowing policy. These documents aim to mitigate 30 corruption risks identified and prioritised as 'high risks' by Kenya Fisheries Service. They were approved in 2025 by the institution's senior management, its board of trustees, the Ethics and Anti-Corruption Commission and the Public Service Commission. Dissemination activities are planned in Nairobi and along the coastal region.\n\nAuthorities in Bolivia, Ecuador and Peru , with support from the Basel Institute on Governance, have promoted transparency and integrity in the forestry and mining sectors with the ultimate goal to induce behaviour change. In total, 6,172 public officials and civil servants from agencies in these three countries have participated in integrity workshops designed to encourage ethical reflection and strengthen public integrity in the exercise of their public functions.\n\nIn Malawi , a distinct approach to promoting ethical practices, integrity and transparency has been adopted (see Box 2).\n\n## Box 2: Malawi - promoting a holistic corruption prevention approach\n\nSince 2019, Malawi has adopted a holistic approach to preventing corruption. Each ministry, department and agency must allocate a minimum of 1 percent of its annual budget to tackle corruption . 13 For example, the Department of Forestry under the Ministry of Natural Resources and Climate Change has dedicated 1 percent of its total annual budget in 2024 to anti-corruption initiatives and has used 75 percent of the amount allocated.\n\n\u003C!-- image -->\n\nIn addition, each ministry, department and agency must establish an Institutional Integrity Committee (IIC) to promote integrity, transparency and accountability and to improve service delivery.\n\nThe Department of Forestry established its IIC in 2023. Since then, its members have participated in various training sessions on corruptionrelated issues with support from the Malawi Anti-Corruption Bureau and the Basel Institute on Governance. IIC members have subsequently conducted awareness sessions in six locations across the country, reaching 233 staff members. In collaboration with the Anti-Corruption Bureau, the IIC has also developed a corruption prevention policy, including a code of ethics and an awareness brochure, available in English and in Chichewa.\n\nThe Department of National Parks and Wildlife , too, has established an IIC in 2023 with support from the Anti-Corruption Bureau, the Basel Institute on Governance and UNODC. Its IIC members have taken part in training sessions, including on conducting initial corruption investigations and on public procurement.\n\nThe Department of National Parks and Wildlife has also consulted 500 staff members in the Central, Northern, Upper-Shire and Lower-Shire divisions to develop a corruption prevention policy which reflects the insights, experiences and day-to-day realities of the Department. 14\n\nFurthermore, the Department of National Parks and Wildlife adopted a code of ethics in 2023. To increase knowledge of the ethics code among staff and disseminate it across the different parks and border posts, the department used printed posters and a short video shared via WhatsApp.\n\nThe Anti-Corruption Bureau has played an instrumental role to create a culture of integrity within the Department of Forestry and the Department of National Parks and Wildlife.\n\n## 2�2 Establishing whistleblower protection programmes (OP 12)\n\nWhistleblowers have played a crucial role in exposing corruption and crimes that have an impact on the environment, but they often face retaliation for their actions. An appropriate legal framework and effective whistleblowing protection programmes are crucial not only to enable individuals to safely report wrongdoing, but also to deter unethical behaviours.\n\nWhile article 33 of UNCAC provides that appropriate measures shall be incorporated to grant protection to those who report corruption, many countries do not have dedicated legislation. When they do, the scope, the forms of protection and the effectiveness of the laws vary widely (Feinstein, Devine et al. 2021). It should be noted that these laws do not specifically focus on corruption or on crimes that have an impact on the environment.\n\nIn addition to adopting a dedicated legal framework, it is essential to establish effective whistleblowing protection programmes.\n\nIn Kenya, to encourage the reporting of corruption, Kenya Wildlife Service , with support from UNODC, developed an automated integrity management system. An integrity office was established in 2023 and has been operational since 2024. Composed of two staff members, the office is responsible for receiving, analysing, processing and monitoring corruption reports through a separate server as well as ensuring that appropriate actions are taken. Complaints can be submitted via a dedicated hotline, by email, via integrity boxes and online. Each complaint is assigned a unique number to ensure anonymity.\n\nBetween July 2024 and July 2025, the integrity office received 87 alerts, of which 57 have been closed and 30 are still under enquiry, a result that highlights the success of the whistleblowing programme. Based on employee feedback and the upcoming whistleblowing legislation, Kenya Wildlife Service is reviewing its whistleblowing policy to further strengthen, among other aspects, confidentiality and anonymous reporting.\n\nFor whistleblowing protection programmes to be effective, they must be widely known and easily accessible�\n\nIn South Africa, South African National Parks (SANParks), with support from UNODC, developed an awareness-raising campaign and communication strategy to promote the whistleblowing hotline available for reporting corruption and wrongdoings. Launched in November 2024, the campaign targeted both SANParks employees and external stakeholders and led to an increase in the number of alerts received (from 44 reports for the year 2023-2024 to 65 in 2024-2025).\n\nIn Bolivia , a similar approach was implemented with UNODC's support. In 2025, the Authority of Forests within the Ministry of Environment prepared and distributed awareness-raising materials (handouts, roll-ups and reporting boxes) with the objective of enhancing public engagement and increasing the number of reported cases of corruption.\n\n## 2�3 Assessing and mitigating corruption risks (OP 15)\n\nCorruption risk assessments enable institutions to understand the wide range of corruption vulnerabilities linked to crimes that have an impact on the environment, map the corruption risks and associated mitigation measures, assign responsibility for implementing mitigation measures and outline how progress will be monitored .\n\nSince 2019, various methods and approaches for assessing corruption risks have been developed both at sectoral (e.g. forestry, fisheries or mining) and institutional levels. For instance, UNODC designed methodologies for the fisheries sector 15 and for wildlife management authorities 16 . The Basel Institute on Governance designed the Map, Characterise, Assess and Recommend (MCAR) method for law enforcement and criminal justice processes. 17\n\nOver the last six years, multiple countries have conducted corruption risk assessments. UNODC is supporting six wildlife authorities, six forest authorities, two fisheries authorities and one environmental authority from eight countries to assess their corruption risks. 18\n\nFor example, in South Africa, the Department for Forest, Fisheries and Environment conducted a corruption risk assessment in October 2024. The Department, then, organised a strategic management anti-corruption workshop in May 2025 to embed integrity measures into routine operations and accountability systems. With UNODC's support, the Fisheries branch developed a series of standard operating procedures (SOPs) related to the monitoring, control and surveillance functions, integrating anti-corruption safeguards under each SOP. As a next step, the Fisheries branch will review the workplans of different job categories to align them with the new SOPs and ensure that anti-corruption measures are streamlined.\n\nThe Basel Institute on Governance has been working in partnership with ministries and agencies in six countries to design and implement corruption risk assessments (see also Box 3). 19 In some cases, these assessments refer to widely used international standards. One such example is the development of corruption risk management plans for the timber value chain - based on ISO 31000 on risk management and ISO 37001 on anti-bribery management systems - by the Forest and Land Inspection and Social Control Authority in Bolivia and the Ministry of Environment and Energy in Ecuador in 2024. 20\n\n- 17 See: https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-guide-to-conducting-corruption-risk-assessments-in-a-wildlife-lawenforcement-context\n- 18 Bolivia, Kenya, Malawi, Mozambique, Nigeria, Solomon Islands, South Africa and Uganda.\n- 19 Bolivia, Ecuador, Indonesia, Malawi, Peru and Ukraine.\n- 20 Corruption risk assessments were conducted in 2023.\n\nWhile assessing corruption risks is essential, implementing the measures identified in the action plans is even more important for effective corruption prevention . With support from the Basel Institute on Governance, the Forest and Land Inspection and Social Control Authority in Bolivia reached implementation levels of 82 percent and the Ministry of Environment and Energy in Ecuador 79 percent by the end of the first year of implementation. 21\n\nCorruption risk assessments are often carried out at the national level, but in some cases they are developed at the regional level to better reflect local contexts and territorial vulnerabilities. This approach has been adopted in Peru by the Regional Government of San Martín, through its Regional Environmental Authority, and by the Regional Government of Ucayali, through its Regional Forest and Wildlife Management Office, with support from the Basel Institute on Governance.\n\nThis process resulted in the approval of a corruption risk management plan for the issuance of forest transport guides in December 2024. The plan includes control measures, the institutions responsible for implementation and timelines. Implementation is ongoing, with measures currently focusing on satellite monitoring in San Martín and on the transfer of seized or abandoned forest products in Ucayali.\n\nBox 3: Ukraine - continued anticorruption efforts despite the war\n\nHistorically, the forestry sector in Ukraine has been one of the areas of the national economy most exposed to systemic integrity risks. In 2023, a report published by the Basel Institute on Governance identified institutional gaps that enable corruption schemes and illegal logging. 22\n\nFollowing the report's findings, the National Agency on Corruption Prevention, the Prosecutor General's Office of Ukraine, the Basel Institute on Governance and WWF-Ukraine conducted an in-depth analysis of corruption risks in the forestry sector and proposed mitigation measures. 23\n\nThe outlined reforms are demanding in any context. For a country at war and given the difficult conditions under which authorities must operate, these reforms are particularly challenging. However, safeguarding its forestry sector through strengthened governance is a crucial priority for post-war economic reconstruction.\n\nLaw enforcement is pursuing numerous irregularities in Ukraine's forest management. To prevent such irregularities from occurring in the first place, corporate governance must be strengthened and stronger internal control measures must be built. These are ongoing priorities that need to be augmented with greater transparency measures to enable independent oversight of the industry.\n\n## Box 4: Fostering peer-to-peer learning exchanges on corruption prevention\n\nIn 2024, Bolivia, Ecuador and Peru met to review progress in implementing their corruption risk management plans and to exchange lessons learned. Field visits allowed participants to observe practical control tools. An example is the low-cost digital microscope used in San Martín to verify timber species, illustrating that corruption prevention can be effective even without substantial financial resources. The meeting also strengthened regional cooperation among institutions, helping to build a collaborative network dedicated to promoting more transparent and sustainable forest management practices.\n\nIn addition, the Basel Institute on Governance organised a workshop in 2024 on corruption risk management in the timber value chain, attended by representatives from forest authorities of Bolivia, Ecuador and Peru, as well as regional governments and Indigenous leaders. A second edition is taking place at the time of writing this report.\n\nFurthermore, the Forest and Land Inspection and Social Control Authority in Bolivia and the Basel Institute on Governance held an event on 'Satellite Monitoring for Crime Prevention and Forest Protection in Bolivia' in March 2025. This event brought together expert agencies from Bolivia, Ecuador and Peru to share knowledge and reflect on ways to strengthen satellite monitoring for the prevention of environmental crimes and acts of corruption in Bolivia's forests. As a result, participants recommended developing technical solutions, algorithms and institutionalised procedures to process, validate and use satellite information as evidentiary input in administrative and criminal proceedings.\n\nPeer-to-peer learning exchanges have also been organised in other regions. For instance, the Nigeria Park Service (in 2024) and the Ministry of Water and Environment of Uganda (in 2025) undertook a 'study tour' to meet with Kenya Wildlife Service and Kenya Fisheries Service, in collaboration with the Kenyan Ethics and Anti-Corruption Commission and UNODC.\n\nThe visits aimed to enhance knowledge and awareness of good practices related to corruption risk assessments in Kenya, learn how to establish corruption prevention or management committees at a sectoral level, share practical experiences, build lasting relationships with other countries and strengthen regional collaboration.\n\n## 3 Enforcement\n\nFigure 4: Operative paragraphs of Resolution 8\u002F12 relating to enforcement\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nOP 3 and 4: Recovery and return of proceeds of crimes in accordance with UNCAC and of crimes that have an impact on the environment\n\nOP 4 and 11: Investigate and prosecute corruption as it relates to crimes that have an impact on the environment, including by using financial investigation techniques\n\nOP 9: Take measures to ensure that legal and natural persons are held accountable for corruption offences\n\nResolution 8\u002F12 puts a strong emphasis on enforcement actions. In particular, UNCAC States Parties are urged to take actions to investigate, prosecute, hold accountable legal and natural persons for corruption offences, strengthen cooperation, and recover and return proceeds of crimes. Accessing information on case laws is difficult (Box 5). Nevertheless, the report highlights interesting and promising enforcement approaches.\n\n## Box 5: Absence of publicly available statistics does not imply an absence of cases\n\nThe lack of publicly available statistics on investigations and convictions, coupled with the absence of systematic and specific data collection by countries on cases of corruption linked to crimes that have an impact on the environment, poses a challenge in assessing progress and determining the number of ongoing or adjudicated cases since 2019. 24 However, the absence of publicly available statistics should not be seen as an indication that corruption cases related to crimes that have an impact on the environment are non-existent.\n\n\u003C!-- image -->\n\nOP 5: Make use of legal instruments available to tackle corruption as it relates to crimes that have an impact on the environment, including through legislation related to money-laundering, corruption, fraud, racketeering and financial crime\n\nOP 10: Strengthen cooperation in criminal matters\n\nMoreover, while law enforcement authorities around the world have taken enforcement actions against crimes that have an impact on the environment, the degree of focus on potential corrupt practices in these cases varies. In other words, the absence of corruption in reported cases of crimes that have an impact on the environment does not necessarily mean that there was no corruption . Rather, it suggests that corruption might not be explicitly addressed in the reported cases. The actual number of corruption incidents linked to crimes that have an impact on the environment could, in fact, be much higher.\n\nAdditionally, States rarely disclose information about ongoing investigations due to confidentiality reasons. Hence, there is likely a more extensive number of cases involving corruption linked to crimes that have an impact on the environment than what is indicated in this report.\n\n## 3�1 Prosecuting corruption cases and holding legal and natural persons accountable (OP 4, 9, 11)\n\nSince 2019, law enforcement authorities have investigated and prosecuted individuals and companies for corruption offences linked to crimes that have an impact on the environment. There is anecdotal evidence in countries such as Cameroon, Kenya, Indonesia, Malawi, Namibia and The Gambia (see Box 6 on Namibia).\n\nWhen convicted, individuals and companies face imprisonment, fines and confiscation of assets (see Section 3.3 below). We are also starting to see specific financial penalties included in the sentencing to compensate for the environmental harm done and conduct restoration actions (see Annex 2 on Indonesia and Section 4.4 on strategic litigation by civil society). However, the number of investigations and prosecutions remains low compared to the number of suspected corruption incidents reported by media and civil society organisations.\n\n## Box 6: Namibia - bringing high-level public officials to justice\n\nIn December 2019, media outlet Al Jazeera exposed extensive corrupt practices in Namibia's fishing industry following the publication of over 30,000 documents by WikiLeaks from whistleblower Johánnes Stefánsson (Al Jazeera 2019). This scandal became known as the Fishrot case or Fishrot scandal.\n\n\u003C!-- image -->\n\nThis is the first transnational corruption case in the fisheries sector. 25 It involves public officials in Namibia (including the former Attorney General, who at the time of his arrest was the Minister of Justice, and the former Minister of Fisheries and Marine Resources), a fishing company headquartered in Iceland, a bank located in Norway and a total of 27 jurisdictions involved at various levels.\n\nThe investigation, prosecution and trials are taking place in Namibia, where the corruption offence took place. The suspects are indicted for racketeering, bribery, money laundering and tax evasion. International cooperation through mutual legal assistance contributed to the successful conclusion of the investigation. Law enforcement authorities did not face political interference despite the fact that high-level public officials were charged with corruption. Witnesses are also determined to testify notwithstanding the high visibility and stakes of the case. Paulus K. Noa, Director-General of the Namibian Anti-Corruption Commission, refers to the case as 'a true testimony of the Government of Namibia's commitment to fighting corruption and organised crimes' .\n\nWhile the trial was expected to open in 2024, the case has since been postponed and delayed due to the defendants' various applications. Though the final outcome is uncertain, the case is an illustration of a successful enforcement action in a grand corruption case.\n\n## 3�2 Using anti-money laundering legislation and financial investigation techniques (OP 11)\n\nFinancial investigations - also known as 'follow-the-money' methods - are instrumental to get an understanding of the locations, the networks of actors and assets involved, the movement of funds and how the criminal activities are financed (Reid, Parry-Jones and Keatinge 2020). They are necessary not only to combat crimes that have an impact on the environment, but also for exposing corrupt allies and gathering evidence to initiate corruption cases linked to these crimes. 26\n\nIt is also important that national legal frameworks recognise crimes that have an impact on the environment as a predicate offence in order to mobilise antimoney laundering legislation to tackle these crimes.\n\nSeveral countries, including Canada, Colombia, China, Kenya, Hong Kong, Indonesia, Malawi, Mozambique, South Africa, 27  Thailand and the US, have applied an anti-money laundering approach to wildlife trafficking (Hsu 2025). For instance, in at least eleven cases since 2019, the US indicted individuals for money laundering in connection with wildlife crimes.\n\nOne such example is Bhagavan Doc Antle who pleaded guilty in November 2023 to money laundering and to a conspiracy to violate the Lacey Act (U.S. Department of Justice 2023). He was sentenced to 12 months in prison, fined USD 55,000 and ordered to forfeit three chimpanzees and more than USD 197,000 to the US government (U.S. Department of Justice 2025). Bhagavan Doc Antle used bulk cash payments to hide the transactions and requested that payments for endangered species be made to his non-profit so they could appear as 'donations' (U.S. Department of the Treasury 2024).\n\nIn Mozambique , Chabane Assuba, a broker, was sentenced in 2024 to 30 years in prison and fines equivalent to two years for illegal possession and storage of wildlife products, criminal association and money laundering (English.news.cn 2024). More than 600 kg of products of prohibited species (such as lion bones, elephant bones and ivory tusks) were found at his residence.\n\nAnti-money laundering legislation and 'follow-the-money' methods can be applied to all crimes that have an impact on the environment and not only to wildlife crimes. Some countries have taken this approach (Box 7). In Brazil , federal authorities launched an investigation into the laundering of more than USD 16.4 million of\n\nillegally mined gold (Pope 2023). A shell company supposedly trading hospital supplies is alleged to have laundered over USD 12.3 million in gold.\n\nIn 2024, the Spanish Guardia Civil launched Operation Dashboard, with support from the European Anti-Fraud Office, against individuals who were introducing hazardous waste into the EU. They are under investigation for alleged crimes against natural resources and the environment, falsification of certificates, money laundering, tax fraud and membership in a criminal group (OLAF 2024).\n\nSince the adoption of Resolution 8\u002F12, there are nevertheless very limited examples of financial investigations targeting corruption linked to crimes that have an impact on the environment (see Annex 2 on Indonesia). 28\n\n\u003C!-- image -->\n\nBox 7: Indonesia - Environmental Ministry achieves first conviction for money laundering linked to illegal logging 29\n\nIn 2022, an Indonesian Court\n\nsentenced a businessman named Supono for illegal logging and then, in 2024, for money laundering. In both cases, he was sentenced to prison and ordered to pay a fine. Financial investigations revealed that the defendant earned approximately USD 127,000 from illegally sourced timber from Alas Purwo National Park and several other regions across Indonesia.\n\nSupono illegally traded rosewood with two sawmill companies. To conceal the illicit origin of the proceeds, the payments were channelled through his son's bank account. Supono then transferred the funds back to his own bank account in smaller transactions, integrating them with money he had loaned from the bank and using the illicit funds to pay back the loan.\n\nThis is a landmark conviction. It is notable because the investigations were led by investigators from Indonesia's Ministry of Environment and Forestry. Until a Constitutional Court's ruling in 2021, only a limited number of law enforcement authorities could use the provisions set in the 2010 Anti-Money Laundering Law No. 8\u002F2010. The court's 2021 decision extended the power to pursue money laundering offences\n\nlinked to crimes that have an impact on the environment to investigators from natural resources and environmental authorities. This is the first money laundering conviction achieved by the Ministry of Environment's investigators.\n\nWhile the amount of money laundered in this case and the imposed fines (approximately USD 29,900 for illegal logging and USD 3,000 for moneylaundering) were relatively modest, the case has opened the door to tackling more complex, high-value cases in the future.\n\n## 3�3 Seizing and confiscating assets (OP 3 and 4)\n\nRecovering assets (such as vehicles, houses or bank accounts) in a corruption or money laundering case linked to crimes that have an impact on the environment is crucial. Asset recovery is a powerful deterrent. It can mean seizing assets that were bought with illicit profits as well as seizing the instrumentalities of the crimes (the trucks, the boats or machinery used in illegal activities), and therefore directly disrupts operations of the networks of actors engaged in corruption and crimes that have an impact on the environment.\n\nOne example can be found in Mozambique . In 2024, two rhino horn traffickers Simon Valoi and Paulo Zucula - were convicted for illegal wildlife trade, criminal association and money laundering (Wildlife Justice Commission 2024). Simon Valoi was sentenced to 27 years in prison, the confiscation of assets worth approximately USD 140,625, and a USD 170,000 fine in compensation to the State. Paulo Zucula received a 24-year prison sentence, a USD 62,500 fine in compensation to the State and USD 265,625 of his assets were confiscated.\n\nIn October 2025, the Economic and Financial Crimes Division of the High Court of Zambia , a civil jurisdiction, ordered the confiscation of assets valued at more than USD 1 million to the benefit of the State (WCP News). These assets are tied to an illegal logging operation, including offices, trucks and trailers, over 1,900 logs, fork lifter and industrial machinery. 30  The National Prosecution Authority used nonconviction based forfeiture law.\n\nIn its judgement, the High Court of Zambia sent a clear message that owners must ensure their assets 'will not be used as instrumentalities in the commission or furtherance of economic and financial crimes' . It also added that 'Courts have a duty not to embolden people to engage in or perpetrate illegal logging but to protect the country's Natural Resources for future generations' .\n\nOnce confiscated, assets could be used to compensate, restore and\u002For repair the harm done . However, tracing, seizing and definitive confiscation of illicit assets related to corruption and crimes that have an impact on the environment are not yet systematic.\n\n## 3�4 Strengthening cooperation (OP 10)\n\nEnforcement actions to address corruption as it relates to crimes that have an impact on the environment require significant time and resources (for timely detection and adequate investigation), specialised knowledge and the involvement of multiple agencies or authorities. 31  Although the assistance and dedicated expertise of the respective agencies is generally needed, cooperation between the anti-corruption agency, the financial intelligence unit, prosecutors, police, customs and the agency in charge of the environment is often ad hoc at best.\n\nYet, multi-agency cooperation is a crucial step to tackle corruption linked to crimes that have an impact on the environment and dismantle criminal networks. Over the last six years, countries have worked to develop and improve inter-agency coordination at the country level and international level.\n\n## National multi-agency and interdisciplinary collaboration\n\nStates are more and more establishing multi-agency and interdisciplinary task forces within their own countries to tackle corruption linked to crimes that have an impact on the environment (Box 8).\n\nFor instance, in Kenya , under the leadership of the Ethics and Anti-Corruption Commission, an inter-agency arrangement was established comprised of Kenya Wildlife Service, the Assets Recovery Agency, the Directorate of Criminal Investigations and the Kenya Revenue Authority. The institutions meet regularly and have set specific targets to be achieved for the fiscal year July 2025 - July 2026.\n\nProactive law enforcement cooperation combined with partnerships with civil society organisations and\u002For the private sector is also essential for greater impact.\n\nFor example, the Nigeria Customs Service and Wildlife Justice Commission have been collaborating since 2021 to dismantle criminal networks involved in the trafficking of ivory and pangolin scales. This collaboration has produced tangible results: 42 suspected wildlife traffickers were arrested with 12 convictions secured, 13 major criminal networks have been disrupted, and over 25 tonnes of pangolin scales and more than one tonne of ivory have been seized (Wildlife Justice Commission 2025b). Moreover, there have been no significant pangolin scale seizures at seaports or airports for more than three years (Wildlife Justice Commission 2025a). This suggests that criminal networks have been severely disrupted.\n\nWhile this successful partnership does not focus on corruption linked to crimes that have an impact on the environment, it underscores the importance of cooperation, including with civil society organisations, to effectively halt criminal activities.\n\nBox 8: Madagascar - national and international interagency cooperation was key to dismantling a wildlife trafficking network 32\n\nIn May 2024, Thai customs authorities seized more than 1,000 radiated tortoises and 48 live lemurs from Madagascar (protected under CITES) at Suvarnabhumi International Airport in Bangkok, with support from Interpol, the Wildlife Justice Commission, the U.S. Fish and Wildlife Service and UNODC.\n\n\u003C!-- image -->\n\nWhile the case in Thailand is still ongoing, a positive outcome has already been achieved in Madagascar. Following the criminal complaint filed by the Malagasy Ministry of Environment and Sustainable Development in Madagascar, the investigation led to the identification of Malagasy, Thai and Burmese suspects. In addition to pursuing the trafficking offences, the Malagasy authorities adopted a 'follow-the-money' approach, bringing together relevant national authorities with support from the Basel Institute on Governance.\n\nOn 8 May 2025, for the first time in Madagascar, the specialised anticorruption court convicted 12 individuals for smuggling protected species, money laundering and criminal conspiracy. The defendants received prison sentences of up to ten years. They were ordered to pay a customs fine of over EUR 5 million and EUR 2.5 million in damages to the Ministry of Environment and Sustainable Development. Bank accounts, vehicles and motorcycles were also confiscated.\n\nThe Thai and Burmese nationals involved were tried in absentia (while on bail pending their related trial in Thailand), and international arrest warrants were issued. Moreover, the species seized in Thailand were safely returned to Madagascar thanks to successful international cooperation.\n\nThis case demonstrates the key role of inter-agency cooperation at the national and international levels as well as the effectiveness of applying money laundering and related criminal provisions to address crimes that have an impact on the environment. This approach is expected to be duplicated in ongoing and future cases in Madagascar.\n\n## Regional and international cooperation\n\nCross-border collaboration among law enforcement authorities is instrumental, as seen in the Fishrot case (Box 6). International cooperation takes many forms, from formal mutual legal assistance requests to information sharing between financial intelligence units through the Egmont Group  public-private , partnerships (Box 9) and informal exchanges facilitated by dedicated networks.\n\nCoordination and support from organisations like UNODC, Interpol, Europol and the World Customs Organization (WCO) are essential.\n\nThe publication of notices such as Interpol's red, silver or purple Notices helps States to find criminals and to better understand the modus operandi and methods used by criminals.\n\nProject TENTACLE, an initiative led by WCO since 2018 and funded by the U.S. Bureau of International Narcotics and Law Enforcement Affairs, places emphasis on collaboration between customs services and both financial intelligence units and police services to dismantle criminal networks.\n\nThe Informal Law Enforcement Network - an initiative launched by UNODC, WCO, OECD and Interpol in 2020 - provides a forum for government representatives, civil society organisations and the private sector to meet twice a year to discuss and facilitate the exchange of information on gold trafficking.\n\nSince the publication of the Seedlings of hope report in 2023, several joint crossborder law enforcement operations were conducted to combat crimes that have an impact on the environment. Operation Thunder 33  and Operation Panthera Onca 34 are examples from 2024.\n\nIn 2025, Operation Green Shield, 35  led by the United Arab Emirates, Brazil, Colombia, Ecuador and Peru, targeted activities linked to illegal mining, wildlife trafficking, illegal logging, fuel smuggling and illegal waste across the Amazon. The operation was part of the International Law Enforcement Initiative for Climate Change launched in February 2023. 36\n\nA new initiative, GUARD Wildlife (Global United Action to Reduce and Dismantle Wildlife Crime), was launched in February 2025 to enhance cooperation at the national, regional and international levels in order to tackle organised criminal networks involved in wildlife trafficking. It will be implemented by the International Consortium on Combating Wildlife Crime with funding from the European Union.\n\n- 36 See: https:\u002F\u002Fmoi.gov.ae\u002Fen\u002Fabout.moi\u002FInitiative\u002F040725m01.aspx#:~:text=The%20international%20law%20enforcement%20 initiative,resulted%20in%20the%20launch%20of\n\nDespite these many initiatives, multi-agency and interdisciplinary collaborations at the national, regional and international levels on corruption linked to crimes that have an impact on the environment remain limited.\n\n\u003C!-- image -->\n\nThrough the partnership, an 'operational alert' was issued to support financial institutions in recognising suspicious financial transactions. 37  In a span of two years, FINTRAC received over 150 suspicious transaction reports (STRs) with a total value equivalent to CAD 200 million - a significant rise compared to less than 200 STRs received in the ten years prior to Project Anton.\n\nThe initiative also enabled FINTRAC to increase the amount of intelligence it is sharing with domestic and international authorities (Countering Environmental Corruption Practitioners Forum 2025).\n\n## 3�5 Making use of legal instruments available (OP 5)\n\nResolution 8\u002F12 encourages States to make use of legal instruments available to tackle corruption as it relates to crimes that have an impact on the environment, 'including through legislation related to money-laundering, corruption, fraud, racketeering and financial crime' .\n\nIn the previous sections, we have seen that law enforcement authorities have been using anti-money laundering legislation to tackle this issue. Complementary approaches are possible:\n\n- · Imposing sanctions and visa bans on individuals and companies involved in corruption linked to crimes that have an impact on the environment.\n- · Using non-conviction based confiscation , i.e. the possibility to confiscate assets derived from criminal activity without the need for a criminal conviction (Spicer and Grossmann 2022).\n- · Applying social re-use of seized and confiscated assets for the benefit of citizens and the planet. The assets could be allocated to law enforcement involved in cases of corruption and crimes that have an impact on the environment or to anti-corruption and conservation civil society organisations, or used to restore nature (UNICRI 2025).\n- · Mobilising illicit enrichment or unexplained wealth laws (Dornbierer 2021).\n- · Using innovative legal instruments such as the presumption of money laundering , a mechanism adopted in France in 2023 to combat the laundering of the proceeds of crime (Brimbeuf and Bornstein 2023).\n- · Making the most of beneficial ownership and other available registers (asset declaration databases, land register, company register, procurement monitoring systems, etc.) to conduct criminal investigations.\n\nOther avenues to explore include tax-related laws, corporate due diligence legislation, misconduct and misstatements in relation to environmental, social and governance (ESG) considerations, and remedies via civil proceedings.\n\n## 4 Civil society and the media as key actors\n\nIn its preamble, Resolution 8\u002F12 highlights 'the important role of the media, civil society, academia and private sector entities in the prevention of and the fight against corruption as it pertains to crimes that have an impact on the environment' .\n\nOver the past six years, the media and civil society have played an essential role, despite facing many challenges. The space for civil society is shrinking worldwide. 72.4 percent of the global population now live in countries classified as closed or repressed (CIVICUS Monitor 2024). Press freedom is also declining in many regions. For the first time in the history of the World Press Freedom Index, Reporters Without Borders classified the global state of press freedom as a 'difficult situation' . 38\n\nThe following section looks at four areas where the media and civil society have been a driving force.\n\n## 4�1 Raising awareness through investigative journalism\n\nJournalists and media organisations have played a crucial role in exposing the links between corruption and crimes that have an impact on the environment . Major international media outlets such as Mongabay Cenozo  InSight Crime , , , The Gecko Project , the International Consortium of Investigative Journalists , and Organized Crime and Corruption Reporting Project have documented how corruption enables environmental crimes across the globe. For example, through Journalismfund Europe cross-border investigations have documented cases of waste trafficking, illegal logging, eels trafficking and exotic birds trafficking, exposing Europe's role. 39\n\nNational media have also contributed to raising awareness with support from organisations like the Thomson Reuters Foundation and the Internews' Earth Journalism Network (Box 10). In 2024, The Africa Report , together with the Pulitzer Center Rainforest Investigations Network, published a four-part series on timber trafficking in the Democratic Republic of the Congo (DRC) and how it is smuggled to Uganda and Kenya (Musinguzi 2024). The Bridge Magazine reported on corruption and wildlife trafficking along the DRC-Rwanda border (Umuhoza 2024). The Citizen documented how tax inconsistencies incentivise gold smuggling in Tanzania (Bahemu 2024) and Musoma News Hub explained how the country loses\n\ntax revenues from the illegal exploitation and trade of tin which is facilitated by corruption (Sebastian 2025). The Forefront Magazine investigated illegal mining and trafficking in minerals in Rwanda (Ntawurikura 2025) while Amazon Underworld looked at corruption and conflicts of interest in the exploitation of gold in Peru (Huerta 2025).\n\nWhile journalists and media organisations have shed essential light on the nexus between corruption and crimes that have an impact on the environment, they are particularly at risk . They face a wide range of threats, including arrest, imprisonment, surveillance, physical and digital aggressions and legal attacks such as administrative harassment or abusive lawsuits (International Press Institute 2024).\n\nBetween 2009 and 2023, at least 749 journalists, groups of journalists and news media outlets were targeted (UNESCO 2024). During the same period, 44 environmental journalists were killed in 15 different countries, with convictions secured in only five cases (UNESCO 2024). And more than 30 journalists covering issues such as waste, illegal mining, water pollution, deforestation, illegal sand extraction and renewable energy were obstructed, threatened or killed in 2024-2025 (RSF 2025).\n\nWhen journalists are killed or threatened, media organisations join forces to continue their work. In 2023, for example, 50 journalists from 16 news organisations, coordinated by Forbidden Stories, pursued the investigations on illegal fishing started by Dom Phillips and Bruno Pereira who were murdered in 2022 in the Amazon. In February 2025, Forbidden Stories investigated the murder of Cambodian journalist Chhoeung Chheng who had been documenting illegal deforestation. In Ghana, journalists reporting on illegal gold mining face abduction, beating and death threats. In response, The Fourth Estate , The Reporters' Collective and Forbidden Stories partnered to investigate the impacts of the illegal gold industry as well as the role of money and gold laundering (Abdelilah 2025).\n\nDespite the many challenges they face, journalists have kept investigating . Without their dedication and courage, our understanding of how corruption and crimes that impact the environment intersect would be far more limited.\n\nBox 10: Enhancing journalists' expertise on 'follow-the-money'\n\nReporting on corruption or money laundering linked to crimes that have an impact on the environment requires specialised skills and expertise . To strengthen media coverage of these issues and thereby raise public awareness, several organisations provide targeted training.\n\nThe East Africa Wildlife Journalism Project of Internews' Earth Journalism Network and the Thomson Reuters Foundation's Curbing Illicit Financial Flows programme organise training and workshops that build and develop expertise and knowledge of journalists to investigate corruption and trace illicit financial flows related to environmental crimes.\n\nThe Centre for Investigative Journalism (CIJ) and Finance Uncovered provide in-person and online courses on financial investigations and follow the money. CIJ has also offered in 2025 a training programme called 'Dark Green' , designed to equip European journalists with the tools and methods needed to more effectively 'follow the money' in environmental and climate related investigations.\n\nThese organisations also award grants that enable journalists to pursue their work.\n\n## 4�2 Strengthening knowledge with practitioneroriented research and learning\n\nCivil society has played a fundamental role in closing the knowledge gap in relation to crimes that have an impact on the environment.\n\nBetween 2023 and 2025, the Wildlife Justice Commission, Environmental Investigation Agency, the Igarapé Institute, the FACT Coalition, the Global Initiative against Transnational Organized Crime and Earth League International, among others, have provided evidence on wildlife trafficking, illegal logging, shark fin trafficking or gold trafficking. Launched in 2023 by the Global Initiative against Transnational Organized Crime, the ECO-SOLVE project monitors and analyses data on online wildlife trafficking.\n\nOne major change compared to 2023 is the increased number of research into illegal gold mining.\n\nWhile it is essential to strengthen knowledge on crimes that have an impact on the environment, the role of corruption is often overlooked . Limited research has focused on corruption related to crimes that have an impact on the environment.\n\nFor example, publications by the Igarapé Institute and the FACT Coalition analysed illicit financial flows (in particular money laundering) from environmental crimes, and the Basel Institute on Governance provided evidence on corruption in waste management and trade as well as on corruption in the forestry sector in Ukraine. A forthcoming report by Earth League International provides an in-depth analysis of corruption incidents linked to illegal logging, wildlife trafficking, illegal mining, land grabbing as well as illegal, unreported and unregulated fishing (Byrd et al., forthcoming). It also examines how corruption enables criminal networks to expand their activities through crime convergence.\n\nCivil society organisations have also designed self-paced e-learning courses available in different languages that are free and open to everyone with the objective of sharing knowledge and increasing awareness on the relationship between corruption and crimes that have an impact on the environment.\n\nFor example, U4 Anti-Corruption Resource Centre proposes self-paced courses on corruption linked to the forestry sector and wildlife trafficking, while ACAMS offers a self-paced course on illicit financial flows associated with illegal wildlife trade. Through Basel LEARN, the Basel Institute on Governance proposes a self-paced course on Open-source Intelligence with a case study about illegal fishing.\n\n## 4�3 Building bridges between anti-corruption and environmental practitioners\n\nSince 2019, various networks, coalitions and fora have emerged that bring together practitioners from the anti-corruption and environmental fields.\n\nThe UNCAC Coalition's Environmental Crime and Corruption working group , 40 established in 2021, offers a space for civil society organisations to coordinate and develop joint advocacy efforts, provide updates on policy developments and share knowledge and findings on corruption linked to environmental matters. More than 230 individuals are members of the working group, coming from civil society organisations working at the national, regional and international levels and specialised in a wide range of topics from wildlife trafficking and climate related issues to extractive industries.\n\nOne key advocacy output is a 2024 discussion paper to facilitate discussions on interlinkages between corruption, environmental crime and climate degradation (UNCAC Coalition 2024). A forthcoming publication aims to provide an overview of knowledge gaps and best practices to address corruption linked to crimes that have an impact on the environment.\n\nLaunched in December 2022, the Countering Environmental Corruption Practitioners Forum 41 brings together anti-corruption and conservation practitioners to discuss, exchange and foster peer-to-peer learning on issues related to corruption that impacts the environment.\n\nOver 800 members from the anti-corruption, conservation and governance communities around the globe have joined the Forum. They include practitioners from government institutions (such as anti-corruption agencies, financial intelligence units and environmental agencies), United Nations agencies, academia, civil society organisations, journalists and the private sector.\n\nPlenary sessions are held twice a year, covering a wide range of cross-cutting topics such as the nexus between human rights and environmental corruption. Five working groups have also been established to address key issues: land corruption; follow-the-money and financial investigations; climate finance; open data; and minerals corruption (the latter was launched in December 2025). Members meet regularly to exchange knowledge and strengthen collaboration. Events are recorded and made publicly available on the Forum's website, which also includes blog posts by members.\n\nThe Nature Crime Alliance , 42 launched in 2023 and hosted by the World Resources Institute, has set up a knowledge database compiling relevant research on nature crimes, a wildlife expert directory as well as an index of tools gathering publicly available data on technologies. Even though the Nature Crime Alliance does not focus its work on the nexus between corruption and the environment, the resources it provides are useful.\n\n## Box 11: Actions taken by the private sector\n\nThe private sector takes part in several global initiatives . For example, with United for Wildlife, financial institutions and the transport industries (airline and shipping companies, logistics firms, freight organisation) are committed to addressing the issue of wildlife trafficking. The private sector is also involved in initiatives such as the Global Platform for Sustainable Natural Rubber, the Forest Stewardship Council, the Extractive Industries Transparency Initiatives, the Fisheries Transparency Initiatives, the Maritime Anti-Corruption Network and the Urban Cleaning, Solid Waste and Effluents Anti-Corruption Collective Action.\n\nIn 2024, WWF and Themis, with support from the Climate Solutions Partnership (a collaboration between HSBC, World Resources Institute and WWF), launched a toolkit to equip financial institutions with knowledge on environmental crime, focusing on deforestation and land conversion, illegal mining and the illegal wildlife trade. 43\n\nPrivate sector awareness of the role, importance and impact of corruption and money laundering associated with crimes that have an impact on the environment remains nevertheless limited. Additional efforts are needed so that the private sector does not facilitate corruption and money laundering linked to the environment.\n\n## 4�4 Initiating litigation for lasting change\n\nCivil society organisations around the world have used strategic litigation to defend human rights, tackle corruption, raise awareness on a specific issue or open new legal avenues (Lemaître 2023a).\n\nFor example, Sherpa, the Center for Climate Crime Analysis, Repórter Brasil and Transparency International filed a complaint in November 2023 with the French Financial Prosecutor's Office against four French banks (BNP Paribas, Crédit Agricole, BPCE and Axa) for money laundering and concealment. The case revolves around their alleged financial support for Brazil's leading beef companies, which are suspected of contributing to illegal deforestation in the Amazon (Sherpa 2023). An investigation was opened by the Financial Prosecutor's Office.\n\nIn Italy, NGOs have made use of environmental liability provisions to secure compensation for harm caused to the environment . For example, Associazione per la Biodiversità e la sua Conservazione, supported by Conservation-Litigation. org, joined the criminal prosecution of two cactus smugglers as a civil party. In January 2025, the court convicted the smugglers and awarded EUR 20,000 in remedies to Associazione per la Biodiversità e la sua Conservazione (ConservationLitigation.org 2025). 44  The awarded funds will be invested into cacti conservation.\n\nIn Jamaica, Freedom Imagineries uses human rights laws to address corruption and crimes that have an impact on the environment . Together with 10 individuals from communities in St. Ann, it launched a case against the government for granting a bauxite mining licence located in the Cockpit Country, a protected ecological area. Freedom Imagineries argues that the mining operations have led to health issues, dust and air pollution for the communities living near the mine. It is also alleged that the award process was not followed; mining activities started before the approval was granted. The case is ongoing.\n\nIn parallel, Freedom Imagineries submitted an application in June 2022 to the InterAmerican Commission on Human Rights asking that the Jamaican government be required to adopt the necessary measures to protect the rights to health, personal integrity and life of the communities. The Commission issued precautionary measures in November 2022, requesting the country to protect the rights to life, personal integrity and health of the communities affected by the mine. 45  For defending their rights, Freedom Imagineries and affected communities have been facing threats and reprisals (Box 12).\n\nBox 12: Anti-corruption and environmental defenders under attack (Lawlor 2025,\n\nHuman rights defenders working on corruption and\u002For the environment are targeted by state and non-state actors Forst 2025). Their repression is on the rise.\n\nSince 2012, 2,253 land and environmental defenders have been killed worldwide (Global Witness 2025a). 46  In 2024 alone, 144 were murdered for defending the planet, with Latin America accounting for the vast majority of these killings (Global Witness 2025a). The most frequently reported violations include arrest and arbitrary detention, legal action, threats, surveillance and death threats (Front Line Defenders 2025). Moreover, 92 percent of defenders surveyed by Global Witness responded that they have experienced some form of online abuse or harassment as a result of their work (Global Witness 2025b).\n\nBeyond physical, verbal and online attacks, anti-corruption and environmental defenders also have to face the misuse of the legal and judicial system . They are investigated and prosecuted under national security, disinformation and anti-terrorism laws, anti-money laundering legislation and defamation provisions, among others. This practice, known as lawfare , is found on every continent  (Lemaître 2025).\n\n## 5 A paradigm shift for corruption and the environment\n\nResolution 8\u002F12 and subsequent UN Resolutions have set a precedent to address\n\ncorruption as it relates to crimes that have an impact on the environment. Nevertheless, a paradigm shift is necessary because corruption can harm the environment without being linked to a crime that has an impact on the environment .\n\nFor example, a bribe to obtain a land conversion permit for agricultural purposes may result in deforestation and biodiversity loss while no crime is committed. Similarly, embezzlement 47  of funds allocated for climate adaptation or mitigation projects such as afforestation or carbon capture impedes efforts to address climate change, without an environmental crime being committed.\n\nTherefore, focusing solely on corruption linked to crimes that have an impact on the environment overlooks situations where corruption causes environmental harm without an associated criminal offence.\n\nAs our collective understanding of the connection between corruption and the environment expands, so should our definition to encompass corruption linked to activities damaging the environment. A holistic approach, moving from the concept of 'corruption as it relates to crimes that have an impact on the environment' to 'corruption that has an impact on the environment' is crucial for protecting the environment and people.\n\nThis section explores two interconnected issues which have a devastating impact on the environment: corruption linked to climate finance and renewable energy as well as corruption tied to the exploitation of critical minerals (see also Box 14).\n\n## 5�1 Corruption linked to climate finance and renewable energy\n\nWhen Resolution 8\u002F12 was adopted in 2019, the connection between corruption and climate finance and renewable energy was not yet at the forefront of international debates and negotiations.\n\nOver the past six years, however, research conducted by civil society organisations and academia has highlighted how corruption hampers efforts to adapt to and mitigate climate change, jeopardises the energy transition, weakens countries' resilience to climate disasters and leads to the misuse of climate funds (e.g.\n\nNest et al. 2020; Transparency International 2022; Chan et al. 2023; Nest and Mullard 2025).\n\nIn its Climate and Corruption Case Atlas 48 , Transparency International has identified 89 cases around the globe, and its 2024 report provides an analysis of these cases (Nest 2024). Moreover, international organisations such as UNODC and the World Bank have recognised and documented the links between corruption and climate finance (World Bank 2025; UNODC and World Bank 2024).\n\nResearch has also examined the various forms corruption can take, such as conflicts of interest, undue influence and disproportionate lobbying, which can hinder the adoption and implementation of ambitious climate policies (e.g. Resimić 2022; Nest and Mullard 2021). For example, Transparency International published several reports in 2024 and 2025, analysing the influence of fossil fuel interests before and during UN climate talks and how it undermines trust and legitimacy in multilateral processes as well as obstructs efforts to reduce emissions (Gverdtsiteli 2025a; Goddard et al. 2024; Gverdtsiteli 2025b).\n\nEvidence provided by the Extractive Industries Transparency Initiatives (EITI), U4 Anti-Corruption Resource Centre and the Basel Institute on Governance have also underscored the various governance and corruption risks in the renewable energy sector (Zinnbauer and Trapnell 2023; de Vibe and Robinson 2024; Nest and Mullard 2025). This is an area requiring additional focus.\n\nBillions of dollars are mobilised and invested for climate mitigation and adaptation. 49  Recognising and integrating corruption risks linked to climate finance and renewable energy at the international, regional and national levels is crucial to effectively address all forms of corruption jeopardising initiatives that aim to address the climate crisis.\n\nBox 13: Collaborative educational tools for raising awareness on corruption linked to climate\n\nGamification is a powerful tool for raising awareness and engaging a broad audience on anti-corruption issues through interactive discussions, creative exercises and reflection.\n\nInspired by the success of the Climate Fresk 50  - a collaborative workshop designed to share climate knowledge with the general public - UNODC, together with its youth programme, developed a variation of this format\n\nto explore and deepen understanding of how corruption can exacerbate climate change and undermine climate action.\n\nThe methodology was tested in October 2025 with a group of students at the University of Mostar in Bosnia and Herzegovina as well as officials from the country's Agency for the Prevention of Corruption and Coordination of the Fight against Corruption. It received positive feedback and is currently finalised, with public release expected in 2026.\n\nThe UNODC's 'corruption and climate fresk' will support the dissemination of knowledge and raise public awareness of corruption linked to climate issues.\n\n## 5�2 Corruption and critical minerals\n\nCritical or strategic minerals - such as copper, lithium, cobalt, nickel and rare earths - are essential to our daily lives . They are key components in mobile phones, computers, semiconductors, etc. These minerals also play an important role in reducing greenhouse gas emission and enabling the energy transition .\n\nThe International Energy Agency projects that demand for minerals used in solar panels, wind turbines, electric vehicles and related technologies will quadruple by 2040. 51 Demand is further driven by the rapid development of artificial intelligence infrastructures as well as military and defence systems, making these minerals the centre of geopolitical tensions.\n\nHowever, the growing demand, the race to secure mineral supplies, the urgency to address climate change and the immense profits at stake come with significant challenges and vulnerabilities . These range from environmental and social harms to human rights violations, corruption, financing conflicts and organised crime infiltration.\n\nResearch by Natural Resource Governance Institute (NRGI), Transparency International, EITI and UNODC underscores the risks of corruption associated with the exploitation of critical minerals (Sturman et al. 2022; Sayne et al. 2024; Carballo et al. 2025; UNODC 2025; Fitzgerald et al. 2025). For instance, 91 percent of rare earths, 74 percent of cobalt and 67 percent of nickel are located in countries with high perceived levels of corruption (Carballo et al. 2025).\n\nThese organisations have also documented how corruption undermines progress towards a low carbon economy , with corrupt practices taking place at every stage of the supply and value chains, ranging from bribery and collusion to undue influence and misappropriation of funds. NRGI identified 53 cases of corruption in 30 countries across five continents (Sayne et al. 2024).\n\nTo address these challenges, NRGI developed a diagnostic tool 52  which aims at identifying the forms of corruption and creating an action plan to prevent corruption in the oil, gas and mining sectors. NRGI's diagnostic tool has already been used in Mongolia, Philippines, Guinea and Chile to diagnose corruptions risks associated with the exploitation of critical minerals such as bauxite, lithium and nickel. 53  In the DRC, the Anti-Corruption Agency ( Agence de Prévention et de Lutte contre la Corruption - APLC) is applying the tool to assess corruption risks associated with cobalt exploitation.\n\nTransparency International Australia designed the Mining Awards Corruption Risk Assessment (MACRA) Tool to assess the underlying causes of corruption in mining sector awards. 54  It has been used in 23 countries. The OECD and EITI have also been developing guidance to support companies in conducting due diligence in mineral supply chains, taking an anti-corruption perspective. 55\n\nLastly, the UN established a panel on critical energy transition minerals, bringing together governments, intergovernmental and international organisations, industry and civil society to develop a set of common and voluntary principles to guide the transition. It published a report in 2024 laying down seven guiding principles, including principle 6 on transparency, accountability and anti-corruption measures to ensure good governance. 56\n\nWhile Resolution 8\u002F12 does not explicitly address corruption linked to critical minerals governance, States should urgently integrate anti-corruption measures and safeguards in this sector to protect efforts towards a just and equitable energy transition.\n\n## Box 14: Cross-cutting issues requiring attention: the digital challenge\n\nSeveral cross-cutting issues are not addressed by Resolution 8\u002F12, but merit close attention, as they significantly influence efforts to combat corruption that has an impact on the environment. Two examples are highlighted in this box.\n\nGovernments are increasingly relying on digital technologies and artificial intelligence (AI) tools to prevent, detect and investigate corruption and\u002For crimes that have an impact on the environment.\n\n- 52 See: https:\u002F\u002Fresourcegovernance.org\u002Fpublications\u002Fdiagnosing-corruption-extractive-sector-tool\n- 53 Briefs on lessons learned for each country are available at https:\u002F\u002Fanticorruptiontool.resourcegovernance.org\u002F\n- 54 See: https:\u002F\u002Ftransparency.org.au\u002Fpublications\u002Fmacra-tool\n- 55 See for example: https:\u002F\u002Fwww.oecd.org\u002Fcontent\u002Fdam\u002Foecd\u002Fen\u002Ftopics\u002Fpolicy-sub-issues\u002Fdue-diligence-guidance-forresponsible-business-conduct\u002Fminerals\u002Ffaq-how-to-address-bribery-and-corruption-risks-in-mineral-supply-chains.pdf\n- 56 See: https:\u002F\u002Fwww.un.org\u002Fsites\u002Fun2.un.org\u002Ffiles\u002Freport\\_sg\\_panel\\_on\\_critical\\_energy\\_transition\\_minerals\\_11\\_sept\\_2024.pdf\n\nWhile digital and AI technologies offer significant opportunities and benefits, recent studies have underscored the challenges associated with these tools, including data quality issues, opaque and discriminatory algorithms, biases, regulatory gaps or risks to privacy and fundamental rights (Resimić 2025, Izdebski 2023).\n\nFurthermore, digital and AI technologies can be 'corrupted' and abused for private gain (Köbis et al. 2022a, Köbis et al. 2022b, Transparency International 2025). It can also be used to increase the surveillance of journalists and civil society organisations and further repress civic space.\n\nAddressing and mitigating these risks is essential to ensure digital and AI technologies are an effective approach to tackle corruption that has an impact on the environment.\n\nCryptocurrencies are now well established in the global financial system. They are also increasingly used to facilitate illicit activities - not only cybercrime, but any type of crime involving the transfer of monetary value. Cryptocurrencies can enable corruption and money laundering (Elsayed 2023, UNODC 2025) and are intersecting with crimes that have an impact on the environment. They can add a layer of opacity and complexity that helps conceal and launder the proceeds from crimes that have an impact on the environment.\n\nFor example, in Brazil, law enforcement dismantled a criminal network which had created its own cryptocurrency to launder profits from illegal gold mining (Sayki 2022, Ministério da Justiça e Segurança Pública 2022).\n\nDespite its prominent role, research on - and our understanding of how cryptocurrencies are used in corruption cases linked to crimes that have an impact on the environment remains limited. Preventing and combating the misuse of cryptocurrencies, for example by equipping law enforcement authorities to navigate financial investigations related to cryptocurrencies, is therefore vital to effectively address corruption that has an impact on the environment.\n\n## 6 Conclusion\n\nSince the adoption of Resolution 8\u002F12 in December 2019, various activities have been taking place to tackle corruption as it relates to crimes that have an impact on the environment.\n\nIn terms of prevention , the journey towards fostering a culture of integrity and anti-corruption is progressing, although it takes time for behaviours and practices to evolve. The report highlights a diverse range of actions that are beginning to generate concrete improvement in key systems, processes or norms within environmental authorities - not only to safeguard them from corruption, but also to encourage integrity champions and promote a broader shift in mindset. These initiatives can already be replicated and scaled up.\n\nThe international community can also play a key role by sharing these examples and encouraging States to go further in building robust systems capable of resisting corruption and enabling staff and citizens to safely report wrongdoing and misconduct.\n\nFrom an enforcement perspective, as the first generation of money laundering cases against environmental criminals concludes, it is vital to ensure that lessons learned are shared, replicated or adapted by relevant institutions within the same jurisdiction and in other countries. The 'follow-the-money' approach is beginning to show concrete results.\n\nIt is equally essential to address the root drivers of crimes that have an impact on the environment. Corruption remains an under-addressed dimension of efforts to combat these crimes. Thus, enforcement actions must receive adequate support and resources so they can prioritise the investigation and prosecution of corruption linked to crimes that have an impact on the environment.\n\nThis is no easy task. It requires a systemic approach with committed leadership to equip law enforcement authorities with the right resources and skills, remove obstacles and potential undue influence within the enforcement chain and build strong inter-institutional cooperation. Such collaboration is necessary for specialised anti-corruption actors to broaden their focus and investigate and prosecute crimes that have an impact on the environment.\n\nThe contributions of non-state actors discussed in this report include the research and reporting from journalists, civil society organisations and academia which have enhanced our understanding of corruption as it relates to crimes that have an impact on the environment. The various fora established to facilitate exchanges among officials and professionals engaged in fighting corruption and\u002For crimes that have an impact on the environment have provided specialised networks and knowledge to accelerate peer learning, expertise and thus impact.\n\nOver the last six years, most initiatives tested or implemented have primarily focused on wildlife and forest crimes , with fewer initiatives related to other crimes that have an impact on the environment. It is worth noting, however, that this report has identified several actions targeting illegal gold mining , an increase compared to the 2023 report.\n\nEven though it is still early to draw definitive conclusions on the results and impacts of these activities, they are promising in many aspects.\n\n## What make initiatives promising?\n\nThe authors looked at a combination of the following characteristics to determine the promising initiatives identified in this report:\n\n- · Tried and tested approaches in other spaces that appear to have the right preconditions to function well in the environmental space.\n- · New approaches that are low cost and low risk.\n- · Spaces where very limited work is done to date, meaning that investments might make an outsized difference.\n- · Engagements where environmental and integrity considerations align and thus make adoption more likely.\n- · Activities that align with broader national, regional or global trends, where efforts are likely to bear fruit over time.\n\nPromising initiatives relating to corruption prevention include:\n\n- · Conducting regular corruption perception and experience surveys among staff can help assess both progress and the effectiveness of corruption prevention measures. It can also create baselines against which to measure progress. Not enough interventions and reform efforts start with such a baseline, which means they then struggle to assess progress.\n- · Involving high-level management and leadership at each stage of the corruption prevention approach can help develop ownership and accountability. Explaining how integrity efforts support the strategic and political priorities of the leadership is crucial to achieve this. It requires adapting technocratic approaches to be relevant to the institutional leadership.\n\n- · Stipulating a mandatory budget for corruption prevention across ministries, agencies and departments can help ensure that minimal investments in integrity and anti-corruption activities are effectively prioritised and implemented. Sanctions for not respecting the mandatory budget should be imposed.\n- · Launching awareness-raising campaigns to promote knowledge of anti-corruption measures is an important first step to their effective implementation.\n- · Developing whistleblowing mechanisms can help increase reporting and detection of corruption. To achieve their potential, whistleblower mechanisms require a strong system, reliable protections and an institutional culture that welcomes such feedback.\n- · Peer-to-peer learning for government representatives from different countries and institutions to exchange on corruption prevention actions can be relevant, as anti-corruption officials often struggle with similar institutional challenges. Peer exchanges can help people and institutions to learn from each other's successes and challenges and jointly identify effective mitigation measures.\n\nPromising initiatives relating to enforcement include:\n\n- · Assessing the economic, social and environmental losses from cases of corruption linked to crimes that have an impact on the environment - and using these to calculate associated penalties and fines - can help compensate and restore some of the harm done. Combining calculations of losses due to corruption with those of losses due to the environmental crimes can result in stiffer sentences and penalties.\n- · Seizing and confiscating proceeds and instrumentalities of crime (bank accounts, real estate, vehicles, machineries, etc.) through the diverse legal instruments available in jurisdictions can help ensure that crime does not pay. It also removes the resources needed to continue activities that harm the environment, thereby halting ongoing destruction.\n- · Exploring legal avenues outside the anti-corruption field can help strengthen enforcement. These include legislation on money laundering and tax offences as well as social re-use of seized and confiscation assets, sanctions and visa bans.\n\n## Further promising initiatives\n\nUNCAC States Parties, civil society, academia, the media and the private sector have also engaged in initiatives in areas that were not laid out in Resolution 8\u002F12 which show promising signals and should be highlighted:\n\n- · The increase of transparency and accountability through initiatives such as the Extractive Industries Transparency Initiative 57 , the Fisheries Transparency Initiative 58 , the Open Government Partnership 59  and the Open Contracting Partnership 60 .\n- · The adoption of beneficial ownership legislation , the disclosure of beneficial ownership information, including politically exposed persons, and the creation of beneficial ownership registers. 61\n- · The establishment of traceability systems, electronic information systems and electronic permitting systems in the forestry, wildlife and fisheries sector. 62\n- · The monitoring and reviewing of court proceedings and decisions . 63\n\n## Looking ahead\n\nOverall, the diversity of engagements is laudable. But it is far from the scale needed to make a systemic difference to both societal corruption and environmental challenges. Sustaining efforts and maintaining momentum over time are necessary for long-lasting change. UNCAC States Parties need to adapt and scale up initiatives that are effective or look promising, by:\n\n- · Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources.\n- · Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment.\n\n- 60 See: https:\u002F\u002Fwww.open-contracting.org\u002F\n- 61 For an overview of actions worldwide on beneficial ownership transparency, see the work by Open Ownership: https:\u002F\u002Fwww. openownership.org\u002Fen\u002Fmap\u002F\n- 62 For example, in 2021-2022, WWF Peru piloted an electronic permitting app to reduce opportunities for corruption in the fisheries sector. See: https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-peru-pilot-summary. In addition, around 30 countries are developing or planning electronic CITES permit systems.\n- 63 For more information, see the TNRC publication reviewing the monitoring of wildlife crime cases in Africa, Asia and South America: https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-practice-note-monitoring-wildlife-crime-cases-a-possible-approach-toreduce-corruption-in-the-justice-system\n\n- · Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms.\n- · Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment.\n- · Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment.\n- · Making use of legal frameworks and testing new legal avenues to hold individuals and legal persons accountable, including through asset recovery and remedies to repair the damage.\n- · Engaging in platforms for representatives from governments, civil society and other stakeholder groups to exchange experiences and know-how in tackling corruption that has an impact on the environment.\n- · Sharing knowledge , case law, success stories, etc.\n- · Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity.\n- · Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related issues.\n\nAs these initiatives have now been conducted for six years, there is a sufficient body to scrutinise their effectiveness and efficiency. It is therefore essential to rigorously assess these measures , especially in an environment of increasingly scarce financial resources.\n\nFinally, a paradigm shift is now more than ever necessary. We need to move from the concept of 'corruption as it relates to crimes that have an impact on the environment' to 'corruption that has an impact on the environment ' .\n\nAdopting a holistic approach is crucial to address all forms of corruption that affect the environment, including pressing issues such as corruption linked to climate finance, renewable energy and the exploitation of critical minerals.\n\n## References\n\nAbdelilah, Alexander. 2025. Ghana: Illegal gold poisons land and global supply chains. Forbidden Stories . 24 October 2025. https:\u002F\u002Fforbiddenstories.org\u002Fghanaillegal-gold-environment-multinationals\u002F\n\nAbdelilah, Alexander. 2025. In Ghana, the environment and journalists are the first casualties of the illegal gold rush. Forbidden Stories . 24 October 2025. https:\u002F\u002F forbiddenstories.org\u002Fghana-the-trail-of-illegal-gold-leads-to-india\u002F\n\nAnindito, Lakso. 2025. Indonesia: a landmark money laundering conviction in a forestry crime case . Case Study 12. Basel Institute on Governance. https:\u002F\u002F baselgovernance.org\u002Fpublications\u002Fcs-12\n\nBahemu, Ephrahim. 2024. Uneven playing field: How tax rates drive Tanzania's gold smuggling. The Citizen. 29 November 2024. https:\u002F\u002Fwww.thecitizen.co.tz\u002F tanzania\u002Fmagazines\u002Funeven-playing-field-how-tax-rates-drive-tanzania-s-goldsmuggling-4838896\n\nBrimbeuf, Sara and Esther Bornstein. 2023. B eating the corruptors at their own game A look back at a decade of implementation of the presumption of money laundering in France . Transparency International.\n\nByrd, Nicole, et al. Forthcoming. Money Talks: Ten Years of Firsthand Corruption Reporting from ELI Investigations . Earth League International.\n\nCarballo, Ana Estefanía, et al. 2025. Global transition, local transformations: Governance Challenges for the Energy Transition at the Sites of Extraction . Transparency International Australia.\n\nChan, Tiffanie, et al. 2023. Corruption and integrity risks in climate solutions: an emerging global challenge . The London School of Economics and Political Science.\n\nCIVICUS Monitor. 2024. People Power Under Attack 2024 . CIVICUS Monitor.\n\nConservation-Litigation.org. 2025. Unique legal victory for nature - Precedent-setting case protects threatened cacti and secures remedies for environmental harm . 10 February 2025. https:\u002F\u002Fstatic1.squarespace.com\u002Fstatic\u002F64e90e1032b13d4cbafc8e39\u002Ft\u002F67aa2a85b 4126660856b47d4\u002F1739205277015\u002FCactus+Press+Release\\_1022025.docx.pdf\n\nCountering Environmental Corruption Practitioners Forum. 2025. Takeaways on Dissecting the environmental-financial crime nexus: delving into a case from the Canadian Financial Intelligence Unit. 16 April 2025. https:\u002F\u002Fenvironmental-corruption. org\u002Fnews\u002Ftakeaways-on-dissecting-the-environmental-37\n\nDahl, Hoejris Mie. 2025. Cross-border operation cracks down on environmental crimes in the Amazon . Mongabay.\n\nde Vibe Maja, and Mark Robinson. 2024. Good governance and the just transition: Implications for renewable energy companies . Working Paper 53. Basel Institute on Governance.\n\nDornbierer, Andrew. 2021. Illicit Enrichment - a guide to laws targeting unexplained wealth . Basel Institute on Governance.\n\nElsayed, S. 2023. Cryptocurrencies, corruption and organised crime - Implications of the growing use of cryptocurrencies in enabling illicit finance and corruption . U4 Heldesk Answer 2023:8. U4 Anti-Corruption Resource Centre.\n\nEnglish.news.cn. 2024. Mozambican poacher gets 30 years in prison after being found guilty of killing 42 lions. English.news.cn . 22 March 2024. https:\u002F\u002Fenglish.news. cn\u002F20240322\u002F26832790e7664d359265732c8e1404ae\u002Fc.html\n\nFeinstein, Samantha, Tom Devine, et al. 2021. Are whistleblowing laws working? A global study of whistleblower protection litigation . International Bar Association.\n\nFinancial Crimes Enforcement Network. 2021. Illicit finance threat involving wildlife trafficking and related trends in bank secrecy act data . Financial Crimes Enforcement Network.\n\nFitzgerald, Susannah, et al. 2025. Preventing Corruption in Africa's Transition Mineral Supply Chains . Natural Resource Governance Institute.\n\nForst, Michel. 2025. Report on key trends and threats regarding environmental defenders identified by the Special Rapporteur on environmental defenders . Economic Commission for Europe. ECE\u002FMP.PP\u002F2025\u002F20.\n\nFront Line Defenders. 2025. Global Analysis 2024\u002F25 . Front Line Defenders.\n\nGlobal Witness. 2025a. Roots of resistance - Documenting the global struggles of defenders protecting land and environmental rights . Global Witness.\n\nGlobal Witness. 2025b. Toxic platforms, broken planet - How online abuse of land and environmental defenders harms climate action . Global Witness.\n\nGoddard, Louis, et al. 2024. COP Co-opted? - How Corruption and Undue Influence Threaten Multilateral Climate Action . Transparency International.\n\nGverdtsiteli, Gvantsa. 2025a. Fuelling Delay - How fossil fuel interests shape global climate negotiations . Transparency International.\n\nGverdtsiteli, Gvantsa. 2025b. Behind the Badge - Understanding the roles, reach, and risks of fossil fuel industry participation in UN climate talks . Transparency International.\n\nHuerta, Pamela. 2025. When Gold Rules: Politicians and Criminals Fight Over Resources in the Peruvian Amazon. Amazon Underworld . 28 October 2025. https:\u002F\u002F amazonunderworld.org\u002Fwhen-gold-rules-politicians-and-criminals-fight-overresources-in-the-peruvian-amazon\u002F\n\nHsu, Emily, et al. 2025. Dissecting the environmental - financial crime nexus: a spotlight on the illegal wildlife trade . WWF and Themis.\n\nInternational Press Institute. 2024. Climate and environmental journalism under fire: Threats to Free and Independent Coverage of Climate Change and Environmental Degradation . International Press Institute.\n\nInterpol. 2016. Uncovering the risks of corruption in the forestry sector . Interpol.\n\nInterpol, RHIPTO, Global Initiative against Transnational Organized Crime. 2018. World Atlas of Illicit Flows . Global Initiative against Transnational Organized Crime.\n\nIzdebski, Krzysztof, et al. 2023. The Digitalization of Democracy - How Technology is Changing Government Accountability . National Endowment for Democracy.\n\nKleinfeld, James. 2019. Anatomy of a Bribe: A deep dive into an underworld of corruption. Al Jazeera . 1 December 2019. https:\u002F\u002Fwww.aljazeera.com\u002Ffeatures\u002F2019\u002F12\u002F1\u002Fanatomyof-a-bribe-a-deep-dive-into-an-underworld-of-corruption\n\nKöbis, Nils, et al. 2022a. The corruption risks of artificial intelligence . Transparency International.\n\nKöbis, Nils, et al. 2022a. The Promise and Perils of Using Artificial Intelligence to Fight Corruption . Nature Machine Intelligence, 4, 418-424.\n\nLawlor, Mary. 2025. Tipping points: human rights defenders, climate change and a just transition . United Nations General Assembly.\n\nLemaître, Sophie. 2025. Réduire au silence - Comment le droit est perverti pour bâillonner média et ONG . Rue de l'échiquier.\n\nLemaître, Sophie. 2023a. Strategic litigation and its untapped potential for anticorruption. U4 Anti-Corruption Resource Centre . 12 July 2023. https:\u002F\u002Fwww.u4.no\u002Fblog\u002F strategic-litigation-untapped-potential-for-anti-corruption\n\nLemaître, Sophie. 2023b. Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8\u002F12. Working Paper 50, Basel Institute on Governance. https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fwp-50\n\nMinistério da Justiça e Segurança Pública. 2022. PF Desarticula Organizações Criminosas Voltadas à Extração e Comércio Ilegal de Ouro. 7 July 2022. https:\u002F\u002Fwww. gov.br\u002Fpf\u002Fpt-br\u002Fassuntos\u002Fnoticias\u002F2022\u002F07\u002Fpf-desarticula-organizacoes-criminosasvoltadas-a-extracao-e-comercio-ilegal-de-ouro\n\nMusinguzi, Blanshe. 2024. How Congo trees are smuggled through East Africa . Africa Report.\n\nNatural Resource Governance Institute. 2025. Digging into the Problem - How corruption facilitates socioenvironmental, human rights, and Indigenous Peoples' rights harms in the mining sector . Natural Resource Governance Institute.\n\nNest, Michael, et al. 2020. Corruption and climate finance . U4 Anti-Corruption Resource Centre.\n\nNest, Michael and Saul Mullard. 2021. Lobbying, corruption and climate finance: The stakes for international development . U4 Anti-Corruption Resource Centre.\n\nNest, Michael. 2024. Climate and Corruption Atlas: Lessons from Real-World Cases . Transparency International.\n\nNest, Michael and Saul Mullard. 2025. Climate governance in a fast-changing world: Evolving patterns of corruption risks . U4 Issue 2025:2. U4 Anti-Corruption Resource Centre.\n\nNtawurikura, Rosine. 2025. Lives in Ruin: The Trail of Devastation Left by Illegal Miners in Rwanda's Kamonyi. The Forefront Magazine . 28 June 2025. https:\u002F\u002F theforefrontmagazine.com\u002Flives-in-ruin-the-trail-of-devastation-left-by-illegal-minersin-rwandas-kamonyi\u002F\n\nOLAF. 2024. OLAF pivotal in uncovering a criminal network introducing hazardous waste from the UK to the EU. OLAF . 4 July 2024. https:\u002F\u002Fanti-fraud.ec.europa.eu\u002Fmediacorner\u002Fnews\u002Folaf-pivotal-uncovering-criminal-network-introducing-hazardous-wasteuk-eu-2024-07-04\\_en?utm\\_source=chatgpt.com\n\nPope, Henry. 2023. Brazil Launches Investigation into R$80 Million in Illegal Gold. OCCRP . 11 July 2023. https:\u002F\u002Fwww.occrp.org\u002Fen\u002Fnews\u002Fbrazil-launches-investigationinto-r80-million-in-illegal-gold\n\nReid, Alexandria, Rob Parry-Jones and Tom Keatinge. 2020. Targeting corruption and its proceeds: Why we should mainstream an anti-corruption perspective into 'follow the money' approaches to natural resource crime . TNRC.\n\nResimić, Miloš. 2022. Grand corruption and climate change policies . U4 Anti-Corruption Resource Centre.\n\nResimić, Miloš. 2025 . Harnessing artificial intelligence (AI) for anti-corruption - Benefits and challenges in prevention, detection and investigation . U4 Heldesk Answer 2025:24. U4 Anti-Corruption Resource Centre.\n\nRSF. 2025. 30 journalists embody struggle for freely reported environmental coverage. RSF . 27 October 2025. https:\u002F\u002Frsf.org\u002Fen\u002F30-journalists-embody-struggle-freelyreported-environmental-coverage\n\nSAMLIT. 2025. Financial flows and key indicators associated with illegal wildlife trade in South Africa - the 2025 updated perspective . SAMLIT.\n\nSayki, Inci. 2022. Brazil Dismantles Network That Used Crypto to Launder Illegally Extracted Gold. OCCRP . 14 July 2022. https:\u002F\u002Fwww.occrp.org\u002Fen\u002Fnews\u002Fbrazildismantles-network-that-used-crypto-to-launder-illegally-extracted-gold?utm\\_ source=chatgpt.com\n\nSayne, Aaron, et al. 2024. Ten Red Flags for Corruption Risk in Transition Minerals Licensing and Contracting . Natural Resource Governance Institute.\n\nSebastian, Angela. 2025. Tanzania Bleeds Revenue as Illegal Tin Trade Thrives at Mulongo Border. Musoma News Hub. 16 June 2025. https:\u002F\u002Fmusomanewshub.blogspot. com\u002F2025\u002F06\u002Ftanzania-bleeds-revenue-as-illegal-tin.html\n\nSherpa. 2023. Complaint filed against French banks for money laundering and concealment of proceeds from illegal deforestation in the Amazon. Sherpa . 8 November 2023. https:\u002F\u002Fwww.asso-sherpa.org\u002Fcomplaint-filed-against-french-banks-for-moneylaundering-and-concealment-of-proceeds-from-illegal-deforestation-in-the-amazon\n\nSpicer, Jonathan and Juhani Grossmann. 2022. Targeting profit: non-conviction based forfeiture in environmental crime . TNRC.\n\nSturman, Kathryn, et al. 2022. Mission critical - Strengthening governance of mineral value chains for the energy transition . Extractive Industries Transparency Initiative.\n\nTransparency International. 2022. Corruption-free climate finance: Strengthening multilateral funds . Transparency International.\n\nTransparency International. 2025. Addressing Corrupt Uses of Artificial Intelligence . Transparency International.\n\nUmuhoza, Nadine. 2024. Porous border with DR Congo turns Rwanda into a wildlife trafficking hub . The Bridge Magazine.\n\nUNCAC Coalition. 2024. Breaking the silos: combating corruption and environmental crime to advance climate protection goals . UNCAC Coalition.\n\nUNESCO. 2024. Press and planet in danger: safety of environmental journalists; trends, challenges and recommendations . UNESCO.\n\nUNICRI. 2025. The social re-use of seized and confiscated assets: good policies and practices . UNICRI.\n\nUNODC. Date unknown. Crimes that Affect the Environment and Climate Change . UNODC.\n\nUNODC. 2021. Preventing and Combating Corruption as it Relates to Crimes that have an Impact on the Environment . UNODC.\n\nUNODC. 2025. The Nexus Between Cybercrime and Corruption . UNODC.\n\nUNODC and World Bank. 2024. Addressing Corruption Risks to Safeguard the Response to Climate Change - Discussion draft II. UNODC.\n\n- U.S. Department of Justice. 2023. Doc Antle, Owner of Myrtle Beach Safari, Pleads Guilty to Federal Wildlife Trafficking and Money Laundering Charges. U.S. Department of Justice . 6 November 2023. https:\u002F\u002Fwww.justice.gov\u002Farchives\u002Fopa\u002Fpr\u002Fdoc-antle-ownermyrtle-beach-safari-pleads-guilty-federal-wildlife-trafficking-and-money\n- U.S. Department of Justice. 2025. Doc Antle, Owner of Myrtle Beach Safari, Sentenced for Federal Wildlife Trafficking and Money Laundering Charges. U.S. Department of Justice . 8 July 2025. https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Fdoc-antle-owner-myrtle-beachsafari-sentenced-federal-wildlife-trafficking-and-money\n- U.S. Department of the Treasury. 2024. 2024 National Money Laundering Risk Assessment . Department of the Treasury.\n\nWCP News. 2025. High Court Forfeits $1 Million in Illegal Timber Assets. WCP News . 15 October 2025. https:\u002F\u002Fwww.wildlifecrimeprevention.com\u002F2025\u002F10\u002F15\u002Fhigh-courtforfeits-1-million-in-illegal-timber-assets\u002F\n\nWildlife Justice Commission. 2024. Simon Valoi convicted and sentenced to 27 years in prison: A major blow to rhino horn trafficking in Mozambique and South Africa. Wildlife Justice Commission . 21 August 2024. https:\u002F\u002Fwildlifejustice.org\u002Fsimon-valoi-convictedand-sentenced-to-27-years-in-prison-a-major-blow-to-rhino-horn-trafficking-inmozambique-and-south-africa\u002F\n\nWildlife Justice Commission. 2025a. Disruption and Disarray: An analysis of pangolin scale and ivory trafficking, 2015-2024 . Wildlife Justice Commission.\n\nWildlife Justice Commission. 2025b. Is wildlife trafficking being treated as serious crime? A review of criminal offences, penalties, and implementation of the United Nations Convention against Transnational Organized Crime . Wildlife Justice Commission.\n\nWorld Bank. 2019. Illegal logging, fishing, and wildlife trade: the costs and how to combat it . World Bank.\n\nWorld Bank. 2025. 2nd Symposium on Supranational Responses to Corruption: Integrity in Climate Finance and Action knowledge report . World Bank.\n\nZinnbauer, Dieter and Stephanie Trapnell. 2023. Race to renewables - Tackling corruption and integrity risks in the renewable energy sector . Extractive Industries Transparency Initiative.\n\n## Annex 1 - Relevant resources\n\n## Resource hubs, learning platforms and tools\n\nACAMS self-paced course: https:\u002F\u002Fwww.acams.org\u002Fen\u002Ftraining\u002Fcertificates\u002Fendingillegal-wildlife-trade#learning-points-4fd76b28\n\nBasel Institute on Governance's publications and resources on Green Corruption: https:\u002F\u002F baselgovernance.org\u002Fpublications?topic=6&type=All&country=All&language=All&title\n\nBasel LEARN: https:\u002F\u002Flearn.baselgovernance.org\n\nECOSOLVE's Global Monitoring System on illicit online wildlife markets: https:\u002F\u002Fwww. ecosolve.eco\u002Fdashboard\n\nEnvironmental Investigation Agency's Global Environmental Crime Tracker: https:\u002F\u002Feiainternational.org\u002Fglobal-environmental-crime-tracker\n\nInternational Maritime Organization's self-paced course: https:\u002F\u002Fwww.imo.org\u002Fen\u002F mediacentre\u002Fpressbriefings\u002Fpages\u002Fnew-e-learning-course-tackles-illegal-wildlife-trade. aspx\n\nNature Crime Alliance's knowledge database: https:\u002F\u002Fnaturecrimealliance.org\u002F knowledge-database\n\nNature Crime Alliance's index of tools (a compilation of tools developed by various organisations): https:\u002F\u002Fnaturecrimealliance.org\u002Findex-of-tools\n\nNatural Resource Governance Institute's tool to diagnose corruption in the extractive sector: https:\u002F\u002Fresourcegovernance.org\u002Fpublications\u002Fdiagnosing-corruption-extractivesector-tool\n\nTargeting Natural Resource Corruption knowledge hub: https:\u002F\u002Fwww.worldwildlife.org\u002F pages\u002Ftnrc-knowledge-hub\n\nTransparency International's Climate and corruption atlas: https:\u002F\u002Fwww.transparency. org\u002Fen\u002Fprojects\u002Fclimate-governance-integrity-programme\u002Fclimate-corruption-atlas\n\nTransparency International Australia's Mining Awards Corruption Risk Assessment Tool (MACRA Tool): https:\u002F\u002Fmining.transparency.org.au\u002Fmacra-tool\n\nU4 Anti-Corruption Resource Centre self-paced courses: https:\u002F\u002Fwww.u4.no\u002FU4natural-resources-short-online-courses\n\nUNODC's publications and resources: https:\u002F\u002Fwww.unodc.org\u002Funodc\u002Fen\u002Fenvironmentclimate\u002Fresources.html\n\nUNODC's global analysis on crimes that affect the environment: https:\u002F\u002Fwww.unodc. org\u002Funodc\u002Fen\u002Fdata-and-analysis\u002Fcrimes-that-affect-the-environment.html\n\nUNODC's teaching modules on wildlife crime: https:\u002F\u002Fsherloc.unodc.org\u002Fcld\u002Fen\u002F education\u002Ftertiary\u002Fwildlife-crime.html\n\nWWF and Themis's Environmental Crimes Financial Toolkit: https:\u002F\u002Fwww.wearethemis. com\u002Fuk\u002Fresources\u002Fenvironmental-crimes-financial-toolkit\n\n## Main publications since 2019 providing a global overview of corruption, money laundering and financial crimes linked to crimes that have an impact on the environment\n\nAmerhauser, Kristina and Robin Cartwright. 2023. Hidden in plain sight - counting the cost of environmental crime . Global Initiative against Transnational Organized Crime.\n\nBarber, Victor Charles, et al. 2025. People. Planet. Justice. Understanding and countering nature crime . World Resources Institute.\n\nByrd, Nicole, et al. Forthcoming. Money Talks: Ten Years of Firsthand Corruption Reporting from ELI Investigations . Earth League International.\n\nCarballo, Estefanía Ana, et al. 2025. Global transition, local transformations: Governance Challenges for the Energy Transition at the Sites of Extraction . Transparency International Australia.\n\nCutajar, Chantal, et al. 2025. Livre blanc sur la criminalité environnementale . Dalloz.\n\nde  Vibe  Maja,  and  Mark  Robinson.  2024. Good  governance  and  the  just  transition: Implications  for  renewable  energy  companies . Working  Paper  53.  Basel  Institute  on Governance.\n\nECOFEL. 2021. Financial investigations into wildlife crime . Egmont Group.\n\nEgmont  Group  of  Financial  Intelligence  Units.  2025. The  role  of  FIUs  in  fighting environmental crimes. Egmont Group of Financial Intelligence Units.\n\nEnvironmental Investigation Agency. 2021. Rotten to the Core: How to tackle the corrupt networks facilitating wildlife and forest crime . Environmental Investigation Agency.\n\nEnvironmental Investigation Agency. 2025. Tricks, Traders and Trees - How Illegal Logging Drives Forest Crime in the Brazilian Amazon and Feeds EU and U.S . Markets. Environmental Investigation Agency.\n\nEuropol. 2022. Environmental Crime in the Age of Climate Change .  Threat  assessment, Europol.\n\nFATF. 2020. Money Laundering and the Illegal Wildlife Trade . FATF.\n\nFATF. 2021. Money Laundering from Environmental Crimes . FATF.\n\nFitzgerald, Susannah, et al. 2025. Digging Into the Problem - How corruption facilitates socioenvironmental,  human  rights,  and  Indigenous  Peoples'  rights  harms  in  the  mining sector . Natural Resource Governance Institute.\n\nFitzgerald,  Susannah,  et  al.  2025. Preventing  Corruption  in  Africa's  Transition  Mineral Supply Chains . Natural Resource Governance Institute.\n\nGlantz, Elijahs, et al. 2025. Strengthening Financial Investigation of Wildlife Crime in Central Africa . RUSI.\n\nGonzalez, Sofia, et al. 2023. Dirty Money and the Destruction of the Amazon: Uncovering the U.S. Role in Illicit Financial Flows from Environmental Crimes in Peru and Colombia . FACT Coalition.\n\nHsu, Emily, et al. 2025. Dissecting the environmental - financial crime nexus: a spotlight on the illegal wildlife trade . WWF and Themis.\n\nKassa, Saba, et al. 2019. Corruption and wildlife trafficking: exploring drivers, facilitators and networks behind illegal wildlife trade in East Africa . Working Paper 30. Basel Institute on Governance.\n\nInstituto Igarapé. 2025. Strengthening Anti-Money Laundering Systems Against Environmental Crime: Comparative Legal and Policy Frameworks in Amazonian Countries . Instituto Igarapé.\n\nIsarin, Nancy, et al. 2023. Dirty deals - Case studies on corruption in waste management and trade . Working Paper 49. Basel Institute on Governance.\n\nMarks,  Dan  and  Jennifer  Scotland.  2025. Emerging  Insights  -  Scoping  Corruption  in Voluntary Carbon Markets . RUSI.\n\nNest,  Michael.  2024. Climate  and  Corruption  Atlas:  Lessons  from  Real-World  Cases . Transparency International.\n\nNest,  Michael  and  Saul  Mullard.  2025. Climate  governance  in  a  fast-changing  world: Evolving  patterns  of  corruption  risks . U4  Issue  2025:2.  U4  Anti-Corruption  Resource Centre.\n\nSayne, Aaron, et al. 2024. Ten Red Flags for Corruption Risk in Transition Minerals Licensing and Contracting . Natural Resource Governance Institute.\n\nStassart,  Joachim,  and  Flávia  M.  de  A.  Collaço.  2023. Addressing  land  corruption  for climate justice . Transparency International.\n\nStewart, Davyth, et al. 2023. Wildlife money trails - Building financial investigations from wildlife and timber trafficking cases in the European Union . TRAFFIC.\n\nTRAFFIC.  2020. Case  Digest:  Initial  Analysis  of  the  Financial  Flows  and  Payment Mechanisms behind Wildlife and Forest Crime . TRAFFIC.\n\nUNODC. 2019. Rotten  Fish:  A  Guide  on  Addressing  Corruption  in  the  Fisheries  Sector . United Nations Office on Drugs and Crime.\n\nUNODC. 2021 . Preventing and Combating Corruption as it Relates to Crimes that Have an Impact on the Environment: An Overview . United Nations Office on Drugs and Crime.\n\nUNODC. 2023. Scaling Back Corruption: A Guide on Addressing Corruption for Wildlife Management Authorities . United Nations Office on Drugs and Crime.\n\nUNODC.  2023. Rooting  out  corruption  -  An  introduction  to  addressing  the  corruption fuelling forest loss . United Nations Office on Drugs and Crime.\n\nUNODC. 2024. World Wildlife Crime Report . United Nations Office on Drugs and Crime.\n\nUNODC.  2025. Safeguarding  strategic  resources  in  Latin  America  and  the  Caribbean: countering organized crime, money laundering, and corruption in the mining sector . United Nations Office on Drugs and Crime.\n\nWildlife  Justice  Commission.  2022 . Role  of  corruption  in  illegal  trade .  Wildlife  Justice Corruption.\n\nWildlife Justice Commission. 2023. Dirty Money: The Role of Corruption in Enabling Wildlife Crime . Wildlife Justice Commission.\n\nWildlife  Justice  Commission.  2023. Convergence  of  wildlife  crime  with  other  forms  of organised crime: A 2023 review . Wildlife Justice Commission.\n\nWildlife Justice Commission. 2025. Is wildlife trafficking being treated as serious crime? A review of criminal offences, penalties, and implementation of the United Nations Convention against Transnational Organized Crime . Wildlife Justice Commission.\n\nWorld Bank. 2025. 2nd Symposium on Supranational Responses to Corruption: Integrity in Climate Finance and Action knowledge report . World Bank.\n\nYansura, Julia. 2024. Money Laundering from Environmental Crime: Typologies and Trends in Countries in the Amazon Region . FACT Coalition.\n\n## Annex 2 - Initiatives from the 2023 Seedlings of hope report\n\nBelow are two promising initiatives which were included in the Seedlings of hope report published in 2023.\n\n\u003C!-- image -->\n\nIndonesia: Combining anticorruption and anti-money laundering legislation for nature restoration\n\nPT Duta Palma, a major palm oil conglomerate in Indonesia, and its\n\nsubsidiaries have been under investigation for bribing public officials in Riau Province, illegal land clearing and conversion and land conflicts with local communities, among many allegations. In September 2023, Surya Darmadi, the CEO of PT Duta Palma, saw his initial conviction in February 2023 for corruption and money laundering upheld by the Supreme Court of Indonesia (Jong Hans Nicholas 2023).\n\nThe case has many distinctive features. The conviction is exemplary: Surya Darmadi was sentenced to 16 years in prison. The Attorney General's Office took an innovative approach. Instead of relying on environmental crime legislation, it based its case on the Indonesian anticorruption law that includes a special provision on unlawful enrichment that has an impact on finance and economic state loss. The Supreme Court followed the Attorney General's approach, using the provisions related to economic loss for the State and the removal of the illegal gains for its verdict.\n\nWhile the imposed fine of IDR 2.23 trillion (equivalent to USD 144 million) represents a significant reduction from the initial conviction in February 2023, 64 the case underscores the possibility of assessing economic and social losses resulting from corrupt practices linked to crimes that have an impact on the environment.\n\nWith several corruption cases currently under prosecution that have similar characteristics, one can only hope that the ensuing fines will reflect the gravity of the offences, ensuring that effective restoration actions are taken and sending a clear message that crime does not pay.\n\n\u003C!-- image -->\n\n## Thailand: Using anti-money laundering legislation to confiscate illicit acquired assets\n\nIn Thailand, after a first criminal investigation into the operations of Boonchai Bach, a Vietnamese and Thai citizen suspected of wildlife trafficking, the AntiMoney Laundering Office opened a new case in 2019. It collaborated with the NGO Freeland Foundation to map the entire criminal network. Using the Anti-Money Laundering Act, the Anti-Money Laundering Office seized and froze more than THB 300 million (USD 11 million) worth of assets\n\n(including hotels, land, vehicles and bank accounts) of Boonchai Bach for laundering profits of wildlife trafficking (Freeland 2021).\n\nThe case was a success thanks in part to the collaboration with the Freeland Foundation and government agencies from Australia, Malaysia, South Africa, Thailand and the US (Cabrejo le Roux and Romero 2023). Thailand, Vietnam and Malaysia are examining how they can work together to make it a multi-country case to seize his assets in every jurisdiction (Nuwer 2023).\n\n## References:\n\nCabrejo le Roux, Amanda and Isabella Romero. 2023. 'Following-the-money' in environmental crime cases: Lessons from experience. TNRC . September 2023. https:\u002F\u002F www.worldwildlife.org\u002Fpages\u002Ftnrc-blog-following-the-money-in-environmental-crimecases-lessons-from-experience\n\nFreeland. 2021. Thailand says $11m seized in wildlife trafficking sting. Freeland . 17 March 2021. https:\u002F\u002Fwww.freeland.org\u002Fnewsroom\u002Fthailand-says-11m-seized-in-wildlifetrafficking-sting\n\nJong, Hans Nicholas. 2023. Experts slam massive 'discount' in fines for Indonesian palm oil billionaire. Mongabay . 27 September 2023. https:\u002F\u002Fnews.mongabay.com\u002F2023\u002F09\u002F experts-slam-massive-discount-in-fines-for-indonesian-palm-oil-billionaire\u002F\n\nLlewellyn, Aisyah. 2023. Indonesia's palm oil tycoon Darmadi gets 15 years for corruption. Al Jazeera . 24 February 2023. https:\u002F\u002Fwww.aljazeera.com\u002F economy\u002F2023\u002F2\u002F24\u002Findonesias-palm-oil-tycoon-darmadi-gets-15-years-for-corruption\n\nNuwer, Rachel. 2023. Thai poaching kingpin is on the run after prison sentence. National Geographic . 15 February 2023. https:\u002F\u002Fwww.nationalgeographic.com\u002Fanimals\u002Farticle\u002F manhunt-thai-poaching-kingpin-southeast-asia-traffickingivory\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->","2025-12-11T17:05:46.000Z","2026-06-02T14:08:56.000Z","Adopted in 2019, UNCAC Resolution 8\u002F12 – *Preventing and combating corruption as\nit relates to crimes that have an impact on the environment* – urges States Parties to\nprevent, investigate and prosecute corruption offences where they may be linked to\ncrimes that have an impact on the environment.\n\nIn 2023, the Basel Institute on Governance published its Working Paper 50,\n*Seedlings of hope*, providing a panorama of emerging and promising initiatives\nacross the world since the adoption of Resolution 8\u002F12. The purpose of the updated\nreport Saplings of hope is to highlight what progress has been achieved since then.\n\n### Corruption prevention measures\n\nStates have implemented a host of initiatives to strengthen integrity systems.\nMost commonly, this included the revision and adoption of internal control policies, more dedicated risk management efforts, including through the establishment\nof corruption prevention committees, and a range of capacity building efforts to\nstrengthen environmental agencies’ ability to mitigate their own corruption risks,\nsuch as workshops on ethics codes and other integrity measures. Whistleblower\nprotection programmes were increasingly designed, implemented and promoted.\nCorruption risk assessments were conducted in sectors such as wildlife management, forestry and fisheries.\n\nPromising corruption prevention interventions include:\n\n- Conducting regular corruption perception and experience surveys among staff. This can help assess both progress and the effectiveness of corruption prevention measures. It can also create baselines against which to measure progress. Not enough interventions and reform efforts start with such a baseline, which means they then struggle to assess progress.\n- Involving high-level management and leadership at each stage of the corruption prevention approach. This can help develop ownership and accountability. Explaining how integrity efforts support the strategic and political priorities of the leadership is crucial to achieve this. It requires adapting technocratic approaches to be relevant to the institutional leadership.\n- Stipulating a mandatory budget for corruption prevention across ministries, agencies and departments. This can help ensure that minimal investments in integrity and anti-corruption activities are effectively prioritised and implemented. Sanctions for not respecting the mandatory budget should be imposed.\n- Launching awareness-raising campaigns to promote knowledge of anti-corruption measures. This is an important first step to their effective implementation.\n- Developing whistleblowing mechanisms. They can help increase reporting and detection of corruption. To achieve their potential, whistleblower mechanisms require a strong system, reliable protections and an institutional culture that welcomes such feedback.\n- Peer-to-peer learning for government representatives from different countries and institutions to exchange on corruption prevention actions. This can be relevant, as anti-corruption officials often struggle with similar institutional challenges. Peer exchanges can help people and institutions to learn from each other’s successes and challenges and jointly identify effective mitigation measures.\n\n### Enforcement actions\n\nSeveral countries have investigated and prosecuted corruption cases linked to\ncrimes that have an impact on the environment. Financial investigations and\nmoney laundering legislation are more frequently used to tackle these crimes.\nThe systematic seizure and confiscation of assets is still just beginning, as is\nthe creation of multi-agency and interdisciplinary task forces, nationally and\ninternationally. However, enforcement actions on corruption as it relates to crimes\nthat have an impact on the environment are still limited.\n\nPromising enforcement interventions include:\n\n- Assessing the economic, social and environmental losses from cases of corruption linked to crimes that have an impact on the environment – and using these to calculate associated penalties and fines – can help compensate and restore some of the harm done. Combining calculations of losses due to corruption with those of losses due to the environmental crimes can result in stiffer sentences and penalties.\n- Seizing and confiscating proceeds and instrumentalities of crime (bank accounts, real estate, vehicles, machineries, etc.) through the diverse legal instruments available in jurisdictions can help ensure that crime does not pay. It also removes the resources needed to continue activities that harm the environment, thereby halting ongoing destruction.\n- Exploring legal avenues outside the anti-corruption field can help strengthen enforcement. These include legislation on money laundering and tax offences as well as the social re-use of seized and confiscation assets, sanctions and visa bans.\n\n### Essential role of civil society and the media\n\nAlongside States, civil society organisations and the media have played an essential\nrole in increasing our understanding of the relationship between corruption and\ncrimes that have an impact on the environment.\n\nTheir efforts span investigative reporting, publishing evidence-based research,\ncapacity building, creating networks to bridge the gap between anti-corruption\nand environmental practitioners, as well as initiating strategic litigation cases. Their\ninvolvement is all the more commendable given that they are facing an increasingly\nrepressive environment.\n\n### The way forward\n\nAs this Working Paper highlights, various activities are taking place to tackle\ncorruption linked to crimes that have an impact on the environment. The paper\npicks out those that show significant promise. The diversity of engagements is\nlaudable, but it is far from the scale needed to make a systemic difference to both\nsocietal corruption and environmental challenges. States Parties need to adapt and\nscale up initiatives that are effective or look promising, by, among other things:\n\n- Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources.\n- Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment.\n- Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms.\n- Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment.\n- Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment.\n- Making use of legal frameworks and testing new legal avenues to hold individuals and legal persons accountable, including through asset recovery and remedies to repair the damage.\n- Engaging in platforms for representatives from governments, civil society and other stakeholder groups to exchange experiences and know-how in tackling corruption that has an impact on the environment.\n- Sharing knowledge, case law, success stories, etc.\n- Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity.\n- Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related\nissues.\n\nAs these initiatives have now been conducted for six years, there is a sufficient\nbody to scrutinise their effectiveness and efficiency. It is therefore **essential to\nrigorously assess these measures**, especially in an environment of increasingly\nscarce financial resources.\n\n### Addressing corruption that has an impact on the environment\n\nThe Working Paper also makes a case for moving from the concept of “corruption\nas it relates to crimes that have an impact on the environment” to “**corruption that\nhas an impact on the environment**”.\n\nFocusing solely on corruption linked to crimes that have an impact on the\nenvironment overlooks situations where corruption causes environmental harm\nwithout an associated criminal offence. It does not take into consideration pressing\nissues such as corruption linked to climate finance, renewable energy and the\nexploitation of critical minerals.\n\nAdopting a holistic approach is crucial to address all forms of corruption that affect\nthe environment, and thus to protect the environment and people.","\u002Fresources\u002Fpublications\u002Fwp-61",{"id":447,"slug":448,"title":449,"status":6,"nid":450,"year":397,"body":451,"external":19,"topic":452,"language":15,"type":455,"date_published":456,"image":457,"citation":458,"publisher":17,"link_internal":459,"link_external":463,"authors":464,"countries":473,"tags":478,"pdf":487,"topics":489,"featured":19,"languages":7,"summary":491,"programme":7,"area":7,"websites":7,"pdf_text":492,"sort":7,"user_created":48,"date_created":493,"user_updated":49,"date_updated":494,"main_points":14,"short_version":495,"subtitle":496,"link":497},2419,"wp-58","Working Paper 58: Corruption as a facilitator of drug trafficking in the port of Rotterdam",2847,"This Working Paper explores the drivers and strategies of corruption as a facilitator of drug trafficking in the port of Rotterdam, with a specific focus on cocaine trafficking. Through in-depth interviews with stakeholders, a review of judicial cases and desk research, it aims to:\n\n\n- deepen understanding of the systems and mechanisms of corruption that enable drug trafficking;\n- show how trafficking and corruption strategies are changing in response to increased enforcement pressure; and\n- provide practical insights on how to further strengthen port resilience.\n\n\nIt contributes to the growing body of work that looks at corruption from a systemic viewpoint, analysing the relationships and adaptive capabilities that allow organised crime to thrive. This research supports efforts to develop more robust and foresight-focused approaches to combat corruption and drug trafficking.\n\n### About this Working 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 \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002Fdeed.en\">BY-NC-ND 4.0\u003C\u002Fa> International Licence.\n\nThis Working Paper was written as part of the FALCON (Fight Against Largescale Corruption and Organised Crime Networks) project. FALCON is funded under the European Union’s Horizon Europe Framework Program Grant Agreement ID 101121281. The Basel Institute on Governance, as an associated partner without the right to receive funds directly from the European Research Executive Agency, has received funding from the Swiss State Secretariat for Education, Research and Innovation (SERI).\n\nThe contents of this document are the sole responsibility of the authors and do not necessarily reflect the views of the European Union, the European Research Executive Agency or SERI.\n",[453,454],"Prevention","Research and Innovation",[32],"2025-09-11","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Ff2bc171a-166b-4939-9829-788720a33c29?width=600&height=840","Kassa, Saba and Jacopo Costa. 2025. ‘Corruption as a facilitator of drug trafficking in the port of Rotterdam: Drivers, strategies and implications.’ Working Paper 58, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-58.",[460],{"url":461,"caption":462},"https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F2844"," View related workshop \"Red flags at the frontier\"",[],[465,469],{"authors_id":466},{"id":467,"name":468},559,"Dr Saba Kassa",{"authors_id":470},{"id":471,"name":472},550,"Dr Jacopo Costa",[474],{"countries_id":475},{"id":476,"name":477},163,"Netherlands",[479,481,485],{"tags_id":480},{"id":384,"name":385},{"tags_id":482},{"id":483,"name":484},859,"Corruption risks",{"tags_id":486},{"id":428,"name":429},[488],2476,[490,29],"Prevention Research and Innovation","This Working Paper explores the drivers and strategies of corruption as a facilitator of drug trafficking in the port of Rotterdam, with a specific focus on cocaine trafficking. Through in-depth interviews with stakeholders, a review of judicial cases and desk research, it aims to","\u003C!-- image -->\n\n## Corruption as a facilitator of drug trafficking in the port of Rotterdam\n\n## Drivers, strategies and implications\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n## About this Working Paper\n\nThis Working Paper explores the drivers and strategies of corruption as a facilitator of drug trafficking in the port of Rotterdam, with a specific focus on cocaine trafficking. Through in-depth interviews with stakeholders, a review of judicial cases and desk research, it aims to:\n\n- · deepen understanding of the systems and mechanisms of corruption that enable drug trafficking;\n- · show how trafficking and corruption strategies are changing in response to increased enforcement pressure; and\n- · provide practical insights on how to further strengthen port resilience.\n\nIt contributes to the growing body of work that looks at corruption from a systemic viewpoint, analysing the relationships and adaptive capabilities that allow organised crime to thrive. This research supports efforts to develop more robust and foresight-focused approaches to combat corruption and drug trafficking.\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 International Licence.\n\nThe contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n\nSuggested citation: Kassa, Saba and Jacopo Costa. 2025. 'Corruption as a facilitator of drug trafficking in the port of Rotterdam: Drivers, strategies and implications.' Working Paper 58, Basel Institute on Governance. Available at: baselgovernance.org\u002Fpublications\u002Fwp-58.\n\n## About the authors\n\n\u003C!-- image -->\n\n## Saba Kassa\n\nSenior Specialist and Deputy Director, Prevention, Research and Innovation.\n\nDr Saba Kassa is a public governance expert with over 10 years of experience in promoting democratic governance. She leads the implementation of the research, technical assistance and capacity-building activities of the Basel Institute's Prevention, Research and Innovation team.\n\nSaba holds a PhD in International Development Studies from the International Institute of Social Studies in The Hague, a Master's in International Development Studies from the University of Amsterdam, as well as a Master's in Public Administration from Erasmus University Rotterdam.\n\nEmail: saba.kassa@baselgovernance.org\n\n\u003C!-- image -->\n\n## Jacopo Costa\n\nSenior Specialist Prevention, Research and Innovation\n\nDr Jacopo Costa is Senior Specialist, Prevention, Research and Innovation at the Basel Institute on Governance.\n\nHis research has been published in renowned academic journals in the field of criminology and political science. Topics include for example the nature of informal networks, the corrupt exchange in the public works and football industry, illegal wildlife trade between East Africa and Southeast Asia, and the nexus between corruption and money laundering.\n\nHe holds a PhD in Sociology and Political Studies from the University of Turin, a Master's from the University of Florence and a Bachelor's in Culture and Human Rights from the University of Bologna.\n\nEmail: jacopo.costa@baselgovernance.org\n\n## Acknowledgements and funding\n\nThis Working Paper was written as part of the FALCON (Fight Against Largescale Corruption and Organised Crime Networks) project. FALCON is funded under the European Union's Horizon Europe Framework Program Grant Agreement ID 101121281. The Basel Institute on Governance, as an associated partner without the right to receive funds directly from the European Research Executive Agency, has received funding from the Swiss State Secretariat for Education, Research and Innovation (SERI).\n\nThe contents of this document are the sole responsibility of the authors and do not necessarily reflect the views of the European Union, the European Research Executive Agency or SERI.\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n## Project funded by\n\n\u003C!-- image -->\n\nSchweizerische Eidgenossenschaft Confédération suisse Confederazione Svizzera Confederaziun svizra\n\nSwiss Confederation\n\nFederal Department of Economic Affairs. Education and Research EAER State Secretariat for Education, Research and Innovation SERI\n\n## Executive summary\n\nThis Working Paper examines how corruption facilitates drug trafficking (specifically cocaine) through the port of Rotterdam, looking at the underlying drivers and strategies involved. Legal trade routes and commercial ports are especially attractive because of the high volumes of cargo, which make it possible to conceal illicit cargo under licit cargo. The spatial complexity of the port of Rotterdam also makes it difficult to fully secure it against criminal activity.\n\nDigging deeper into the facilitating factors of trafficking, the paper finds that, paradoxically, a main driver of rising border corruption is the increased political attention on and resources dedicated to fighting trafficking. Desk research and stakeholder interviews highlight that as authorities deploy new technology to improve detection, traffickers face more obstacles to operating effectively. Having someone on the inside then becomes increasingly important (Staring et al., 2019). So, an unintended but important consequence of the strengthened fight against drug trafficking is that corruption becomes even more essential for the operational success of organised crime networks.\n\nThis study focuses specifically on the role of customs. Tasked with monitoring the import and export of goods, customs officers are important actors in the fight against drug trafficking. However, their role also makes them vulnerable: they have crucial knowledge on processes and procedures, access to systems and discretionary power that can be exploited by criminals (KPMG, 2021).\n\nThe desk research shows that corruption is used strategically to circumvent two important bottlenecks: the container screening and security as cargo enters the port, and the exit of drugs from the port (Staring et al., 2019). Traffickers may seek to obtain key information or direct assistance from customs officers.\n\nThese corrupt relationships and the emerging networks between members of crime groups and the customs officials are diverse. Some relationships can be characterised by collusion, where customs officials offer their services or are persuaded to cooperate. This collusion may be opportunistic or targeted. Other relationships can be characterised by coercion. Customs officials may be lured by financial reward, but this is accompanied by intimidation or the threat of violence to ensure that the officer cooperates and continues to cooperate. Our research highlights that the boundary between collusion and coercion is often blurred.\n\nBeyond collusion and coercion, we also see infiltration, which crosses the boundaries between the criminal, public and private. What emerges is less a matter of individual corruption and more akin to regulatory capture, where the public office position is held by a member of the criminal network.\n\nThe review of the judicial cases shows that bribes involved in these schemes can amount to millions. To hide and use the illicit gains, traffickers rely on money laundering, disguising its source as legitimate. They often enlist the help of family and friends, a trusted inner circle or professional specialists. They may also hide cash at home or invest it in assets and businesses in the Netherlands or abroad.\n\nA key finding of our research is that the criminal and corruption strategies used to facilitate drug trafficking are highly adaptive. The underlying driver of this adaptability is the unchanging demand for drugs and high profitability of the crime. This pushes traffickers to adopt new strategies to overcome hurdles in supplying the demand.\n\nCorruption strategies adapt in response to new enforcement measures. When control systems are changed and\u002For strengthened, corruption strategies evolve alongside them. This research identifies some key patterns:\n\n- · Stronger detection efforts increase the incentives for corruption.\n- · Evolving systems encourage a similar shift in corruption strategies.\n- · Anti-corruption and anti-trafficking measures may change the profile of those most vulnerable to being co-opted.\n- · The characteristics of corruption can also evolve, from collusion to coercion, to full infiltration of institutions and systems - with blurred lines in between.\n\nTrafficking strategies are similarly adaptive. There have been increased efforts by the port to combat trafficking through enhanced detection and technology. This was initially reflected by increased drug seizures. But since 2024, drugs seizures have declined. The research findings provide an explanation for this: As detection strengthens, more drug seizures are made. But what may happen, too, is a response to these new measures. As the risk of detection increases, criminals may adapt their trafficking strategies to overcome the additional hurdles, including:\n\n- · changing concealment strategies; and\n- · changing modes of transport and trafficking routes, including to ports outside of the Netherlands.\n\nThese developments highlight the complexity in understanding the impact of stronger anti-trafficking measures on both corruption and trafficking strategies. Trafficking and corruption are typically measured by detection, for example, by changes in the volume of drug seizures or the number of public officials caught engaging in corruption. But the elephant in the room is that increasingly sophisticated criminal strategies can hide what is really happening. This underscores the need to continuously strengthen our ability to recognise 'red flags' of corruption and trafficking. Data-driven tools and refined risk indicators are critical for understanding how crime and corruption strategies are changing.\n\nThe evolving nature of criminal strategies is often likened to a game of chess: enforcement makes a move, and criminal networks adapt. But what now seems to be emerging is more troubling. When barriers to drug trafficking increase while demand remains unchanged, crime and corruption strategies adapt in ways that can deepen their impact on society, leading for example to the hardening of crime and associated violence.\n\nThis makes anticipating how crime may adapt to changing anti-corruption and anti-trafficking strategies critical. Improved foresight and scenario-building capacities will be vital in order to develop more robust enforcement efforts against drug trafficking and mitigate the negative impact on society.\n\nA holistic approach is essential. Addressing corruption as a facilitator of drug trafficking requires a broad view of crime that focuses on understanding vulnerabilities, leveraging data and harnessing collaboration. The risk of trafficking routes changing are high, therefore, we must use every tool at our disposal to ensure effective and sustainable enforcement efforts.\n\nTable of contents\n\n| 1                                                                                                                                                                                     | Introduction ......................................................................................................... 8                                                              | Introduction ......................................................................................................... 8   |\n|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|\n| 2  Facilitating factors of drug trafficking and drivers of  border corruption ............................................................................................... 9       | 2  Facilitating factors of drug trafficking and drivers of  border corruption ............................................................................................... 9       |                                                                                                                            |\n| 2.1                                                                                                                                                                                   | Facilitating factors of trafficking through the port of Rotterdam                                                                                                                     | 9                                                                                                                          |\n| 2.2                                                                                                                                                                                   | Drivers of border corruption                                                                                                                                                          | 10                                                                                                                         |\n| 2.3                                                                                                                                                                                   | More obstacles create greater need for corruption                                                                                                                                     | 10                                                                                                                         |\n| Strategies of border corruption  ......................................................................12                                                                             | Strategies of border corruption  ......................................................................12                                                                             |                                                                                                                            |\n| 3.1                                                                                                                                                                                   | Involvement of organised crime networks                                                                                                                                               | 12                                                                                                                         |\n| 3.2                                                                                                                                                                                   | Crime networks and evolving corruption practices                                                                                                                                      | 13                                                                                                                         |\n| Corruption networks: collusion, coercion and infiltration  ........................17                                                                                                 | Corruption networks: collusion, coercion and infiltration  ........................17                                                                                                 | Corruption networks: collusion, coercion and infiltration  ........................17                                      |\n| 4.1                                                                                                                                                                                   | Building corruption networks                                                                                                                                                          | 17                                                                                                                         |\n| 4.2                                                                                                                                                                                   | Collusion                                                                                                                                                                             | 17                                                                                                                         |\n| 4.3                                                                                                                                                                                   | Coercion                                                                                                                                                                              | 18                                                                                                                         |\n| 4.4                                                                                                                                                                                   | Infiltration                                                                                                                                                                          | 19                                                                                                                         |\n| Bribery and money laundering .......................................................................21                                                                                | Bribery and money laundering .......................................................................21                                                                                | Bribery and money laundering .......................................................................21                     |\n| 5.1                                                                                                                                                                                   | Bribe payments in line with the high profits of drug trafficking                                                                                                                      | 21                                                                                                                         |\n| 5.2                                                                                                                                                                                   | Social and financial strategies for money laundering                                                                                                                                  | 22                                                                                                                         |\n| 6  Adaptive criminal and corruption strategies to facilitate  drug trafficking  .................................................................................................. 25 | 6  Adaptive criminal and corruption strategies to facilitate  drug trafficking  .................................................................................................. 25 |                                                                                                                            |\n| 6.1                                                                                                                                                                                   | Trafficking and corruption strategies follow the path of  least resistance                                                                                                            | 25                                                                                                                         |\n| 6.2                                                                                                                                                                                   | Corruption strategies are adaptive                                                                                                                                                    | 25                                                                                                                         |\n| 6.3                                                                                                                                                                                   | Trafficking strategies are equally adaptive                                                                                                                                           | 28                                                                                                                         |\n| 6.4                                                                                                                                                                                   | The problem with understanding hidden and complex                                                                                                                                     |                                                                                                                            |\n| 6.5                                                                                                                                                                                   | corruption and crime strategies   Practitioner insights on how to deal with the adaptive  nature of crime                                                                             | 30 32                                                                                                                      |\n| Conclusion ......................................................................................................... 34                                                               | Conclusion ......................................................................................................... 34                                                               |                                                                                                                            |\n| Bibliography ............................................................................................................ 35                                                          | Bibliography ............................................................................................................ 35                                                          |                                                                                                                            |\n| Annex ........................................................................................................................ 43                                                     | Annex ........................................................................................................................ 43                                                     |                                                                                                                            |\n\n## 1 Introduction\n\nRotterdam is the largest port in Europe. While efficiency and safety are top priorities for the port, as an important logistical hub it becomes inadvertently attractive for drug trafficking, especially of cocaine (Staring et al., 2019). The head of the Seaport Police Rotterdam laments that 'the biggest battle against traffickers is their ability to corrupt ports with money and intimidation' (May and Holcova, 2023). This corruption at the border comprises an illegal exchange of resources between border officials (the bribe takers) and private actors (the bribe givers) (Jancsics, 2019, 2020, 2021).\n\nFighting border corruption as a facilitator of drug trafficking has become an important priority for the Dutch government, with increased attention and resources devoted to it (Staring et al., 2019; Zürcher et al., 2024; Government of the Netherlands, 2021). This is because the illicit drug trade and the corruption that facilitates it come at a high cost to society and the rule of law, impacting health, security and governance (Nistotskaya et al., 2024).\n\nThe problem faced by the port of Rotterdam is not unique. Organised crime networks use corruption to facilitate trafficking into, through and out of ports across Europe. Ports in France (Marseille), Germany (Hamburg), Belgium (Antwerp), Italy (Gioia Tauro) and Spain (Valencia) face similar risks. It is an important problem that the Horizon Europe project FALCON (Fight Against Large-scale Corruption and Organised Crime Networks) aims to address. Law enforcement practitioners, social scientists and data analysis experts join forces in this project to innovate the fight against corruption by leveraging digital tools. This Working Paper is based on research that is part of and contributes towards the FALCON project.\n\nThe scale of the problem is significant. Half of Europe's criminal networks are involved in drug trafficking, either alone or as part of other criminal activities. Crucially, over 70 percent of criminal networks use corruption to facilitate their illegal activities (Europol, 2024). A close examination of this phenomenon in the port of Rotterdam can provide some critical insights into:\n\n- · the drivers and aims of border corruption, giving attention to characterising the manner in which corruption deals are carried out and the goals that are pursued by engaging in them; and\n- · the adaptive nature of corruption in response to innovations aimed at enhancing efficiency and security at the borders.\n\nThis paper highlights the drivers and strategies of corruption (with a focus on public officials and specifically customs officials) as a facilitator of drug trafficking (with a focus on cocaine) in the Port of Rotterdam. It further considers the key challenges, opportunities and risks in efforts to address drug trafficking and border corruption. The analysis is based on a desk review, a review of drug-related corruption court cases and five interviews with key experts from academia and law enforcement (see Annex).\n\n## 2 Facilitating factors of drug trafficking and drivers of border corruption\n\n## 2.1 Facilitating factors of trafficking through the port of Rotterdam\n\n## 2.1.1 Modern infrastructure and high cargo volumes at ports\n\nThe Port of Rotterdam is the largest port in Europe. It aims to become the world's safest, most efficient and most sustainable port (Port of Rotterdam Authority, n.d.-a). This is reflected in a modern logistical and digital infrastructure, allowing fast processing of cargo containers (Staring et al., 2019; Zürcher et al., 2024).\n\nAn important point is that trafficking takes place on the back of legal trade routes (Staring et al., 2019; Zürcher et al., 2024; Staring et al., 2023). Commercial ports are especially attractive because of the high cargo volumes they process and the possibility to conceal illicit cargo under licit cargo. It is more difficult to detect trafficking in the case of high transport volumes (Zaitch, 2002 as referenced in Eski and Buijt, 2017), and Rotterdam has deep water channels that allow large ships with many containers to dock (Zürcher et al., 2024).\n\n## 2.1.2 Spatial and operational complexity of ports\n\nThe spatial and operational complexity of ports makes security a challenge.\n\nThe large physical size of the port of Rotterdam (over 12,500 ha), volume of goods (the cargo throughput is approximately 436 million tonnes of freight a year) and number of people working on its premises (approximately 1,400 employees work for the Port Authority alone) contribute to its vulnerability (Zürcher et al., 2024; Port of Rotterdam Authority, n.d.-b). The sheer size of the Rotterdam harbour means that it will never be totally secure (Staring et al., 2019).\n\nThis is further complicated by the fact that tensions may arise between security objectives and economic objectives in port operations - acting on suspicions of illicit activity may undermine efficiency (Costa et al., 2024). It is important to find a balance between these goals, which at times can be contradictory (Eski, 2019; Staring et al., 2019). This is especially the case in a port environment with many stakeholders and where promoting security is a shared responsibility (Staring et al., 2019). In this context, good partnerships, information sharing and robust investigation and enforcement capacity are critical but at the same time challenging (Government of the Netherlands, 2024; Spapens et al., 2021).\n\n9\n\n## 2.2 Drivers of border corruption\n\nThe Port's enforcement efforts have been bolstered by more political attention and resources, prompting criminal networks to increasingly target public officials in order to override more stringent detection measures.\n\nSince the mid-1990s, the fight against organised crime and drug production\u002F trafficking has been an important political topic in the Netherlands. More recently, there has been an important shift, as the hardening of crime is seen as having an increasingly negative impact on the rule of law and the democratic state (Government of the Netherlands, 2021). This is linked to an increased perception of the negative impact of drug-related crime (Spapens et al., 2021).\n\nIn 2021, the then government (Cabinet Rutte III) announced an extra EUR 524 million for tackling subversive crime (Government of the Netherlands, 2021). In 2024, the new government (Cabinet Schoof I) emphasised that security remains an important issue and that it would step up the fight against subversive crime by strengthening laws, detection, punishment, information exchange, the police and intelligence services, and tackling international criminal activity and related corruption (Government of the Netherlands, n.d.-a).\n\nStronger political prioritisation and resources have resulted in the ability of the port of Rotterdam to strengthen its efforts to prevent and curb trafficking. A focus has been on improving technology, digitisation and automation of processes (including the robotisation of container transport). Security is promoted through the use of modern technologies, such as 'port keys' , 'digital safety passports' and 'cargocards' , which store biometric data of key players in the logistics chain, information on commercial vessels, containers and the companies that are behind the delivery and logistics (Oosting, 2016 as referenced in Staring et al., 2019).\n\nEnforcement has been similarly strengthened. A key initiative is the Hit and Run Cargo (HARC) team, a partnership between Dutch Customs, the Public Prosecution Service, the Seaport Police and the Fiscal Information and Investigation Service (FIOD). The HARC team specialises in investigating and prosecuting drug smuggling and criminal networks and their activities in and around the port of Rotterdam. It was set up over 25 years ago specifically to combat drug trafficking in Rotterdam through joint intelligence gathering (Customs Administration of the Netherlands, n.d.-a; Netherlands Public Prosecution Service, n.d.). The HARC team is responsible for most of the drug seizures in the port (Staring et al., 2019).\n\n## 2.3 More obstacles create greater need for corruption\n\nAs increased obstacles make trafficking more difficult, an increased need for corruption emerges.\n\nWhereas previously the likelihood of drugs being detected was perceived as relatively low (Staring et al., 2019), this seems to have changed. The ability\n\nto detect drugs has been strengthened through increased risk analysis and surveillance (Nelen and Kolthoff, 2017). For instance, in 1994, 0.1 percent of cargo was checked. By 2019, this had increased to 0.5 percent (Staring et al., 2019). This approach is paying off. In an interview in 2021, the head of the Seaport Police noted that intensified efforts were leading to more drug seizures (Port of Rotterdam Authority, 2021). Mid-2023 saw the largest drug seizure ever made (Netherlands Public Prosecution Service, 2023).\n\nNow, the combined force of political prioritisation and strengthened detection and automation has increased the potential to disrupt drug trafficking. An unintended consequence is that from the perspective of the drug traffickers, having accomplices embedded inside the port operations has become increasingly important, if not indispensable. This has been recognised by the Dutch Public Prosecution Service and other sources (Roks et al., 2021; Sergi, 2020; KPMG, 2021; Staring et al., 2019, 2023; Netherlands Public Prosecution Service, 2025).\n\n'If everything works as it should, it is impossible to traffic drugs through the port. To do this, you need some inside help. There is always a corrupt insider who facilitates trafficking.'\n\nInterview with a law enforcement stakeholder, 16 July 2024\n\nFacilitating factors of trafficking\n\n- ·  Illegal trade latches onto legal trade\n- ·  Complexity of port makes security challenging\n\nDrivers of border corruption\n\n- ·  Fighting drug trafficking as a political priority\n- ·  Strengthening detection and automatisation to prevent crime\n\nFigure 1: Intensified efforts to fight drug trafficking can lead to a rise in corruption risks.\n\nCollusion\n\nCoercion\n\nInfiltration\n\nIncreased potential for disruption of drug trafficking\n\nIncreased need for insider help: corruption increases\u002Fadapts\n\n## 3 Strategies of border corruption\n\n## 3.1 Involvement of organised crime networks\n\nOrganised crime networks are involved in the illicit drug trade. A key modus operandi is that cocaine is trafficked by sea from Latin America (i.e. Ecuador, Peru, Venezuela, Colombia and Bolivia) to Europe via the port of Rotterdam. The Netherlands is predominantly a transit country. A common strategy is that the drugs latch onto fruit transports, which require swift processing (Staring et al., 2019; Trimbos Instituut, 2025).\n\nThe crime networks are ethnically heterogeneous and have 'a small core and informal, flexible structures' (Staring et al., 2019). They have been likened to logistics companies in that they are organised as professional organisations which focus on security, transport and development. For specialised tasks, they can call on specific people or involve people with specific skills, such as money laundering (Staring et al., 2019, 2023).\n\nBuilding trust and ensuring loyalty is important, so social ties such as family and friends can be a way of bringing people into the network. Robust and solid social connections can also form through shared social spaces, as well as through professional ties such as working together in the port (Staring et al., 2019, 2023). One example of this dynamic is that social ties between groups in the Netherlands and Latin America may help organised crime groups to connect across large geographical areas (Burt, 1992 as referenced in Madarie and Kruisbergen, 2019).\n\nA researcher interviewed for this study suggests that there is no overarching criminal organisation that facilitates access to the port. Instead, different criminal networks have to find their way into and through the port by cultivating relevant relationships through bribery (interview of 5 April 2024). Research shows that several transnational criminal groups - including Italian, British, Albanian and Dutch groups - have cocaine distribution lines through the Netherlands to various countries (Dirksen et al., 2021). Even if their interests and goals differ, criminal networks cooperate (Costa, 2022).\n\nThe multidimensionality and fluidity of the cocaine trafficking networks make efforts at eliminating them inherently difficult, as illustrated by the case discussed in the box below.\n\n## The case of Ridouan Taghi\n\nRidouan Taghi, the leader of the largest drug cartel in the Netherlands, is a key figure in what is arguably the biggest drug trafficking operation in Europe. He was sentenced to life imprisonment in the Netherlands'\n\nMarengo trial, which was the country's most prominent mass trial involving his criminal organisation.\n\nAt his peak, Taghi imported an estimated third of all the cocaine entering the Netherlands through Rotterdam's port. He worked with some of Europe's largest trafficking networks, including the Italian Camorra mafia and the Irish Kinahan crime group, and each group benefitted from the others' contacts. Taghi's deputy lived in Colombia and organised the export of cocaine to Europe, allegedly by buying it from the Gaitanistas (Autodefensas Gaitanistas de Colombia).\n\nSeveral other members of Taghi's network were arrested in Latin America, the Caribbean and in Suriname. Despite the arrest of the leader and others, the network and infrastructure established continued to allow the importation of cocaine. A former associate of Taghi, Leijdekkers, is said to have taken over the network and was found guilty in absentia of international cocaine trafficking and ordering an assassination.\n\n(Sources: Held, 2024; Holligan, 2024; Booty and Bamford, 2025; NL Times, 2024a)\n\n## 3.2 Crime networks and evolving corruption practices\n\nCriminals use a variety of methods to move drugs into and through the port with the aim of ensuring that they will not be detected or confiscated. There are two major bottlenecks in the transit of drugs: getting the drugs into and out of the port. It is at these two points that trafficking most heavily relies on corruption to evade detection and monitoring (Staring, 2021; Madarie and Kruisbergen, 2019).\n\n## 3.2.1 Aim of corruption: evading monitoring and surveillance\n\nFor organised crime networks to overcome bottlenecks in drug trafficking, to pass surveillance and get drugs out of the container and out of the port, they need information on logistical processes in the port.\n\nWhile several public agencies are involved in fighting crime, 1  the role of customs stands out as they are tasked with monitoring the import and export of goods, making them crucial stakeholders in the fight against drug trafficking (Staring et al., 2019). The customs authority carries out a wide range of monitoring,\n\nsignalling and investigative tasks (Port of Rotterdam Authority, 2022).  Of the 7.5 million containers that pass through the port each year, 40,000 are scanned and 6,500 are opened, with checks based on risk profiles (Staring et al., 2019).\n\nAs detection activities are strengthened, the need for inside help increases, as do the risks for corrupt engagement of customs officers (KPMG, 2021). Customs officers become vulnerable to corruption because, by virtue of their position, they have important knowledge about processes and procedures, access to systems and discretionary power. Customs officers in strategic positions become a particular focus of attention: personnel with knowledge and authorisation to perform risk analyses, and those carrying out checks, such as scan analysts and sniffer dog handlers. As automation means that information is increasingly stored in databases, customs officers with access to these equally become key (KPMG, 2021).\n\n## 3.2.2  Corruption to get drugs into the port\n\nTo ensure drug shipments can get into the port and pass locations of surveillance, criminal actors use corruption to circumvent or avoid control. They bribe staff for knowledge about the logistics and monitoring process. This includes information about pre-arrival risk analyses, scheduled container checks and container locations, and confidential customs information regarding modus operandi of screenings and general weaknesses in the monitoring system. Bribery is similarly used to co-opt public officials who can help evade controls completely, for example by transferring drugs into safe containers that have already been checked or concealing discoveries (Staring et al., 2019).\n\nThe most infamous and illustrative corruption case involving drug trafficking through the port of Rotterdam involves a customs officer working as a selector in the pre-arrival section of customs. The official decided which containers would be checked and how. In return for bribes amounting to millions of euros, he would provide criminal groups involved in drug trafficking with information on the location and status of particular containers, and would ensure that certain containers were not checked. One way he did this was by marking a container as cleared, stating that the bill of lading had been requested and checked. The officer also provided information on risk profiles used in the selection process. In 2017, the official was sentenced to 14 years in prison (Roks et al., 2021; Staring et al., 2019; Sonnemans, 2017).\n\nIn another example, a customs official was bribed to provide information regarding confidential customs information, including modus operandi regarding the import and the screening of the sending and receiving companies (Judicial case 2019:1103).\n\nOther examples of past corrupt acts by customs officers to evade monitoring and surveillance (see KPMG, 2021) include:\n\n- · falsely clearing containers for import without inspection;\n- · facilitating drugs to be moved to a container that has already been inspected;\n- · failing to (fully) inspect containers marked as high risk;\n- · designating many containers for inspection, thereby ensuring that there is not enough capacity to inspect a container containing drugs.\n\n## 3.2.3  Corruption to get drugs out of the port\n\nCorruption also facilitates the exit of drugs from the port. Officers can be bribed to provide information on container location, allow access to the port or the premises where the container is located, move containers to a place where drugs can be more easily extracted, or extract the drugs from the container themselves (Staring et al., 2019; KPMG, 2021).\n\nThis relates to two specific methods to remove drugs from containers:\n\n- · the 'rip-off method' , where the drugs are removed from the container and out of the port before an inspection; and\n- · the 'switch method' where the drugs are switched out to a container that has already passed inspection or is not planned for inspection.\n\nAs an example, in one case a customs official was accused of accepting a bribe to divert the physical shipment of a consignment outside the customs territory to the warehouse of the forwarding company involved in the shipment. In this case, 26 kilos of drugs were later found in the container (Judicial case 2019:1103).\n\n## 3.2.4  Typology of corruption aims at border spaces\n\nAcross the above examples and cases, a typology of corruption aims at border spaces emerges. Corruption, and bribery in particular, permits criminal actors to obtain key information or direct assistance needed to pass through the two main bottlenecks in the port, the container screening and security as cargo enters the port, and the extraction of drugs from the port.\n\nThe key difference between information and direct assistance is the degree of active involvement of the customs official:\n\n- · Providing information - e.g. about the logistics and monitoring process - is a more indirect, passive involvement. It can help criminal networks prepare and conceal illicit cargo so it's not detected.\n\n- · Direct help in avoiding detection or moving goods - e.g. clearing a container as compliant without inspection or opening the gate to provide access to port premises containing containers with hidden drugs requires a more active collaboration.\n\nFigure 2: Typology of corruption aims at border spaces.\n\n|                               | Getting drugs into the port and past  screenings and security                                                                                                                                   | Getting drugs safely out   of the port                                                                                                                                        |\n|-------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| Obtaining  information        | Corruption to obtain information from  customs officials, e.g. on the criteria  and red flags used by customs for  cargo screening, and on how to hide  drugs in containers to avoid detection. | Corruption to obtain information from  customs officials, e.g. about the location  of containers marked for full inspection  to ensure that drugs can be removed  beforehand. |\n| Obtaining  direct  assistance | Corruption to get direct help from  customs officials to avoid detection of  the drugs. E.g. Official ensures a specific container                                                              | Corruption to get customs officials to  facilitate the extraction of the drugs. E.g. Official provides illegal access to   port premises so criminals can secure              |\n\n## 4 Corruption networks: collusion, coercion and infiltration\n\n## 4.1 Building corruption networks\n\nA key theme in this research is the networked nature of crime. Criminal networks often exploit social networks - i.e. networks within the informal and social spheres - to cut across the public and private divide. These social networks are primarily strategic - they are built to facilitate trafficking. Trust and loyalty are crucial, so criminal networks may turn to family and friends where possible. But even without such pre-existing personal ties, officials can be co-opted, and sociality then built up, for example through the reciprocal and repeated exchange of bribes. The ultimate goal is to build a relationship that includes the social elements of expectation of reciprocity, obligation to the group and loyalty (Basel Institute on Governance, 2024; Jancsics and Costa, 2024; Baez-Camargo et al., 2023; Costa, 2022).\n\nOn the basis of the conceptual model by David Jancsics, we can broadly characterise the corrupt relationships that emerge between officials and criminal organisations as either collusive or coercive. In collusive relationships, the engagement between the public official and the criminal organisation is framed as mutually beneficial (offering\u002Fselling information or providing direct help). In contrast, coercive relationships involve pressure or threats, where the public official is forced to cooperate and provide information or help (Jancsics, 2019; Abdou et al., 2024).\n\n## 4.2 Collusion\n\nCustoms officials may offer their services or be lured into collusion by criminals. Motivations are complex. Customs officials in financial difficulty are more likely to become involved with organised crime groups, but corrupt behaviour may also be driven by a desire for a more adventurous or luxurious lifestyle (KPMG, 2021; Nelen and Kolthoff, 2017).\n\nCollusion can be opportunistic or targeted. Because trust is so important in an illicit arrangement, a key modus operandi is to enlist accomplices opportunistically from existing social networks, for example via family connections, involvement in sports clubs or having attended the same schools. A more targeted approach may involve identifying customs officials, establishing contact with them outside the work environment and attempting to to co-opt them into the criminal network through bribery (KPMG, 2021).\n\nBecause criminals employ and proactively build their social networks, it is common for criminals and customs officials to know each other. Strong bonds within family and friendship networks and norms of solidarity may in turn exert\n\ninformal pressure on the official to help and remain loyal, thus reinforcing incentives for the abuse of power (KPMG, 2021; Nelen and Kolthoff, 2017).\n\nIn relation to the port of Rotterdam, Staring et al. (2023) highlight that family and friendship ties are important factors that facilitate co-optation, but the most important factor is access to and knowledge of the port and control systems. The mixing of professional embeddedness and social networks, and opportunistic and targeted co-optation is highlighted in some recent corruption cases involving customs officials and drug trafficking:\n\nIn one case, a customs officer was approached by two men involved in large-scale drug smuggling through his wife's brother. During a meeting at a petrol station on the motorway, the two men told the customs official that they wanted to work together (van Gestel, 2019). Another case involved a trafficker approaching the son of a customs official to provide information on containers, who in turn sought the information from his mother (Netherlands Public Prosecution Service, 2024a). This shows that vulnerability to corruption can extend beyond the public official to their family and friends.\n\nIt is expected that the use of social networks of family and friends or online platforms such as social media to establish connection with officials will increase. Criminal networks analyse publicly available information on officials' work and private lives to assess potential targets. In response, a key measure of the Rotterdam port's anti-corruption approach is to advise officials not to post work-related photos on social media, as this can make them a target for criminal organisations (Rotterdamse Haven Veilige Haven, n.d.).\n\nAnother tactic is to target and develop ties with multiple officers simultaneously, in order to spread opportunities and risks. A case involving a customs official illustrates this strategic targeting: the official provided a criminal organisation with a list of the names and contact details of fellow customs officials working on scanning containers (Judicial case 2020:12597).\n\n## 4.3 Coercion\n\nCustoms officials can also be coerced into corrupt activity. They may be initially lured with a financial reward but intimidation and the threat of violence can ensure continued cooperation (KPMG, 2021; Sergi, 2020; Europol, 2023). In this regard, Rotterdam's head of the Seaport Police discussed the threat of violence and intimidation to provide information to criminal networks, saying: 'If you don't say yes the first time, when you're in the shop doing your shopping, they'll throw it into your cart again and maybe try a third time to offer you the money.\n\nThere are [also] cases, of course, [where] then they tell people, 'We know where your kids are going to school.'' (May and Holcova, 2023).\n\nCoercion is a dynamic issue. On the one hand, Staring et al. (2023) highlight in their analysis of 10 drug-related cases in the port that excessive violence is 'less emphatically and naturally present' . On the other, research also shows that organised crime has hardened over the years, increasingly using violence and intimidating public officials (Nelen and Kolthoff, 2017).\n\nIntimidation is achieved through blackmail, threat of violence against the officer or their family or creating financial pressures by offering attractive loans (KPMG, 2021). For example, in one case, an official working for the tax agency provided sensitive personal information to members of a crime group involved in drug trafficking who could then use this information to put the targeted person under pressure to comply (Judicial case 2020:1295).\n\nIt is important to recognise that the actual boundaries between collusion and coercion are blurred. Rather than seeing collusion and coercion as separate phenomena, it is better to see them on a continuum, with at one extreme the public official offering and selling information and at the other extreme the criminal actor extorting cooperation through the use of force. Within this continuum, there are various degrees of collusion and coercion. What remains constant is the power imbalance, the exchange of resources for assistance and the relationship's longevity.\n\n## 4.4 Infiltration\n\nInfiltration takes the dynamics of collusion and coercion a step further by completely erasing the boundary between public and private power. It occurs when an individual closely associated with or directly involved in illicit activities proactively acquires the formal position of a public official. Criminals may attempt to infiltrate public and private offices in the port area and embed themselves into the community of personnel through formal employment processes. This provides an opportunity to obtain and share relevant information, establish links with others in the port and, if promoted to a higher position, ensure that other members of the criminal network join the organisation.\n\nThere are documented examples of people associated with criminal groups being sent to police or customs training programmes with the specific aim of making a career in these organisations (KPMG, 2021; Europol, 2023). Through long-term strategies such as these, criminal networks can enlarge and conceal their reach into public office by leveraging social capital (Costa, 2017).\n\nIn one interview, a researcher suggested that infiltration is the most worrying form of corruption because it is more structural and invisible, and it reduces\n\nthe risk of being caught. It transgresses the boundaries between the criminal, public and private. In the long term and in its more extreme and structural forms, infiltration may look less like corruption and more like regulatory capture, where the public office position is held by a member of the criminal network. This means that a system is created or manipulated to work every single time, without the need of bribery or other forms of influence, but through the legal channels (interview of 5 April 2024).\n\nAnother researcher noted that infiltration is still poorly understood because it is mistakenly assumed that it occurs only in settings with weak governance. It is essential to gain a deeper understanding of this kind of long-term and strategic investment - which differs greatly from one-off and opportunistic engagement if efforts to understand and curb border corruption are to succeed (interview of 12 April 2024).\n\nIncreased potential\n\nfor disruption of drug\n\ntrafficking\n\nA court case (Judicial case 2020:12597) involving an intercepted conversation between a customs official and a member of a criminal organisation illustrates how infiltration can unfold. The customs officer had previously worked in the pre-arrival department, which is responsible for organising maritime inspections of incoming cargo traffic, but no longer held that function. The member of the criminal network explained that he had organised every aspect of a drug import, except how to bypass the container scan. He suggested that the customs officer should try to resume work in this department, find a relevant connection there, or even apply for other positions relevant to container scanning. If she succeeded, he said, she would have 'gold' in her hands, promising EUR 1 million for each successful job. It was found that the customs official did potentially try to assist, as a printed list of the names of officials working in the scanning section was found at her home. Drivers of border corruption ·  Fighting drug trafficking as a political priority ·  Strengthening detection and automatisation to prevent crime Facilitating factors of trafficking ·  Illegal trade latches onto legal trade ·  Complexity of port makes security challenging\n\nThis example shows how collusion, coercion and infiltration cutting across the public-private divide can blend together in practice. The criminal entices the official with the promise of money, while at the same time pressuring her to explore ways to rejoin the scanning team. In doing this, he attempts to strategically position her to help the criminal network to avoid inspections, or to provide information on who might be involved in the container scanning position. The lure of financial gain is key, but other forms of pressure are not excluded. The overarching observation is that networked corruption is multifaceted and adaptive. Moreover, once cooperation is established, the corrupt relationships are long-lasting.\n\nFigure 3: The lines between collusion, coercion and infiltration are often blurred.\n\n\u003C!-- image -->\n\nIncreased\n\nfor insider\n\ncorrupti\n\nincreases\u002Fa\n\n## 5 Bribery and money laundering\n\nThis section focuses on understanding the private gains associated with border corruption. The guiding question was simple: how do public officials receive a bribe and how do they launder the proceeds? To gain clarity on this question, an analysis was conducted of judicial cases (published online at rechtspraak.nl, the website of the courts, appeal courts and special courts in the Netherlands). The focus was on ongoing or completed cases involving bribery of public officials working in the port, including both acquittals and sanctions. The following search terms were used to identify relevant cases:\n\n- · An all-fields search with the keywords 'corruption Rotterdam harbour' and 'customs' combined with a content indication search for 'money laundering' resulted in 13 cases. 2\n- · A search with the keywords 'corruption' and 'customs' in the content indication field alone resulted in two additional cases. 3\n\nThe analysis aimed to provide insights into the dynamics of bribery and the money laundering strategies involved, with a focus on bribes made to the public officials, and how that money is hidden and used. Often, the flows and strategies overlap (Abdou et al., 2024). Research shows that, in contexts where criminal networks are pervasive, earning a good salary is not sufficient to discourage corrupt behaviour (Baryal, Patang and Sharaf, 2022; Chalendard et al., 2023; Chêne, 2018; McLinden and Durrani, 2013).\n\n## 5.1 Bribe payments in line with the high profits of drug trafficking\n\nThe large profit involved in drug trafficking means that bribes can be very high, too. A report from Europol (2023) shows that bribes are often hundreds of thousands of euros, with the highest amounts paid to those in critical roles either in kind with a part of the cargo load or as a percentage of the drug value.\n\nIn the port of Rotterdam, similar patterns are observed. In fact, the bribes may be even higher, reaching into the millions. Public officials are promised or given a financial gift (private gain) with the understanding that they will abuse their power, by providing information, doing something or failing to act. Bribes are given in various forms, one of which is money.\n\nFor example, in one case a customs official working as a selector in the pre-arrival department of customs allegedly supported a criminal network to traffic drugs through the port. The official is accused of accepting gifts ranging from half a million to almost a million euro, promises of future gifts amounting to EUR 3 million, or a sum equal to 7.5 percent of the value of cocaine in containers (Judicial case 2017:5125).\n\nIn another case involving a member of a criminal network trafficking drugs through the port, the defendant stated that the payments amount to 'two million for the strepen [custom officials] and half a million for the business, logistics and 'the guys who unload the stuff, the stashes'' (Judicial case 2020:1295). Bribes can also be paid in different forms, such as in drugs or assets (Judicial case 2023:15351).\n\n## 5.2 Social and financial strategies for money laundering\n\nRegardless of the form a bribe is paid in, the proceeds must be integrated into the financial system without attracting attention. This is where money laundering strategies become essential. Cash is king and a necessity. Criminal money is linked to cash, not only because bribes are commonly paid in cash, but because using cash helps to avoid detection in a context of increasing banking surveillance. In the Netherlands, giro accounts are closely monitored. There was even an initiative - ultimately rejected - to monitor all transactions of over EUR 100 (Bolsius, 2022). This surveillance pushes corrupt actors to adapt by prioritising physical cash or employing elaborate strategies to launder their proceeds.\n\nMoney laundering is about obscuring the illicit origin of money with intent. For example, in one case, a customs official in Rotterdam was accused of habitual money laundering of various sums totalling almost EUR 700,000 (Judicial case 2019:1103).\n\nThe cases reviewed illustrate three important strategies in money laundering:\n\n- 1. The illicit origin of the money is disguised by making it appear to come from a licit source.\n- 2. The money is hidden with the help of family and friends or the inner circle, and\u002For by enlisting the help of professional specialists.\n- 3. The money is hidden at home in cash or invested in assets and businesses in the Netherlands or abroad.\n\nThe first strategy is to make it seem as if the bribe money has a legal origin . The cases reviewed show that, when money laundering suspects are found with unexplained funds, they are asked to explain the money's source - regardless of whether the exact amount of the bribe is known. There are two main responses:\n\neither suspects refuse to answer or they provide explanation for all or part of the money, which can lead to other charges such as tax evasion.\n\nFor example, in a case involving a corrupt customs agent working at the port of Rotterdam, the accused claimed that the excess money came from various sources: his mother, online second-hand sales, casino or lottery winnings (in the order of a few thousand euros), and regular gifts from his father - a one-off donation, and cash money that was spent on domestic help and food payments (Judicial case 2019:1103).\n\nIn another case the accused explained the money's origin as having come from: winning the lottery, business activities (cafes or thrift shops) and paid work (Judical case 2022:5588).\n\nThe second strategy is to hide bribe money with the help of trusted networks and\u002For professional specialists . Both cash and bank-based funds can be hidden with family members, friends or those who are part of the criminal network. These individuals 'keep' the money for the public official (Judicial case 2020:1295).\n\nMore elaborate concealment may involve enlisting the support of professional enablers to move money out of the Netherlands. Lawyers or financial specialists can play an important role in facilitating money laundering.\n\nFor example, a recent case reported by Dutch media shows how an underworld banker used 'encrypted communications to manage a courier network in the Netherlands, moving nearly a quarter of a billion euros in cash for criminals between June 2020 and March 2021' (NL Times, 2024b).\n\nInterviews with stakeholders confirm that money is moved out of the Netherlands using networks of underground banking and\u002For money mules (interviews of 4 April 2024, 5 April 2024, 12 April 2024 and 16 July 2024).\n\nThe third strategy is to hide cash or convert cash into assets . Cash may be hidden at home or in safes, exchanged for other currencies or invested in assets and businesses (Judicial case 2020:918).\n\n## Examples include:\n\n- · Buying luxury items such as expensive watches. In 2023 the Hit and Run Cargo (HARC) team seized more value in luxury designer clothes and accessories than cash (Netherlands Public Prosecution Service, 2024b).\n- · Investing in high-value assets such as (vacation) houses, cars and boats, in the Netherlands or abroad. In 2024, HARC confiscated over half a million euros in cars and boats (as well as over EUR 400,000 in cash) (Netherlands Public Prosecution Service, 2025).\n- · Investing in businesses in the Netherlands or abroad, which may involve complex financial structures, or purchasing cryptocurrencies. Financial advisers may assist in establishing business structures that allow money from illegal and legal sources to be mixed (Unger et al., 2018; Pol, 2016).\n\nCash purchases are restricted in the Netherlands. For example, one cannot buy a house with cash, and transactions above EUR 10,000 should trigger a client investigation (Government of the Netherlands, n.d.-b). To tigthen the rules even further, a new law is in the making to lower the maximum allowed cash payment to EUR 3,000 (Tweede Kamer der Staten-Generaal, 2022). Nevertheless, Unger et al. (2018) find that high-value goods can still be acquired with cash by paying an additional 10-20 percent of the value to avoid the purchase being reported.\n\nCriminals find ways to creatively avoid the rules. This not only undermines the intent of the legislation but also enables a steady stream of illicit money to infiltrate the Dutch economy. The impact is significant: of EUR 13 billion in laundered money generated in the Netherlands in 2014, 53 percent, or EUR 6.9 billion, remains in the Netherlands. These funds are then laundered into the formal economy, frequently with the assistance of financial advisors (Unger, et al. 2018). Beyond the economic impact, the key point of concern is that crime money can be used to finance further crime and, by extension, undermines the rule of law and the democratic state.\n\n## 6 Adaptive criminal and corruption strategies to facilitate drug trafficking\n\n## 6.1 Trafficking and corruption strategies follow the path of least resistance\n\nTrafficking and corruption strategies are not static. An important insight from this study is that criminal and corrupt strategies used to facilitate drug trafficking are highly adaptive, multifaceted and change quickly in response to increased enforcement efforts (Interview of 5 April 2024). Critically, criminal activity will follow the path of least resistance (Costa et al., 2023). This means that when met with obstacles, illicit and corrupt activities will:\n\n- · move to different spaces and use different routes (Augustova and Suber 2023);\n- · become more creative and more difficult to detect (Ortiz 2021); and\u002For\n- · involve new actors and functions via corruption and bribes (Europol, 2023).\n\nThe underlying driver of this adaptability is the unchanging demand for drugs and the high profitability of the crime. This incentivises traffickers to adopt new strategies to overcome hurdles in supplying the demand. In one interview, a law enforcement stakeholder noted that both drug production and demand are rising, and with them, the profits to be made (interview of 16 July 2024). The falling price of cocaine is another signal of its ready availability (NL Times, 2025).\n\n## 6.2 Corruption strategies are adaptive\n\nAt the port of Rotterdam, increased political attention and resources to combat trafficking have led to enhanced detection systems and technology. These efforts have raised the risk of detection for traffickers, making the co-optation of public officials to override the stricter controls more appealing.\n\n## 6.2.1 Stronger detection systems increase the incentives for and risk of corruption\n\nThe unintended consequence of strengthened controls is that criminals become more reliant on inside help to facilitate trafficking (Staring et al., 2019). This is complex to measure. A study testing whether more effective detection and enforcement actors are more susceptible to corruption was unable to robustly confirm the hypothesis (Rovers and Moors, 2019). In addition, comparing the number of cases of corruption that facilitated drug trafficking over time can be misleading as not all cases are detected. Moreover, in an interview, one\n\nresearcher also highlighted that our knowledge of corruption comes from criminal investigation reports. Consequently, corruption that goes undetected remains a blind spot (interview of 12 April 2024).\n\nThe prevailing consensus nevertheless is that corruption risks in relation to drug trafficking are increasing. On the one hand, as the desk research highlights, this is because strengthened enforcement makes having an accomplice on the inside necessary. On the other hand, as one of stakeholder interview suggests, if everything works as it should, it is impossible to traffic drugs through the port.  Conversely, when seizures are made, it indicates that corruption has played a part somewhere in the process. In line with this, Zürcher et al. (2024) identify bribery of law enforcement officers as the most significant drug-related corruption risk at the port. The FALCON project's examination of 19 border-corruption cases further highlights that corrupt actors are primarily motivated by the desire to secure illicit advantage or to conceal illegal activity (Paternoster et al., 2024).\n\n## 6.2.2  Corruption adapts to the adoption of new systems and processes\n\nWhile corruption may increase, it can also change: when systems become more efficient or digitised, criminal actors are also incentivised to change their corruption strategies. According to one law enforcement stakeholder, corruption has not increased, rather we are only now seeing the true extent of the problem, with corruption changing (interview of 4 April 2024). The person explained that border corruption used to mean bribing a single guard at a border crossing. Today, increasing efficiency, automation and digitalisation make that one person at the barrier irrelevant. In a port like Rotterdam, where everything is automated, corruption must evolve to target other officials, such as those with access to systems or information. 'If you make the process more complex, corruption changes' , and generates new vulnerabilities.\n\n## 6.2.3  Corruption risks profiles adapt to new control measures and shift among public officials\n\nTo overcome the bottlenecks in the port and facilitate the movement of drugs, criminal actors depend on insider knowledge of the logistical processes in the port. As controls are strengthened, including through automation, the corruption risk profiles of border staff also change. Criminal networks adapt by targeting officials with strategic knowledge and access. Customs officials are particularly important, as they monitor the import and export of goods and are key players in the fight against drug trafficking. As enforcement efforts increase, these officials become more vulnerable to corruption.\n\nIncreased awareness of this risk, partly due to reports of corruption cases, has prompted more efforts to protect customs officials from the influence of criminal organisations. For example, in 2013, a programme called Integere Haven brought the municipality, public prosecutor, police, customs, Deltalinqs\n\n(the port entrepreneurs' association) and the port authority together to promote integrity and professional behaviour in the port, amongst other things (Staring et al., 2019).\n\nAuthorities have developed stronger anti-corruption measures and reduced the discretionary power of those in high-risk positions, such as customs officials. As a result, bribing and co-opting people in these positions becomes less attractive to criminal networks (KPMG, 2021). But when barriers increase in one area, corruption risks may once again shift to a new group.\n\n## 6.2.4  Corruption morphs, blurring the lines between collusion, coercion and infiltration\n\nCorruption is functional and strategic - it helps criminal actors to solve problems and get things done. The nature of these corrupt engagements can take various forms, such as collusion, coercion and\u002For infiltration. Our research has found that as increased enforcement efforts raise incentives for corruption to facilitate trafficking, and given the relative power of criminal networks, the line between collusion and coercion can become blurred. If the promise of riches is ineffective in luring public officials, then threats and coercion can be used to increase pressure.\n\nCoercion puts officials in a lose-lose situation. If they refuse to cooperate, they may face threats from criminal networks; and if they comply with the criminal demands, they could be punished by the legal system for engaging in corruption. At the same time, officials can plausibly claim coercion even if they colluded willingly, which can complicate enforcement.\n\nThe issue is further complicated by infiltration, which collapses the boundary between public office and the criminal network. Collusion and coercion can result in public officials being co-opted. Infiltration takes this to a next level by planting members of the criminal network into public office positions.\n\nFigure 4: Corruption adapts in the face of changing enforcement.\n\n\u003C!-- image -->\n\n## 6.3 Trafficking strategies are equally adaptive\n\n## 6.3.1 Strengthened detection has impacted the number of drug seizures\n\nEfforts to combat drug trafficking at the port of Rotterdam have been intensified through enhanced detection and advanced technology. Now, for example, all shipping containers from Latin America are checked. Initially, stronger measures to counter drug trafficking led to more drug seizures (Port of Rotterdam Authority, 2021). However, in 2024 and 2025 the number of seizures dropped. Authorities equally attribute the decline to strengthened enforcement measures against drug trafficking. Similar patterns are emerging in the larger north-west European seaports (Customs Administration of the Netherlands, 2024; Appleby, 2024; European Monitoring Centre for Drugs and Drug Addiction and Europol, 2024; Global Initiative Against Transnational Organized Crime, 2024).\n\nAt first glace, one might think that the strengthened enforcement measures were successful in reducing drug trafficking. This could potentially be the case, but it may also be a premature conclusion. With consistently high demand for drugs on the market, drug trafficking is unlikely to decrease.\n\nAnother explanation may be that, as the risk of detection increased, criminal networks have adapted their trafficking strategies in response to the increased hurdles, resulting in fewer numbers of seizures with time.\n\nThere are two broad ways in which criminals may have adapted their strategies:\n\n- · Changing concealment strategies\n- · Changing modes of transport and switching trafficking routes altogether\n\n'The criminals always find the weakest spot.'\n\nInterview with a law enforcement stakeholder , 16 July 2024\n\n## 6.3.2  Changing concealment strategies\n\n## Evolving concealment methods\n\nConcealment strategies are becoming increasingly sophisticated. Recent drug seizures have seen cocaine uncovered in places more original than fruit shipments, for example, in shipments of scrap metal, wooden beams, engines, furniture, batches of spirits or timber. More intricate strategies have also been seen, including hiding drugs in the flaps of boxes of bananas, or embedding kilos of cocaine in thousands of individual boxes in a telescopic crane from South America (Netherlands Public Prosecution Service, 2025; Rotterdamse Haven Veilige Haven 2024).\n\nOne interviewer also spoke about cocaine being washed into clothes or mixed with coal or oil (interview of 16 July 2024). In a recent online interview, the head of the Seaport Police explains that liquid cocaine is especially difficult to detect:\n\nit cannot be identified by x-ray scanners or sniffer dogs, and confirming its presence can take up to two weeks in a lab (Dalby, 2024).\n\n## Spreading the risks with smaller but more shipments\n\nAlthough the total amount of cocaine seized has decreased at the port of Rotterdam, interestingly, the number of shipments intercepted has actually increased slightly. A possible explanation hints at another change in concealment strategies: trafficking networks are spreading the risk by smuggling smaller quantities in more shipments, in a strategy known as 'shrinkage' (Netherlands Public Prosecution Service, 2025; Minchin, 2025).\n\n## 6.3.3  Changing modes of transport and trafficking routes\n\n## Shifting modes of transport to avoid detection\n\nA new initiative at the port of Rotterdam seeks to make it more difficult for criminal networks to obtain the container reference codes needed to pick up containers (Europol, 2023). This initiative called the 'Chain of Trust' was developed by both government and industry actors to improve digital security of port logistics and reduce opportunities for fraud, particularly for truck-based transport (Vertrouwensketen, n.d.). 4  The aim is to ensure that the process of picking up import containers and transferring them onto trucks will be more closely monitored, so that only the authorised person is picking up the container.\n\nHowever pick-up via truck is not the only way that containers are collected and transported out of the port. One stakeholder suggested that, as truck transport is more closely monitored, traffickers potentially shift to trains. This is supported by an increase in the number of broken seals found around railway tracks (interview of 4 April 2024).\n\n## Rerouting trafficking to other Dutch ports\n\nAn increase in drug seizures at smaller ports in the Netherlands suggests the possibility that trafficking is being rerouted. It is unclear whether this links directly to increased enforcement measures in Rotterdam or is a separate phenomenon (Netherlands Public Prosecution Service, 2025; Van der Wiele, 2024).\n\n## International displacement of trafficking routes\n\nThe most significant adaptive strategy appears to be diverting drug trafficking to ports and transit points in other countries. As barriers increase in the northern ports of Antwerp, Rotterdam and Hamburg making these ports less attractive, trafficking routes are shifting towards southern points in France, Spain and Portugal, where drug seizures are increasing (Cavalari et al., 2025; Fernández, 2024).\n\ncoercion and\n\ninfiltration)\n\nCorruption\n\naims and\n\ntargets shift\n\nSimilarly, transit routes are shifting, with drugs destined for Europe being transported from Latin America through transit ports in North and West Africa (Cavalari et al., 2025).\n\nThis adaptation strategy underscores the importance of international cooperation on security and fighting crime (Staring et al., 2023).\n\nFigure 5: Strengthened enforcement also changes trafficking strategies.\n\n\u003C!-- image -->\n\n## 6.4 The problem with understanding hidden and complex corruption and crime strategies\n\nThe research highlights that drug trafficking is driven by supply and demand. As long as demand is not addressed, supply remains highly profitable. The consequences are significant. Increased barriers to drug trafficking in the port of Rotterdam have increased the need for inside help to facilitate trafficking (Staring et al., 2019). The dynamics of this corruption are complex: corruption risks rise, corruption goals and targets may change, and corruption practices may morph from collusion to coercion to infiltration. Meanwhile, traffickers adapt their strategies in terms of concealment methods and trafficking routes.\n\nThere are two overarching considerations. First, understanding the impact of stronger anti-trafficking measures on corruption and crime strategies is very complex . A discussion with a law enforcement stakeholder highlights the challenge of interpreting what it means when drug seizures are down: it could be a temporary drop, it could mean that fewer drugs are being shipped through the port of Rotterdam or that concealment methods have changed (interview of 16 July 2024). Fluctuations in the drug seizure figure alone are not an indicator of the scale of the drug trafficking problem, nor of the success of stronger enforcement efforts, as there may be many explanations at play (Staring et al., 2023). The same challenge applies when measuring corruption: the number of reported corruption cases does not accurately reflect the actual prevalence of corruption.\n\nStronger\n\nanti-corruption\n\nmeasures are\n\ndeveloped\n\nBoth drug trafficking and corruption are measured by detection, for instance, through changes in the number of drug seizures or public officials caught engaging in corruption. But the elephant in the room is that increasingly sophisticated criminal strategies can hide the real picture.\n\nIs a drop in seizure figures an indicator that trafficking has been rerouted? Or is the same volume still passing through the port with more sophisticated concealment and corruption strategies? Are adaptive strategies mutually exclusive or layered? Are they used in parallel, or is one activated only when the other has not proven feasible? Are trafficking routes really this elastic?\n\nThese questions underscore the need to continuously strengthen our ability to detect the 'red flags' of corruption and trafficking. Data-driven tools to characterise risk indicators are critical to understanding how crime and corruption strategies may be adapting (Abdou et al., 2024; Cascone et al., n.d.).\n\nThe second consideration is that both trafficking and corruption strategies are constantly evolving . This is often likened to a chess game: enforcement makes a move, the criminal networks adapt. But what seems to be emerging is more troubling. The unintended consequence of increasing barriers to drug trafficking - in a context where demand remains unchanged - is that it fuels increasingly sophisticated crime and corruption strategies that may have a greater negative impact on society. This is reflected in several key developments:\n\n- 1. The recent fall in the price of cocaine, attributed to a flooding of European markets. Seizures are increasingly considered as a cost of doing business - as pre-calculated loss (O'Keeffe, 2023).\n- 2. The hardening of crime and increasing violence associated with drug trafficking (Halsema, 2024).\n- 3. A shift in corruption practices, where the need to secure inside help can now incentivise coercion or deeper infiltration.\n- 4. The growing role of legitimate businesses and services in helping criminals evade detection and launder the proceeds of crime (Government of the Netherlands, n.d.-a).\n\nThese developments underscore the need for strategic foresight. Anticipating how crime may adapt in unexpected ways to changing anticorruption and anti-trafficking strategies is critical to the development of more robust enforcement efforts and the mitigation of negative impacts on society.\n\n## 6.5 Practitioner insights on how to deal with the adaptive nature of crime\n\nA key topic of discussion in stakeholder interviews was how best to respond to the adaptive nature of crime. These were the main ideas, complemented by further insights from desk research:\n\n- · The need for a holistic view of crime. As crime and corruption adapt, it is important to have a broad understanding of the problem. This includes recognising how smuggling can shift to other ports, utilise other modes of transport, or involve different actors. It also means a broader perception and understanding of corruption (interview of 26 March 2024).\n- · A focus on vulnerabilities. It is important to understand present and future vulnerabilities in logistics processes and strategic positions to increase port resilience rather than reacting to specific incidents. This can also improve efficiency and security (interviews of 4 April and 16 July 2024).\n- · Using data smartly. Understanding the flow of goods and profiling it in a way that can highlight anomalies is critical (interviews of 4 April, 5 April and 12 April 2024). At the same time, a focus on big data should not come at the expense of intuition, practical experience and evaluating past successes and failures (interview of 12 April 2024).\n- · Building partnerships. Cooperation, collaboration and information sharing among all public and private stakeholders and enforcement actors is crucial. Strengthening resilience to crime must be a shared goal. The complexity of the port means that security can only be achieved with multi-stakeholder partnerships, characterised by trust, communication and shared commitment to pursuing port-centric efforts (interviews of 4 April, 12 April and 16 July 2024).\n- · Strengthening strategic foresight. Technology is a double-edged sword - by the time it is adopted, it may already be outdated (interview of 5 April 2024). It is also important to look ahead and see that as one area of operations becomes more secure through enhanced processes, criminals may shift the target for corruption (interview of 4 April 2024).\n\n- · The need for robust IT security\u002Fcybersecurity. An additional issue to keep in mind is that technology and automation create new vulnerabilities, for example, through cybercrime (Staring et al., 2023). A recent case highlights the challenge. Drug traffickers hired a hacker to infiltrate the port IT network in Rotterdam and Antwerp to identify the optimal shipping containers for hiding contraband and their exact location (May and Holcova, 2023).\n\n## 7 Conclusion\n\nThis report examines the drivers and strategies of corruption as a facilitator of drug trafficking (with a focus on cocaine) in the port of Rotterdam. It shows that in the context of stronger anti-trafficking measures and unchanged demand for drugs, crime and corruption strategies follow the path of least resistance.\n\nCorruption is both strategic and functional. Social networks are built and nurtured strategically to facilitate corrupt exchanges. These networks are instrumental because trust and loyalty are important in hiding illegal behaviour. Corruption is diverse and complex, ranging from bribery and coercion to infiltration. Once established, corrupt relationships are long-lasting.\n\nA network view of corruption is critical to understanding the evolution of corrupt practices and strategies adopted to bribe public officials and launder the proceeds of crime. The money involved in these drug trafficking schemes is in the millions, so the strategies for laundering the proceeds are sophisticated. Strengthening financial investigations in drug trafficking investigations is therefore critical, as is the introduction of innovative measures such as nonconviction-based confiscation (Zürcher et al., 2024).\n\nOur research shows that both corruption and trafficking strategies are not static but rather adaptive. Increasing the barriers to drug trafficking can intensify corruption risks, change the aims and targets of corruption, and cause the characteristics of corruption to morph from collusion, to coercion or infiltration. Similarly, trafficking strategies adapt, from changing concealment strategies to changing modes of transport and using alternative trafficking routes. These in turn can increase corruption risks in other ports.\n\nConsequently, continuously strengthening a system of red flags with refined data to better characterise risk indicators is critical to enhancing efforts to curb drug trafficking. So too is leveraging anticipatory governance through strategic foresight and scenario building. Thinking about future risks helps us to implement more robust countermeasures today.\n\nThis is vital, as understanding how trafficking and corruption strategies adapt in response to increased enforcement efforts is complex, and the effects of adaptive crime strategies place ever-increasing costs to society.\n\n## Bibliography\n\nAbdou, Aly, Eszter Katona, Daniel Kofran, Viktoriia Poltoratskaya, Bence Toth, Dorina Vajda, Jacopo Costa, et al. 2024. 'Comprehensive List and Definitions of Corruption Risk Indicators.' FALCON.  https:\u002F\u002Fwww.falcon-horizon. eu\u002Fwp-content\u002Fuploads\u002Fsites\u002F6\u002F2025\u002F06\u002FFALCON\\_D2.2\\_Comprehensive-listand-definitions-of-corruption-risk-indicators\\_public.pdf.\n\nAppleby, Peter. 2024. 'What's Behind Falling Cocaine Seizures in the Netherlands and Belgium?' InSight Crime (blog). 17 July 2024. https:\u002F\u002F insightcrime.org\u002Fnews\u002Fcocaine-seizures-europe-netherlands-belgium\u002F.\n\nAugustova, Karolina, and David Leone Suber. 2023. 'The Kurdish kaçakçı on the Iran-Turkey border: corruption and survival as EU sponsored countersmuggling effects.' Trends in Organized Crime 26 (1): 48-63. https:\u002F\u002Fdoi. org\u002F10.1007\u002Fs12117-023-09484-3.\n\nBaez-Camargo, Claudia, Jacopo Costa and Lucy Koechlin. 2023. 'Informal networks as investment: A qualitative analysis from Uganda and Tanzania.' Governance 36 (4): 1165-84. https:\u002F\u002Fdoi.org\u002F10.1111\u002Fgove.12726.\n\nBaryal, Baryalai, Ghazi Patang and Sharafdin Sharaf. 2022. 'Preventing Corruption in the Customs of Afghanistan.' Integrated Journal for Research in Arts and Humanities 2 (6): 52-58. https:\u002F\u002Fdoi.org\u002F10.55544\u002Fijrah.2.6.6.\n\nBasel Institute on Governance. 2024. 'Informal Networks and Anti- Corruption' . Quick Guide 23. Basel Institute on Governance. Originally published in 2022 and updated in 2024. https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide23-informal-networks-and-anti-corruption.\n\nBolsius, Roel. 2022. 'Kabinet wil betalingsverkeer beter laten monitoren, Kamer heeft vragen.' NOS news. 12 December 2022. https:\u002F\u002Fnos.nl\u002Fartikel\u002F2456142kabinet-wil-betalingsverkeer-beter-laten-monitoren-kamer-heeft-vragen.\n\nBooty, Natasha, and David Bamford. 2025. 'Jos Leijdekkers: Wanted Dutch drug-smuggler 'is in Sierra Leone' .' BBC News, 25 January 2025. https:\u002F\u002Fwww. bbc.com\u002Fnews\u002Farticles\u002Fcn4z79eedvpo.\n\nCascone, Georgia, Caterina Paternoster, Michele Riccardi, Bence Tóth, Claudia Baez-Camargo and Jacopo Costa. n.d. 'High-Level Corruption: an Analysis of Schemes, Costs and of Policy Recommendations. Policy Brief of Project FALCON.' Milan: Transcrime - Joint Research Centre on Innovation and Crime. https:\u002F\u002Fwww.falcon-horizon.eu\u002Fwp-content\u002Fuploads\u002F sites\u002F6\u002F2025\u002F03\u002F2025\\_03\\_10-FALCON-Policy-Brief\\_final.pdf.\n\nCavalari, Marina, Alicia Florez, Juliana Manjarrés and Christopher Newton. 2025. 'InSight Crime's 2024 Cocaine Seizure Round-Up.' InSight Crime (blog). 7 May 2025. http:\u002F\u002Finsightcrime.org\u002Fnews\u002Finsight-crimes-2024-cocaine-seizureround-up\u002F.\n\nChalendard, Cyril, Ana M Fernandes, Gael Raballand, and Bob Rijkers. 2023. 'Corruption in Customs.' The Quarterly Journal of Economics 138 (1): 575-636.  https:\u002F\u002Fdoi.org\u002F10.1093\u002Fqje\u002Fqjac032.\n\nChêne, Marie. 2018. 'Corruption at Borders.' Anti-Corruption Helpdesk Brief. Knowledge Hub. https:\u002F\u002Fknowledgehub.transparency.org\u002Fassets\u002Fuploads\u002F helpdesk\u002FCorruption-at-borders-2018.pdf.\n\nCosta, Jacopo. 2017. 'Networks and illicit associations in corrupt exchanges: representing a gelatinous system in Italy.' Global Crime 18 (4): 353-74. https:\u002F\u002F doi.org\u002F10.1080\u002F17440572.2017.1332594.\n\n--- . 2022. 'Structures, functions and flows of IWT: deconstructing a criminal network between East Africa and Southeast Asia.' Crime, Law and Social Change 77 (5): 577-601. https:\u002F\u002Fdoi.org\u002F10.1007\u002Fs10611-021-10009-8.\n\nCosta, Jacopo, Claudia Baez-Camargo, Saba Kassa and Robert Lugolobi. 2023. 'The role of informal networks in promoting illegal wildlife trade: a qualitative analysis from Uganda.' Trends in Organized Crime 26 (4): 397-419. https:\u002F\u002Fdoi.org\u002F10.1007\u002Fs12117-021-09433-y.\n\nCosta, Jacopo, Noémi Jäger and Claudia Baez Camargo. 2024. 'AntiCorruption Legislative Measures and International Policy Landscape.' FALCON. https:\u002F\u002Fwww.falcon-horizon.eu\u002Fwp-content\u002Fuploads\u002Fsites\u002F6\u002F2025\u002F06\u002F FALCON\\_D2.5\\_Anti-corruption-legislative-measures-and-international-policy-landscape\\_public.pdf.\n\nCustoms Administration of the Netherlands. 2024. 'Barrières in de havens helpen: Douane onderschept minder drugs in eerste halfjaar 2024 Nieuwsbericht - Over de Douane.' Nieuwsbericht. Ministerie van Financiën. 9 July 2024. https:\u002F\u002Fwww.overdedouane.nl\u002Factueel\u002Fnieuws\u002F2024\u002F07\u002F halfjaarcijfers-2024\u002Fhalfjaarcijfers-2024.\n\n--- . n.d.-a. 'Samenwerking in HARC - Verdovende middelen - Over de Douane.' Onderwerp. Ministerie van Financiën. Accessed 17 June 2025. https:\u002F\u002F www.overdedouane.nl\u002Fonderwerpen\u002Fverdovende-middelen\u002Fsamenwerken-bijaanpak\u002Fsamenwerking-in-harc.\n\n--- . n.d.-b. 'Programma Weerbare Haven Terminals in strijd tegen ondermijning - Werk van de Douane - Over de Douane.' Webpagina. Ministerie van Financiën. Accessed 17 June 2025. https:\u002F\u002Fwww.overdedouane.nl\u002Fwerkdouane\u002Fsamenwerkingspartners\u002Fsamenwerkingsverbanden\u002Fweerbare-havenspps.\n\nDalby, Chris. 2024. 'Liquid Cocaine and Liquid Meth - The New Winning Strategy for Drug Traffickers.' Seasons of Crime (blog). 21 May 2024. https:\u002F\u002F www.seasonsofcrime.com\u002Fp\u002Fliquid-cocaine-and-liquid-meth-the.\n\nDirksen, Vanessa, Wouter van der Leest and Irma Vermeulen. 2021. 'Netwerken van netwerken in transit: De doorvoer van cocaine via Nederland.'\n\nTijdschrift voor Criminologie 63 (2): 129-45.\n\nEski, Y. 2019. 'Tussen wal en schip: Etnografische inzichten in lokale havenbeveiliging.' In Criminaliteit en veiligheid in mainports, 45:52-68. 2019. WODC. https:\u002F\u002Frepository.wodc.nl\u002Fhandle\u002F20.500.12832\u002F814.\n\nEski, Yarin, and Romano Buijt. 2017. 'Dockers in Drugs: Policing the Illegal Drug Trade and Port Employee Corruption in the Port of Rotterdam.' Policing: A Journal of Policy and Practice 11 (4): 371-86. https:\u002F\u002Fdoi.org\u002F10.1093\u002Fpolice\u002F paw044.\n\nEuropean Monitoring Centre for Drugs and Drug Addiction and Europol. 2024. 'EU Drug Markets Analysis 2024: Key insights for policy and practice.' https:\u002F\u002Fwww.emcdda.europa.eu\u002Fpublications\u002Feu-drug-markets\u002Fanalysis-keyinsights-policy-and-practice\\_en.\n\nEuropol. 2023. 'Criminal networks in EU ports. Risks and challenges for law enforcement.' Joint Report of Europol and the Security Steering Committee of the Ports of Antwerp, Hamburg\u002FBremerhaven and Rotterdam. https:\u002F\u002Fwww. europol.europa.eu\u002Fcms\u002Fsites\u002Fdefault\u002Ffiles\u002Fdocuments\u002FEuropol\\_Joint-report\\_ Criminal%20networks%20in%20EU%20ports\\_Public\\_version.pdf.\n\n--- . 2024. 'Decoding the EU's Most Threatening Criminal Networks.' Luxembourg: Publications Office of the European Union. Accessed 17 June 2025. https:\u002F\u002Fwww.europol.europa.eu\u002Fcms\u002Fsites\u002Fdefault\u002Ffiles\u002Fdocuments\u002F Europol%20report%20on%20Decoding%20the%20EU-s%20most%20 threatening%20criminal%20networks.pdf.\n\nFernández, Beatriz Vicent. 2024. 'Spain Reclaims Position as Cocaine Gateway to Europe.' InSight Crime (blog). 30 October 2024. http:\u002F\u002Finsightcrime. org\u002Fnews\u002Fspain-reclaims-position-as-cocaine-gateway-to-europe\u002F.\n\nGlobal Initiative Against Transnational Organized Crime. 2024. 'European Drug Trends Monitor' . Issue No. 1. https:\u002F\u002Fglobalinitiative.net\u002Fwp-content\u002F uploads\u002F2024\u002F12\u002FObservatory-of-Organized-Crime-in-Europe-European-DrugTrends-Monitor-Issue-1-GI-TOC-December-2024.v4.pdf.\n\nGovernment of the Netherlands. 2021. 'Prinsjesdag 2021: investeren in stabiliteit van de rechtsstaat.' Nieuwsbericht. Ministerie van Algemene Zaken. 21 September 2021. https:\u002F\u002Fwww.rijksoverheid.nl\u002Factueel\u002Fnieuws\u002F2021\u002F09\u002F21\u002F prinsjesdag-2021-investeren-in-stabiliteit-van-de-rechtsstaat.\n\n--- . 2024. 'Douane moet gegevens kunnen delen in strijd tegen ondermijnende criminaliteit - Nieuwsbericht - Rijksoverheid.nl.' Nieuwsbericht. Ministerie van Algemene Zaken. 28 March 2024. https:\u002F\u002Fwww.rijksoverheid.nl\u002F actueel\u002Fnieuws\u002F2024\u002F03\u002F28\u002Fdouane-moet-gegevens-kunnen-delen-in-strijdtegen-ondermijnende-criminaliteit.\n\n--- . n.d.-a. 'Ondermijnende criminaliteit - Ondermijning - Rijksoverheid.nl' . Onderwerp. Ministerie van Algemene Zaken. Accessed 17 June 2025. https:\u002F\u002F www.rijksoverheid.nl\u002Fonderwerpen\u002Fondermijning\u002Fondermijnende-criminaliteit.\n\n- --- . n.d.-b. 'Welk bedrag mag ik maximaal contant betalen? - Rijksoverheid. nl. ' Onderwerp. Ministerie van Algemene Zaken. Accessed 18 June 2025. https:\u002F\u002F www.rijksoverheid.nl\u002Fonderwerpen\u002Fbetalingsverkeer\u002Fvraag-en-antwoord\u002F grote-aankopen-met-contant-geld.\n\nHalsema, Femke. 2024. 'As the mayor of Amsterdam, I can see the Netherlands risks becoming a narco-state.' The Guardian, 5 January 2024, sec. Opinion. https:\u002F\u002Fwww.theguardian.com\u002Fcommentisfree\u002F2024\u002Fjan\u002F05\u002Famsterdamnetherlands-drugs-policy-trade.\n\nHeld, Douwe den. 2024. 'Pioneering Dutch Cocaine Trafficker Sentenced to Life in Prison.' InSight Crime (blog). 6 March 2024. http:\u002F\u002Finsightcrime.org\u002Fnews\u002F pioneering-dutch-cocaine-trafficker-sentenced-to-life-in-prison\u002F.\n\nHolligan, Anna. 2024. 'Dutch mega-trial exposes brutal gangland underworld.' BBC News, 27 February 2024. https:\u002F\u002Fwww.bbc.com\u002Fnews\u002Fworldeurope-68416287.\n\nJancsics, David. 2019. 'Border Corruption.' Public Integrity 21 (4): 406-19. https:\u002F\u002Fdoi.org\u002F10.1080\u002F10999922.2019.1581043.\n\n--- . 2020. 'Corruption in border administration.' In Handbook on Corruption, Ethics and Integrity in Public Administration, 215-25. Edward Elgar Publishing. https:\u002F\u002Fwww.elgaronline.com\u002Fedcollchap\u002F edcoll\u002F9781789900903\u002F9781789900903.00023.xml.\n\n--- . 2021. 'Law enforcement corruption along the U.S. borders.' Security Journal 34 (1): 26-46. https:\u002F\u002Fdoi.org\u002F10.1057\u002Fs41284-019-00203-8.\n\nJancsics, David, and Jacopo Costa. 2024. 'Organizational forms of corruption networks: the Odebrecht-Toledo case.' International Public Management Journal 27 (4): 559-82. https:\u002F\u002Fdoi.org\u002F10.1080\u002F10967494.2023.2260368.\n\nKPMG. 2021. 'De beheersing van corruptierisico's door de Douane in de Rotterdamse haven.' Amstelveen: KPMG. https:\u002F\u002Fopen.overheid.nl\u002Fdocumenten\u002F ronl-aa4c30d2-7240-44ca-b4b5-c0417ff80b09\u002Fpdf.\n\nMadarie, Renushka, and Edwin Kruisbergen. 2019. 'Transitcriminaliteit en logistieke knooppunten in Nederland.' In Criminaliteit En Veiligheid in Mainports , 45:29-51. 2019. Boom Juridisch. https:\u002F\u002Frepository.wodc.nl\u002F handle\u002F20.500.12832\u002F814.\n\nMay, Paul, and Pavla Holcova. 2023. 'Inside Job: How a Hacker Helped Cocaine Traffickers Infiltrate Europe's Biggest Ports.' OCCRP (blog). 7 November 2023. https:\u002F\u002Fwww.occrp.org\u002Fen\u002Fproject\u002Fnarcofiles-the-new-criminal-order\u002F inside-job-how-a-hacker-helped-cocaine-traffickers-infiltrate-europes-biggestports.\n\nMcLinden, Gerard, and Amer Zafar Durrani. 2013. 'Corruption in Customs.' World Customs Journal 7 (2): 3-10. https:\u002F\u002Fdoi.org\u002F10.55596\u002F001c.92957.\n\nMinchin, Joshua. 2025. 'Volume of cocaine seized in Belgium and Netherlands plummets.' Lloyd's List, 24 January 2025, sec. Containers. https:\u002F\u002Fwww. lloydslist.com\u002FLL1152340\u002FVolume-of-cocaine-seized-in-Belgium-andNetherlands-plummets.\n\nNelen, Hans, and Emile Kolthoff. 2017. 'Georganiseerde Criminaliteit En Integriteit van Rechtshandhavingsorganisaties.' WODC, Ministerie van Veiligheid en Justitie. https:\u002F\u002Frepository.wodc.nl\u002Fbitstream\u002F handle\u002F20.500.12832\u002F2307\u002F2748\\_Volledige\\_Tekst\\_tcm28-280189. pdf?sequence=2&isAllowed=y.\n\nNetherlands Public Prosecution Service. 2023. 'Grootste cocaïnevangst ooit in Nederland - Nieuwsbericht - Openbaar Ministerie.' Nieuwsbericht. Ministerie van Justitie en Veiligheid. 10 August 2023. https:\u002F\u002Fwww.om.nl\u002Factueel\u002F nieuws\u002F2023\u002F08\u002F10\u002Fgrootste-vangst-ooit-in-rotterdamse-haven-8000-kilo-terwaarde-van-600-miljoen-euro.\n\n---. 2024a. 'Gevangenisstraffen geëist voor cocaïnesmokkel met behulp van informatie Douane - Nieuwsbericht - Openbaar Ministerie.' Nieuwsbericht. Ministerie van Justitie en Veiligheid. 14 May 2024. https:\u002F\u002Fwww.om.nl\u002Factueel\u002F nieuws\u002F2024\u002F05\u002F14\u002Fgevangenisstraffen-geeist-voor-cocainesmokkel-metbehulp-van-informatie-douane.\n\n---. 2024b. '2023: HARC-team onderschept ruim 45.000 kilo cocaine.' Nieuwsbericht. Ministerie van Justitie en Veiligheid. 17 January 2024. https:\u002F\u002F www.om.nl\u002Factueel\u002Fnieuws\u002F2024\u002F01\u002F15\u002F2023-harc-team-onderschept-ruim45.000-kilo-cocaine.\n\n---. 2025. '2024: Minder drugs onderschept in haven Rotterdam, aantal aangetroffen kilo's in havens Zeeland-West-Brabant nam iets toe.' Nieuwsbericht. Ministerie van Justitie en Veiligheid. 23 January 2025. https:\u002F\u002F www.om.nl\u002Factueel\u002Fnieuws\u002F2025\u002F01\u002F21\u002F2024-minder-drugs-onderschept-inhaven-rotterdam-aantal-aangetroffen-kilos-in-havens-zeeland-west-brabantnam-iets-toe.\n\n---. n.d. 'HARC-team.' Onderwerp. Ministerie van Justitie en Veiligheid. Accessed 17 June 2025. https:\u002F\u002Fwww.om.nl\u002Fonderwerpen\u002Fharc-team.\n\nNistotskaya, Marina, Emanuel Wittberg, Sławomir Śnieżko, Daniel Kofran, Viktoriia Poltoratskaya, Bence Toth and Jacopo Costa. 2024.\n\n'Comprehensive report on the cost of corruption in the EU' . FALCON. https:\u002F\u002F www.falcon-horizon.eu\u002Fwp-content\u002Fuploads\u002Fsites\u002F6\u002F2025\u002F06\u002FFALCON\\_D2.3\\_ Comprehensive-report-on-the-cost-of-corruption-in-the-EU\\_public.pdf.\n\nNL Times. 2024a. 'Wanted criminal 'Bolle Jos' sentenced to 24 years in prison.' 26 June 2024. https:\u002F\u002Fnltimes.nl\u002F2024\u002F06\u002F26\u002Fwanted-criminal-bolle-jossentenced-24-years-prison.\n\n---. 2024b. 'Greek 'underworld banker' faces 10 years in prison for organised crime allegations | NL Times.' 22 August 2024. https:\u002F\u002Fnltimes.nl\u002F2024\u002F08\u002F22\u002F greek-underworld-banker-faces-10-years-prison-organized-crime-allegations.\n\n---. 2025. 'Cocaine smuggling in Netherlands soars as new tactics bypass detection systems.' 29 March 2025. https:\u002F\u002Fnltimes.nl\u002F2025\u002F03\u002F29\u002Fcocainesmuggling-netherlands-soars-new-tactics-bypass-detection-systems.\n\nO'Keeffe, Cormac. 2023. 'Drug cartels' model is to 'flood Europe' with tonnes of cocaine.' Irish Examiner , 20 December 2023, sec. IE-Main\u002FNEWS. https:\u002F\u002F www.irishexaminer.com\u002Fnews\u002Farid-41294608.html.\n\nOrtiz, Turenna Ramirez. 2021. 'Bribery and Corruption at the Border: Mexico: An Outstanding Challenge to Be Overcome by the Mexican Government.' Global Trade and Customs Journal 16 (9). https:\u002F\u002Fkluwerlawonline.com\u002Fapi\u002FProduct\u002F CitationPDFURL?file=Journals\\GTCJ\\GTCJ2021048.pdf.\n\nPaternoster, Caterina, Michele Riccardi, Georgia Cascone, Matteo Anastasio, Giovanni Nicolazzo, Francesco Venturini, Jacopo Costa, Viktoriia Poltoratskaya and Bence Toth. 2024. 'Facilitators, Schemes, Interlinks and Modi Operandi of Corruption.' FALCON.\n\nPol, Wim van de. 2016. 'Wie is wie in het Douane-dossier?' Crimesite (blog). 10 December 2016. https:\u002F\u002Fwww.crimesite.nl\u002Fis-douane-dossier\u002F.\n\nPort of Rotterdam Authority. 2021. 'Annual Report 2021.' https:\u002F\u002Freporting. portofrotterdam.com\u002Fdownloads.\n\n---. 2022. 'Wie doet wat voor een veilige haven?' 22 March 2022. https:\u002F\u002F www.portofrotterdam.com\u002Fnl\u002Fonline-beleven\u002Fhavenkrant\u002Foverzicht\u002Fwie-doetwat-voor-een-veilige-haven.\n\n---. n.d.-a. 'Purpose, mission, vision and strategy' . Accessed 17 June 2025. https:\u002F\u002Fwww.portofrotterdam.com\u002Fen\u002Fabout-port-authority\u002Fpurpose-missionvision-and-strategy.\n\n---. n.d.-b. 'Facts and figures: The port of Rotterdam in numbers' . Accessed 17 June 2025. https:\u002F\u002Fwww.portofrotterdam.com\u002Fen\u002Fexperience-online\u002Ffacts-andfigures.\n\nRoks, Robby, Lieselot Bisschop and Richard Staring. 2021. 'Getting a foot in the door. Spaces of cocaine trafficking in the Port of Rotterdam.' Trends in Organized Crime 24 (2): 171-88. https:\u002F\u002Fdoi.org\u002F10.1007\u002Fs12117-020-09394-8.\n\nRotterdamse Haven Veilige Haven. 2024. 'Let extra op reefers en onlogische goederen.' Veilige Haven (blog). 22 October 2024. https:\u002F\u002Fwww. rotterdamsehavenveiligehaven.nl\u002Fpost\u002Flet-extra-op-reefers-en-onlogischegoederen.\n\n---. n.d. 'Voorkom - Dat je zélf betrokken raakt.' Accessed 17 June 2025. https:\u002F\u002Fwww.rotterdamsehavenveiligehaven.nl\u002Fvoorkomen.\n\nRovers, G, and J.A. Moors. 2019. 'Onderzoeksproject: Als de Prooi de Jager Pakt. Toelichting Op Het Besluit van de Onderzoekers Om Geen Onderzoeksrapport Te Publiceren.' Experts in Media en Maatschappij (EMMA), Bureau voor Toegepast Veiligheidsonderzoek (BTVO). https:\u002F\u002F www.eerstekamer.nl\u002Foverig\u002F20200611\u002Fals\\_de\\_prooi\\_de\\_jager\\_pakt\\_bijlage\u002F document.\n\nSergi, Anna. 2020. The Port-Crime Interface A Report on Organised Crime and Corruption in Seaports . University of Essex. https:\u002F\u002Frepository.essex. ac.uk\u002F30303\u002F.\n\nSonnemans, Sander. 2017. 'Corrupte douanier Gerrit G. voor 14 jaar de cel in.' AD.nl , 4 July 2017, sec. Binnenland. https:\u002F\u002Fwww.ad.nl\u002Fbinnenland\u002Fcorruptedouanier-gerrit-g-voor-14-jaar-de-cel-in~a8f5c063\u002F.\n\nSpapens, Antonius, Manja Abraham, Bram van Dijk and Daniel Hofstra. 2021. '25 Years of Tackling Large-Scale Drug Crime in the Netherlands.' CIROC Newsletter , 2021.\n\nStaring, Richard. 2021. 'Antwerp and Rotterdam: A Comparative Analysis of the Import and Distribution of Cocaine in Two European Port Cities' . CIROC Newsletter , October 2021 (3): 1-2.\n\nStaring, Richard, Lieselot Bisschop, Robby Roks, Elisabeth Brein and Henk van de Bunt. 2019. 'Drugscriminaliteit in de Rotterdamse haven: aard en aanpak van het fenomeen.' May. https:\u002F\u002Frepub.eur.nl\u002Fpub\u002F116670.\n\n---. 2023. 'Drug Crime and the Port of Rotterdam: About the Phenomenon and Its Approach.' In Organized Crime in the 21st Century , edited by Hans Nelen and Dina Siegel, 43-61. Springer International Publishing AG. https:\u002F\u002Fdoi. org\u002F10.1007\u002F978-3-031-21576-6.\n\nTrimbos Instituut. 2025. 'Nationale Drug Monitor 2025: 16.3 Handel, inbeslagnames en ontmanteling.' https:\u002F\u002Fwww.nationaledrugmonitor.nl\u002Fillegalehandel-bezit-en-productie-smokkel-routes-en-samenwerkingsverbanden\u002F.\n\nTweede Kamer der Staten-Generaal. 2022. Wetsvoorstel: Wet plan van aanpak witwassen (Draft Bill: Money Laundering Action Plan Act). Bill no. 36228, 1928. Submitted by S.A.M. Kaag, Minister of Finance. October 21, 2022. https:\u002F\u002Fwww.tweedekamer.nl\u002Fkamerstukken\u002Fwetsvoorstellen\u002F detail?cfg=wetsvoorsteldetails&qry=wetsvoorstel%3A36228.\n\nUnger, Brigitte, Joras Ferwerda, Bojken Gjoleka, Alexander van Saase, Brigitte Slot and Linette de Swart. 2018. 'Aard en omvang van criminele bestedingen: Eindrapportage.' WODC. https:\u002F\u002Fbrigitteunger.nl\u002Fwp-content\u002F uploads\u002F2019\u002F06\u002FAard-en-omvang-van-criminele-bestedingen.pdf.\n\nVan der Wiele, Door. 2024. ''Zo ziet het eruit, zo ruikt het en zo is het verstopt' .' entrum voor Criminaliteitspreventie (blog). 11 December 2024. https:\u002F\u002Fccvsecondant.nl\u002Fplatform\u002Farticle\u002Fzo-ziet-het-eruit-zo-ruikt-het-en-zo-is-hetverstopt.\n\nVan Gestel, Barbra. 2019. 'Boekrecensie: Drugssmokkelaars en de deur in de haven.' In Criminaliteit En Veiligheid in Mainports , 45:91-97. 2019. WODC. https:\u002F\u002F repository.wodc.nl\u002Fhandle\u002F20.500.12832\u002F814.\n\nVertrouwensketen. n.d. 'Samen maken we onze logistiek veiliger.' Accessed 17 June 2025. https:\u002F\u002Fvertrouwensketen.nl\u002F.\n\nZürcher, Emma, Mafalda Pardal, Iris Leussink and Stijn Hoorens. 2024. 'Drugsgerelateerde corruptive op Schiphol en in de Rotterdamse haven [Drugrelated corruption at Schiphol Airport and the Port of Rotterdam].' RAND Europe. https:\u002F\u002Fwww.rand.org\u002Fpubs\u002Fresearch\\_reports\u002FRRA2870-1.html.\n\n## Judicial cases\n\n|            | Judgment of the Rotterdam District Court in Case number ROT 10\u002F750163-14, 4 July  2017.                                                                                                                                                                                                                                                                                                                    |\n|------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| 2017:5125  | Summary:  A customs officer in the port of Rotterdam is accused of accepting bribes  that facilitated the import of large quantities of cocaine, as well as laundering the  money earned from this.  https:\u002F\u002Fuitspraken.rechtspraak.nl\u002Fdetails?id=ECLI:NL:RBROT:2017:5125&showbut-                                                                                                                         |\n| 2019:1103  | 2019. Summary: A customs official is accused of accepting bribes to facilitate drugs traffick- ing and associated money laundering and was sentenced to two years in prison. https:\u002F\u002Fuitspraken.rechtspraak.nl\u002Fdetails?id=ECLI:NL:RBROT:2019:1103&showbut-                                                                                                                                                 |\n| 2020:918   | Summary: The defendant was convicted of, among other things, bribing a customs  official, conspiracy to import narcotics and preparatory acts in that regard, as well as  laundering large sums of money, and was sentenced to 10 years' imprisonment. https:\u002F\u002Fuitspraken.rechtspraak.nl\u002Fdetails?id=ECLI:NL:GHDHA:2020:918&showbut- ton=true&keyword=corruptie%2Brotterdam%2Bhaven,douane,witwassen&idx=10 |\n| 2020:12597 | Summary: Customs official convicted of accepting bribes, breaching official secrecy  and money laundering in connection with drug trafficking. https:\u002F\u002Fuitspraken.rechtspraak.nl\u002Fdetails?id=ECLI:NL:RBROT:2020:12597&showbut- ton=true&keyword=corruptie%2Brotterdam%2Bhaven,douane,witwassen&idx=9                                                                                                        |\n| 2020:1295  | Summary: The defendant (working for the tax office) was convicted for participating in  a criminal organisation that was involved in importing cocaine via the port of Rotter- dam and related offences such as extortion, money laundering and bribery, and was  sentenced to nine years' imprisonment. https:\u002F\u002Fuitspraken.rechtspraak.nl\u002Fdetails?id=ECLI:NL:RBROT:2020:1295&showbut-                     |\n|            | Judgment of the Rotterdam District Court in Case number 10\u002F750306-18, 21 June 2022. Summary: Customs official is convicted of money laundering. https:\u002F\u002Fuitspraken.rechtspraak.nl\u002Fdetails?id=ECLI:NL:RBROT:2022:5588&showbut-                                                                                                                                                                              |\n| 2022:5588  | ton=true&keyword=corruptie%2Brotterdam%2Bhaven,douane,witwassen&idx=8                                                                                                                                                                                                                                                                                                                                      |\n\n## Annex: Overview of stakeholder interviews\n\n|   # | Type of stakeholder   | Date          |\n|-----|-----------------------|---------------|\n|   1 | Academia\u002Fresearcher   | 26 March 2024 |\n|   2 | Law enforcement       | 4 April 2024  |\n|   3 | Academia\u002Fresearcher   | 5 April 2024  |\n|   4 | Academia\u002Fresearcher   | 12 April 2024 |\n|   5 | Law enforcement       | 12 July 2024  |","2025-09-11T10:05:18.000Z","2026-06-02T14:16:22.000Z","This Working Paper examines how corruption facilitates drug trafficking\n(specifically cocaine) through the port of Rotterdam, looking at the underlying\ndrivers and strategies involved. Legal trade routes and commercial ports are\nespecially attractive because of the high volumes of cargo, which make it\npossible to conceal illicit cargo under licit cargo. The spatial complexity of the\nport of Rotterdam also makes it difficult to fully secure it against criminal activity.\n\nDigging deeper into the facilitating factors of trafficking, the paper finds that,\nparadoxically, a main driver of rising border corruption is the increased political\nattention on and resources dedicated to fighting trafficking. Desk research and\nstakeholder interviews highlight that as authorities deploy new technology\nto improve detection, traffickers face more obstacles to operating effectively.\nHaving someone on the inside then becomes increasingly important (Staring\net al., 2019). So, an unintended but important consequence of the strengthened\nfight against drug trafficking is that corruption becomes even more essential for\nthe operational success of organised crime networks.\n\nThis study focuses specifically on the role of customs. Tasked with monitoring\nthe import and export of goods, customs officers are important actors in the\nfight against drug trafficking. However, their role also makes them vulnerable:\nthey have crucial knowledge on processes and procedures, access to systems\nand discretionary power that can be exploited by criminals (KPMG, 2021).\n\nThe desk research shows that corruption is used strategically to circumvent two\nimportant bottlenecks: the container screening and security as cargo enters the\nport, and the exit of drugs from the port (Staring et al., 2019). Traffickers may\nseek to obtain key information or direct assistance from customs officers.\n\nThese corrupt relationships and the emerging networks between members of\ncrime groups and the customs officials are diverse. Some relationships can be\ncharacterised by collusion, where customs officials offer their services or are\npersuaded to cooperate. This collusion may be opportunistic or targeted. Other\nrelationships can be characterised by coercion. Customs officials may be lured\nby financial reward, but this is accompanied by intimidation or the threat of\nviolence to ensure that the officer cooperates and continues to cooperate.\nOur research highlights that the boundary between collusion and coercion is\noften blurred.\n\nBeyond collusion and coercion, we also see infiltration, which crosses the\nboundaries between the criminal, public and private. What emerges is less a\nmatter of individual corruption and more akin to regulatory capture, where the\npublic office position is held by a member of the criminal network.\n\nThe review of the judicial cases shows that bribes involved in these schemes\ncan amount to millions. To hide and use the illicit gains, traffickers rely on money\nlaundering, disguising its source as legitimate. They often enlist the help of family\nand friends, a trusted inner circle or professional specialists. They may also hide\ncash at home or invest it in assets and businesses in the Netherlands or abroad.\n\nA key finding of our research is that the criminal and corruption strategies used\nto facilitate drug trafficking are highly adaptive. The underlying driver of this\nadaptability is the unchanging demand for drugs and high profitability of the\ncrime. This pushes traffickers to adopt new strategies to overcome hurdles in\nsupplying the demand.\n\nCorruption strategies adapt in response to new enforcement measures. When\ncontrol systems are changed and\u002For strengthened, corruption strategies evolve\nalongside them. This research identifies some key patterns:\n\n- Stronger detection efforts increase the incentives for corruption.\n- Evolving systems encourage a similar shift in corruption strategies.\n- Anti-corruption and anti-trafficking measures may change the profile of those most vulnerable to being co-opted.\n- The characteristics of corruption can also evolve, from collusion to coercion, to full infiltration of institutions and systems – with blurred lines in between.\n\nTrafficking strategies are similarly adaptive. There have been increased efforts\nby the port to combat trafficking through enhanced detection and technology.\nThis was initially reflected by increased drug seizures. But since 2024, drugs\nseizures have declined. The research findings provide an explanation for this:\nAs detection strengthens, more drug seizures are made. But what may happen,\ntoo, is a response to these new measures. As the risk of detection increases,\ncriminals may adapt their trafficking strategies to overcome the additional\nhurdles, including:\n\n- changing concealment strategies; and\n- changing modes of transport and trafficking routes, including to ports outside of the Netherlands.\n\nThese developments highlight the complexity in understanding the impact of\nstronger anti-trafficking measures on both corruption and trafficking strategies.\nTrafficking and corruption are typically measured by detection, for example,\nby changes in the volume of drug seizures or the number of public officials\ncaught engaging in corruption. But the elephant in the room is that increasingly\nsophisticated criminal strategies can hide what is really happening. This\nunderscores the need to continuously strengthen our ability to recognise “red\nflags” of corruption and trafficking. Data-driven tools and refined risk indicators\nare critical for understanding how crime and corruption strategies are changing.\n\nThe evolving nature of criminal strategies is often likened to a game of chess:\nenforcement makes a move, and criminal networks adapt. But what now seems\nto be emerging is more troubling. When barriers to drug trafficking increase\nwhile demand remains unchanged, crime and corruption strategies adapt\nin ways that can deepen their impact on society, leading for example to the\nhardening of crime and associated violence.\n\nThis makes anticipating how crime may adapt to changing anti-corruption and\nanti-trafficking strategies critical. Improved foresight and scenario-building\ncapacities will be vital in order to develop more robust enforcement efforts\nagainst drug trafficking and mitigate the negative impact on society.\n\nA holistic approach is essential. Addressing corruption as a facilitator of drug\ntrafficking requires a broad view of crime that focuses on understanding\nvulnerabilities, leveraging data and harnessing collaboration. The risk of\ntrafficking routes changing are high, therefore, we must use every tool at our\ndisposal to ensure effective and sustainable enforcement efforts.","Drivers, strategies and implications","\u002Fresources\u002Fpublications\u002Fwp-58",{"id":499,"slug":500,"title":501,"status":6,"nid":502,"year":503,"body":504,"external":19,"topic":505,"language":15,"type":508,"date_published":509,"image":510,"citation":14,"publisher":17,"link_internal":511,"link_external":512,"authors":513,"countries":522,"tags":523,"pdf":524,"topics":526,"featured":19,"languages":527,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":528,"user_updated":49,"date_updated":529,"main_points":7,"short_version":7,"subtitle":7,"link":530},2359,"wp-53","Working Paper 53: Good governance and the just transition: Implications for renewable energy companies",2673,2024,"There is broad agreement that ensuring a just energy transition is key for achieving the trust and support from citizens needed to succeed with the green transition and the COP28 goal of tripling renewable energy capacity by 2030.\n\nThis paper discusses the concept of a just transition, with a particular focus on the importance of achieving a transition that benefits both local communities and society at large. It examines the governance and corruption challenges that could jeopardise this goal and discusses how industry associations and companies in the renewable energy sector could step up its efforts to address these challenges to realise the ambition of a just transition.\n\nThe paper draws on lessons from the experience of tackling governance and corruption risks in the extractive sector and sets out proposals on how to accelerate collective action in the renewable energy sector. \n\n### About this report\n\nThis is a guest Working Paper of the Basel Institute on Governance, ISSN: 2624-9650. You may share or republish the report under a Creative Commons CC BY-NC-ND 4.0 licence. The contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, University of Basel or funding organisations.\n\nSuggested citation: de Vibe, Maja, and Mark Robinson. 2024. ‘Good governance and the just transition: Implications for renewable energy companies.’ Working Paper 53, Basel Institute on Governance. Available at: baselgovernance.org\u002Fpublications\u002Fwp-53.",[506,21,507],"Collective Action","Private Sector",[32],"2024-09-01","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Facad9a6f-74c5-48d5-9305-a053ed97aa91?width=600&height=840",[],[],[514,518],{"authors_id":515},{"id":516,"name":517},546,"Maja de Vibe",{"authors_id":519},{"id":520,"name":521},547,"Mark Robinson",[],[],[525],2445,[506,21,507],[15],"2024-08-30T16:05:06.000Z","2026-05-31T22:51:53.000Z","\u002Fresources\u002Fpublications\u002Fwp-53",{"id":532,"slug":533,"title":534,"status":6,"nid":535,"year":170,"body":536,"external":19,"topic":537,"language":15,"type":538,"date_published":539,"image":540,"citation":14,"publisher":17,"link_internal":541,"link_external":542,"authors":543,"countries":548,"tags":549,"pdf":550,"topics":551,"featured":19,"languages":552,"summary":7,"programme":7,"area":7,"websites":7,"pdf_text":7,"sort":7,"user_created":48,"date_created":553,"user_updated":49,"date_updated":554,"main_points":7,"short_version":7,"subtitle":7,"link":406},2322,"wp-50","(Forthcoming) Working Paper 50: Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8\u002F12",2549,"At the 8th session of the Conference of the States Parties to the United Nations Convention against Corruption (UNCAC), in December 2019, States parties adopted a resolution recognising the relationship between corruption and environmental crimes. \n\nResolution 8\u002F12 – *Preventing and combating corruption as it relates to crimes that have an impact on the environment *– is a landmark Resolution. With its 23 operative paragraphs (OPs), it underlies the importance of addressing corruption linked to crimes that have an impact on the environment. It urges States parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment. \n\nThis Working Paper report presents a concise overview of prevention and enforcement actions, initiatives and measures implemented by UNCAC States parties between 2019 and 2023 to combat corruption as it pertains to crimes that have an impact on the environment. Section 2 focuses on prevention and Section 3 on enforcement actions.\n\nSection 4 underscores the valuable contributions made by non-state actors, in particular civil society, academia and the media in this collective endeavour.\n\nThe conclusion includes a list of promising initiatives for corruption prevention and enforcement.\n\n### About this Working Paper\n\nThis report is part of the Green Corruption programme at the Basel Institute on Governance and was prepared in the context of the 10th Conference of the States Parties to the UN Convention against Corruption in Atlanta, Georgia, US from 11–15 December 2023. It was made possible by the generous support of the Principality of Liechtenstein.\n\nIt is also part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. You may share or republish the report under a Creative Commons \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa> licence.",[21],[32],"2023-12-04","https:\u002F\u002Fjam.baselgovernance.org\u002Fapi\u002Fassets\u002Fd73f4318-370b-4a00-8fee-542de3b3d650?width=600&height=840",[],[],[544],{"authors_id":545},{"id":546,"name":547},532,"Sophie Lemaître",[],[],[],[21],[15],"2023-12-04T11:04:46.000Z","2026-05-31T22:51:49.000Z",1780676538037]