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How tackling green corruption can help us get ahead in the race to net zero
Juhani Grossmann and Amanda Cabrejo le Roux explain the strategic re-focusing of our Green Corruption programme on energy and climate: What is “green” corruption and why does it matter? Green corruption refers to corruption and other financial crimes and governance failures that harm the environment and hinder global efforts to combat climate change. It’s the reason crimes such as illicit deforestation, mining and wildlife trade continue to be multimillion-dollar illegal industries making organised criminals rich at the expense of our planet and the livelihoods of local communities. Green corruption also diverts crucial investments intended for renewable energy and other climate-related projects. Adapting to humanity’s changing energy needs in a just and sustainable manner are challenging enough. We cannot afford to let corruption undermine these generational challenges. What are some key achievements of the programme so far? We are proud that since its launch in 2018, the Green Corruption programme has contributed to significant strides in tackling corruption affecting the environment. Our programme started with an enforcement focus: applying “follow the money” approaches to environmental crimes like illegal wildlife trade and illegal logging. In practice, that means mentoring and training law enforcement officers of national partner agencies to investigate financial transactions that fuel environmental crimes, including between criminal groups and corrupt facilitators. And ideally, to seize and confiscate illicit profits or assets used in the crimes. That’s the only way to get beyond the low-level perpetrators – such as poachers – to the high-level facilitators and organised crime networks. And the only way to take the profit out of the crime, reducing the incentives to engage in it. At the end of 2024, assets worth around CHF 29.6 million were being targeted in 56 cases directly supported by our advisors. We had quite a few “firsts” – like Uganda’s first ever indictment for tax evasion and money laundering against a wildlife trafficking syndicate, Malawi’s first ever corruption cases related to natural resource crimes, Peru’s confiscation of over CHF 3 million in assets related to forestry and gold trafficking, and Indonesia’s first ever conviction on money laundering in relation to an illegal logging case. Behind the headlines lie many more positive steps towards changing mindsets and the priorities of law enforcement agencies to go after the finances of environmental criminals. Our prevention work rapidly grew as we and our partners realised the chronic under-investment in building systems that strengthen resilience to corruption in the environmental sector. Government agencies and state-owned enterprises in countries as diverse as Indonesia, Malawi, Ukraine and Bolivia have now begun to systematically assess and address corruption risks that are affecting their ability to carry out their important functions of protecting the environment and natural resources. Our prevention specialists supported these in applying our bespoke methodology of assessing and prioritising corruption risks and implementing targeted mitigation measures. We developed a customised internal controls maturity assessment tool to reflect the historic lack of investment in this space, which meant that mainstream assessment tools were insufficiently granular at the first stage of maturity to reflect nuances and chart paths to growth. As result of our partnerships, mitigation measures have been institutionalised in many agencies – for example: in Malawi through the creation of Internal Integrity Committees in environmental agencies; in Ukraine through the empowerment of anti-corruption officers to participate in key decision-making processes; in Ecuador by reducing unsupervised discretion in environmental inspections; in Indonesia in the adoption of conflict of interest regulations in the management of timber sales; and in Peru through the automation and digitalisation of numerous permitting and licensing processes related to the wood value chain. Also pleasing to see are the many collaborations and partnerships that have sprung from our work. In Latin America, for example, forestry officials in Peru, Bolivia and Ecuador are now collaborating on protecting the Amazon rainforest through corruption prevention. Still, targeting and preventing corruption tends to be a lonely effort. So, we have established the Countering Environmental Corruption Practitioners Forum together with WWF, TRAFFIC and Transparency International as a support network, and it has now grown to over 800 members and four working groups. There are frequent meetings and collaborations between practitioners dedicated to tackling corruption and improving governance, and those specialised in environmental conservation or climate initiatives. It’s a sign there’s much appetite and energy for action against green corruption Why is now the time to focus on the energy transition? Whatever happens in these volatile times, one thing is certain: we’ll continue to see growing demands for energy transition and climate mitigation and adaptation. The urgency of tackling the energy transition, and the rapid increase in investments from both the public and private sectors, leaves the door wide open to criminals and the corrupt seeking to profit at the expense of investors and donors – as well as the planet. A clear example in this space is the growing geopolitical centrality of critical minerals and rare earths. The rapid rise in demand has been accompanied by particularly fragile governance structures, intense political and economic subsidies, and even warfare. Our experience shows that these are all breeding grounds for corruption. We are therefore prioritising efforts to analyse and mitigate corruption risks in this space in Bolivia, Indonesia and Ukraine. Ensuring that the energy transition is safeguarded from corruption is essential for achieving net-zero goals. As outlined in our Working Paper on good governance and the just transition, corrupt practices can jeopardise renewable energy investments and hinder the development of clean energy infrastructure. Rapidly emerging market-based solutions to stimulate responsible behaviour, such as carbon offsets, are also affected by weak governance systems and opportunities for corruption. The fast-evolving and highly technical nature of these activities only increases this risk. Corruption risks similarly threaten the effectiveness of climate mitigation and adaptation efforts. If funds are embezzled, used fraudulently or diverted to benefit powerful elites, that’s bad for donors and investors. And it’s bad for local communities, many of which are also directly affected by climate change. On the other hand, there are opportunities. Using corruption risk management tools and enhancing enforcement capabilities can help companies and governments to create thriving, profitable supply chains of critical minerals needed for renewable energy facilities, electric vehicles and the like. What does this shift in priorities mean in practice? Through our Green Corruption programme, we are adapting to this evolving landscape by sharpening our focus on transition minerals and the renewable energy sector. We will continue our dual approach of prevention and enforcement, working closely with long-standing partners in Ukraine, Indonesia, Madagascar, Malawi, Uganda, Peru, Bolivia and Ecuador. Some things you might see us doing in the next years: Strengthening transparency and anti-corruption measures in the extraction and trade of lithium, nickel, germanium and other minerals and rare earths essential for the energy transition. Customising financial investigation and asset recovery tools to the specifics of the energy transition. Working with governments, financial institutions and civil society to safeguard energy transition and climate mitigation funds from corruption, fraud and related crimes. We will continue full force our ongoing engagement related to metals gold in particular and the forestry sector, which remain highly strategic. In other areas, such as illegal wildlife trade, fisheries and waste, we will be more discerning, carefully assessing the potential of engagements prior to pursuing them. What impact do we hope to achieve? By applying our expertise to emerging climate and energy challenges, we want to contribute to measurable improvements in the energy transition, environmental conservation, climate change mitigation and equitable economic development. Through these efforts, our Green Corruption programme will continue to play a vital role in ensuring that the green transition is not only sustainable but also just, transparent and a win-win for all: businesses, local communities and society at large – as well as our planet.
Building follow-the-money skills and networks to target environmental crime syndicates
The illegal wildlife trade is operating at an industrial scale. It has a direct impact on the accelerating rate of biodiversity loss and deprives local communities of sustainable livelihoods. A grant from the UK’s IWT Challenge Fund has enabled the Basel Institute’s Green Corruption team to extend its work in a number of countries vulnerable to the illegal wildlife trade. By providing training, mentoring on live cases and fostering communities of practice, we are advancing the use of “follow-the-money” techniques to combat the criminal networks operating in this field. An underused approach The follow-the-money approach involves scrutinising transactions to extract evidence about crimes and criminal networks. It is widely recognised for its value in investigating and prosecuting profit-driven crime as well as confiscating the proceeds and instrumentalities of crime. However it is still underused, particularly in relation to environmental crime. Like other transnational crime networks, environmental crime syndicates exploit legal, transport and financial systems to facilitate crimes and evade detection, moving money and goods in complex networks around the world. But the use of these systems is also the criminals’ Achilles heel – the size and sophistication of their networks create a significant footprint and enable investigators with the right skills to trace their financial flows. Our programme aims to capitalise on this opportunity by strengthening capacity in follow-the money-techniques, encouraging cross-border collaboration and providing opportunities for peer learning. Training investigators to trace funds Building capacity for these techniques in the environmental field is the foundation of this initiative. This is achieved through a combination of intensive training in financial investigations and asset recovery, and in-person mentoring by locally based advisors. This face-to-face, tailored support can help officers to translate new knowledge into practice, especially when resources are limited. We now have local teams working with government agencies in countries directly impacted by the illegal trade in wildlife and related environmental crimes: In Madagascar, where several species of fauna and flora are under extreme threat from the illegal wildlife trade and illegal logging. The seizure of tens of thousands of radiated tortoises from traffickers in 2018 is just one example of the massive and organised scale of these operations. In Peru and Bolivia, where the jaguar population is classified on the International Union for Conservation of Nature Red List as “near threatened” partly as a result of the illegal trade in this coveted species. In Uganda, which is a transit hub for wildlife products, including ivory and pangolin scales, and a centre of complex financial flows in Africa and beyond. And in Indonesia, where illegal, unreported and unregulated fishing threatens marine ecosystems and affects livelihoods. Strengthening the network A second pillar of the IWT Challenge Fund project is to create a community of experts and advisors on follow-the-money approaches in the environmental sphere. Through virtual roundtables with other IWT Challenge Fund grantees and civil society organisations from around the world, we are collectively working to increase the use of financial investigations and asset recovery in the fight against illegal wildlife trade. As well as the benefits of peer learning and support, building this community will help to generate “surge” capacity to investigate and take down major environmental crime syndicates. Knowledge sharing These efforts align with the establishment of a dedicated Follow-the-Money Working Group in 2022 as part of the Countering Environmental Corruption Practitioners Forum – an initiative of the Basel Institute, WWF, Transparency International and TRAFFIC. Led by our Green Corruption team, the Working Group has already been instrumental in facilitating knowledge exchange through workshops on various follow-the-money topics, including closed case reviews, recent trends and proactive financial analysis. An additional sub-group made up exclusively of law enforcement professionals allows peer learning among prosecutors and investigators who are receiving mentoring in our priority countries. These meet virtually to share their experiences and challenges. Increasing risk for criminals, and reach for practitioners As long as environmental crime remains a high-profit and low-risk activity, we will never succeed in combating it. Nor will we succeed without networks of skilled practitioners that reach as far as those of the crime syndicates. The twin pillars of this IWT Challenge Fund project – building both technical capacity for financial investigations and a broad follow-the-money practitioner network – are therefore crucial steps in strengthening global efforts to protect our wildlife and biodiversity.
Train-the-Trainer programme on financial investigations and asset recovery gets underway in Kosovo
Kosovan financial investigators, police, prosecutors and judges have completed the first phase of an intensive Train-the-Trainer TTT programme on financial investigations and asset recovery. Led by our International Centre for Asset Recovery ICAR training team in conjunction with UNDP and the Kosovo Judicial Academy, the five-phase TTT programme aims to result in four or five ICAR Certified Trainers while simultaneously training other local participants in the process. Following their certification, the Kosovan trainers will go on to deliver the training to their counterparts as a formal part of Kosovo’s judicial training programme. Supporting Kosovo’s anti-corruption efforts The five-day training workshop, which took place in Prizren, Kosovo from 16–20 May 2022, was part of the Support to Anti-Corruption Efforts in Kosovo SAEK III project of UNDP Kosovo. The Basel Institute is an implementing partner of the project, which seeks to reduce corruption in Kosovo by strengthening monitoring and oversight mechanisms of institutions to perform in an efficient, transparent, accountable and gender-sensitive manner. It is funded by the Swiss Agency for Development and Cooperation SDC office in Kosovo and the Swedish International Development Cooperation Agency SIDA . The TTT programme is an integral part of our efforts to sustainably enhance the capacity of investigators and prosecutors in Kosovo to successfully investigate and prosecute corruption and money laundering cases, and recover assets. It follows a February 2020 training programme on the same topic, in which the 25 participants were specifically challenged to make use of Kosovo’s recent Law of Extended Powers on Confiscation of Assets. Why financial investigations training? A financial investigation is an important tool in detecting money laundering, terrorist financing and other serious crimes, as well as in enabling the freezing, seizure and confiscation of the proceeds of crime. Financial investigation in complex corruption and money laundering cases requires specialist skills and techniques in intelligence gathering, prosecution strategies and asset tracing, among others. Of these techniques, one of the judges at the May 2022 training was particularly complimentary about Source and Application analysis, a method to organise and present financial evidence gathered during an investigation in a way that highlights or identifies illicit or unknown income. Putting such skills and techniques into practice requires a thorough knowledge of relevant Kosovan legislation, and a deep understanding of the legal and practical processes and procedures for recovering assets abroad. To tie these elements together, the centrepiece of the ICAR training programme is an extensive hands-on practical exercise in which the participants actually conduct a Kosovo-specific simulated investigation. Learn more Find out about our ICAR training team and unique methodology, and download the current brochure in English, Spanish, French and Portuguese. Learn more about the Basel Institute’s cooperation with the Office of the Chief Prosecutor of Kosovo under the SAEK programme. For a brief introduction to Source and Application analysis, see this Quick guide to analysing a suspect’s financial affairs in a corruption case. More in-depth guidance is in the step-by-step Guide to proving illicit enrichment using financial investigation and Source and Application of Funds analysis and our self-paced eLearning course on Source and Application of Funds analysis, available in English and Ukrainian.
Malawian Police gain essential skills to combat money laundering and recover criminal proceeds
Investigators and prosecutors from the Malawi Police Service MPS have gained vital skills in financial investigations and asset recovery during a five-day intensive Financial Investigations and Asset Recovery training programme. This is the first time our ICAR Training Team has been able to deliver in-person training since the start of the Covid-19 pandemic. As well as members of the MPS, the 23 participants included prosecutors from the Directorate of Public Prosecutions and members of the Judiciary. The training supports the objectives of our multi-year Tackling Serious and Organised Corruption programme in Malawi, which is funded by the UK Foreign, Commonwealth and Development Office. Why do Malawian Police need specialised training? Just like other Malawian agencies, such as the Financial Intelligence Agency FIA or the Anti-Corruption Bureau ACB , the MPS is increasingly involved in the investigation and prosecution of money laundering cases and the recovery of criminal assets. However, one of the challenges raised during the workshop was a lack of experience and technical expertise to tackle such cases. This is not only because of the financial analysis skills required to investigate such cases, but also the transnational nature of large-scale corruption and money laundering. This requires, among other things, the ability to draft proper mutual legal assistance MLA requests. Learning new skills, applying them in day-to-day work The flagship Financial Investigations and Asset Recovery training programme provides participants with the essential skills and simple but yet powerful tools to handle high-profile and complex financial investigations. One Malawian investigator commented: This is one of the most excellent experiences so far. I have really learned a lot from our lectures, that I will surely use in my cases. I really appreciate the issues to do with money laundering, as currently I am handling a case that has that offence and I did not know how to go about it. I will surely use the knowledge gained this week in my cases as well as my daily work. The participants were immersed in a simulated corruption and money laundering investigation during which they actively followed investigative leads, made decisions, analysed and solved problems, using the Malawian legal framework. The experience also allowed them to reflect upon the challenges that such investigations entail and possible solutions to overcome them. A prosecutor stated that: The course has added some useful value as far as my daily work as a prosecutor is concerned. From now on, I will be able to guide the investigators who are investigating the financial crimes on how best we can successfully corner the perpetrators. As a prosecutor, I will be able from now on to apply for forfeiture orders wherever it is necessary. I can now easily prosecute financial crime-related offences. Learn more The ICAR training team delivers a range of tailored, high-impact training programmes to government partner agencies around the world. Find out more and download a brochure in English, Spanish, French and Portuguese. ICAR also offers free, interactive eLearning courses on critical skills in conducting financial investigations, gathering intelligence and international cooperation, including drafting MLA requests. Register on our virtual learning platform, Basel LEARN, and start learning today
Registration open: 5th Global Conference on Criminal Finances and Cryptocurrencies
Registration is now open for the 5th Global Conference on Criminal Finances and Cryptocurrencies on 7–8 December 2021. The virtual conference explores trends, strategies and tactics in tackling crimes involving virtual assets. A joint initiative of the Basel Institute on Governance, INTERPOL and Europol, the annual event now draws hundreds of experts and interested parties from around the world. Through presentations, discussions and case studies, the conference participants seek to illuminate how criminals can abuse the virtual asset ecosystem and develop recommendations on what law enforcement, regulators and the private sector can do about it. Attendance is free but pre-registration is required. Please note that day 2 8 December is restricted to law enforcement and related public authorities; attendance is subject to confirmation by the organising committee. Agenda and registration 7 December, 12:00–15:30 GMT Open to all, this day is dedicated to contrasting perspectives on virtual assets, regulation and compliance from the public and private sectors, media and regulatory bodies. Topics include: the challenges posed by decentralised finance for identifying and tracing suspicious cryptocurrency transactions; what media investigations reveal about how criminals launder the proceeds of crime using cryptocurrencies; changing scenarios of compliance with AML regulations relating to VASPs. The agenda and speaker names will be published in November. Register for day 1 8 December, 12:00–15:30 GMT Limited to law enforcement and related public authorities judicial authorities, Financial Intelligence Units, anti-money laundering supervisors, etc. the second day is an opportunity to explore the changing modi operandi of criminals abusing the cryptocurrency ecosystem to hide and launder money, and how law enforcement can fight back. The agenda will be released to participants shortly before the conference. Apply to attend day 2 More Download the conference poster. View the latest updates and more information about this and previous events, and browse related resources on cryptocurrencies and financial crime, at: baselgovernance.org/5CrC
Publications
Case Study 14: Madagascar: a landmark conviction for money laundering linked to environmental crime
This Case Study demonstrates how international cooperation and the follow-the-money approach revealed a transnational criminal network trafficking endangered species and led to Madagascar’s first money laundering conviction related to wildlife trafficking.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
Photo: Studio Sifaka / khaosodenglish (used with permission).
The Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery. This case relates to the Basel Institute’s Green Corruption programme.
The development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.
The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Case Study 12: Indonesia: a landmark money laundering conviction in a forestry crime case
This Case Study highlights how investigators of Indonesia’s Ministry of Environment and Forestry achieved their first conviction for money laundering linked to forestry offences, leveraging institutional and legal changes in financial investigation procedures.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
The development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.
The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Quick Guide 40: Financial investigations in a cash economy
Despite the increasing use of digital payment methods, cash is still king in many economies – including criminal economies. It remains the most-used payment option across Africa, the Middle East and Latin America, and accounted for over USD 7.6 trillion in consumer expenditures throughout 2022.
That’s a challenge when investigating financial crimes. How can you “follow the money” without records of bank transfers, debit or credit card payments, or digital wallet transactions?
This Quick Guide explains the specific challenges involved in conducting financial investigations in a cash economy. It outlines how law enforcement can use traditional investigative methods to successfully uncover the financial affairs of a suspect.
About this Quick Guide
You are free to share and republish this work under a Creative Commons BY-NC-ND 4.0 Licence. It is part of the Basel Institute on Governance Quick Guide series, ISSN 2673-5229.
Quick Guide 34: Public-private partnerships for financial intelligence sharing
Financial intelligence is the staple food of investigations into corruption, money laundering and other financial crimes.
Much financial intelligence is held by private-sector institutions such as banks and other financial service providers. How does that get into the hands of law enforcement, where it can trigger or inform investigations? And how can we improve the system?
This Quick Guide gives a brief introduction to public-private partnerships or platforms for financial intelligence sharing. It sets out how they work in practice, and how they can improve the sharing of targeted, useful information between law enforcement and financial institutions.
About this Quick Guide
You are free to share and republish this work under a Creative Commons BY-NC-ND 4.0 Licence. It is part of the Basel Institute on Governance Quick Guide series, ISSN 2673-5229.
Illicit financial flows and natural resource corruption - a TNRC guide
This introductory guide for the Targeting Natural Resource Corruption (TNRC) project:
- outlines the impact of illicit financial flows on conservation goals;
- explains approaches that can help conservation and natural resource management practitioners to strengthen their programming and related responses;
- offers guidance on risks and constraints to such financial approaches.
It leads the Illicit Financial Flows topic page of the TNRC Knowledge Hub and is designed to help practitioners find relevant resources.
The key takeaways are:
- Understanding the financial aspects of natural resource crimes and corruption can reveal opportunities to reduce the incentives to illegally exploit and trade in natural resources, as well as to strengthen law enforcement against those who profit from environmental destruction.
- Targeting the financial aspects of natural resource crimes, especially where money crosses borders, can help to identify and break up corrupt and criminal networks and lead to the recovery of illicit proceeds.
- "Follow the money” approaches vary according to context, but generally require multi-stakeholder and cross-sector collaboration and information sharing.
The Basel Institute’s Green Corruption team developed the guide in collaboration with TNRC consortium partners and external experts.