Sanctions

Keeping pace with financial crime: Basel AML Index sharpens risk assessment data for 2026

Financial crime changes fast, and so do the data available to measure it. Compliance teams, supervisors and other public authorities need tools that evolve just as quickly when they assess money laundering and related financial crime risks at the jurisdiction level. The Basel AML Index’s 15th annual update, to be released in early December, is designed to meet that need. Four changes to its methodology replace data sources that are no longer updated, plus add new perspectives on bribery, judicial independence, public financial management, and financial, tax and customs transparency. Subscribers will also gain new features built around their day-to-day work, including coverage of 247 jurisdictions, faster sanctions updates and easier tracking of changes in the Basel AML Index scores over time. Who uses the Basel AML Index and why The Basel AML Index is an independent tool for assessing the risk of money laundering and related financial crimes in jurisdictions around the world. Published annually since 2012 by the Basel Institute on Governance, it combines data from respected public sources on the regulatory, legal, political and financial factors that make a jurisdiction more or less vulnerable to financial crime. The methodology currently comprises 17 indicators across five domains: Quality of AML/CFT/CPF framework; Corruption and fraud risks; Financial transparency and standards; Public transparency and accountability; and Political and legal risks. Financial institutions use the subscription-based Basel AML Index Expert Edition and Expert Edition Plus tools to assess country risks, benchmark internal risk models and identify higher- and lower-risk jurisdictions so they can prioritise resources. Supervisors, regulators and policymakers can access the Expert Editions for free. They use them to benchmark progress over time and against other jurisdictions, prepare for Financial Action Task Force evaluations and strengthen their supervisory approaches. Thank you to our expert reviewers Each year, we review the Basel AML Index methodology with external experts to make sure it remains accurate, transparent and relevant to evolving financial crime risks. This year’s meetings on 21 and 22 September 2026 brought together more than 40 experts from the public and private sectors, including regulators, supervisors, financial intelligence units, international organisations and financial institutions. We are very grateful to all participants for their time and for the meaningful and valuable contributions they made to the review. Their input shaped this year’s decisions in concrete ways: one of the changes described below was proposed by participants during the discussion. Participation in the review meeting does not indicate agreement with the decisions or a consensus among participants. Responsibility for the final decisions on the methodology rests with the Basel Institute on Governance. Four changes to the methodology Table 1 summarises the changes. Weightings of all five domains stay the same. | Domain | Change | Weight in overall score | |----------------------------------------|---------------------------------------------------------------------------------------------------------|-------------------------| | Corruption and fraud risks | TRACE Bribery Risk Matrix replaced by World Bank Enterprise Surveys data on bribery incidence and depth | 5% unchanged | | Political and legal risks | World Economic Forum Judicial Independence indicator replaced by V-Dem judiciary data | 3.33% unchanged | | Public transparency and accountability | PEFA data added as a fourth indicator; domain weight shared equally | 1.25% per indicator | | Financial transparency and standards | Financial Secrecy Index replaced by a new Financial, Tax & Customs Transparency indicator | 15% unchanged | Change 1: Bribery – incorporating data on firms’ direct experience The TRACE Bribery Risk Matrix is no longer updated. We initially proposed removing it and doubling the weight of Transparency International’s Corruption Perceptions Index. During the meeting, experts suggested the World Bank Enterprise Surveys as an alternative. We reviewed and accepted this suggestion. Based on the direct experience of private-sector firms, the Enterprise Surveys complement the perception-based Corruption Perceptions Index. Two of their indicators will be combined into a single score with a weight of 5 percent: - Bribery incidence is the percentage of firms that experienced at least one request for a bribe payment. - Bribery depth is the percentage of public transactions in which a gift or informal payment was requested. This will be included in the Corruption and Fraud Risks domain. Change 2: Judicial independence – V-Dem replaces discontinued data The World Economic Forum no longer regularly updates its Judicial Independence indicator. We will replace it with five indicators from the Varieties of Democracy V-Dem dataset, produced by a global research initiative based at the University of Gothenburg, Sweden. The indicators are: high court independence; lower court independence; compliance with high court decisions; compliance with the judiciary; and government attacks on the judiciary. The five indicators will be combined into a single score from 0 to 10, with higher scores indicating higher risk. The new indicator keeps the existing weight of 3.33 percent, within the Political and Legal Risks domain. Change 3: Public financial management – PEFA data added Data from Public Expenditure and Financial Accountability PEFA assessments will become the fourth indicator in the Public Transparency and Accountability domain. PEFA adds an assessment of public financial management systems, which the existing three indicators in this domain do not cover comprehensively. PEFA assesses 31 performance indicators across seven areas, from budget reliability and transparency of public finances to external scrutiny and audit. Its methodology covers both compliance and effectiveness. We will calculate a single PEFA score for each country, using country-level assessments only. The domain’s 5 percent weight will be shared equally between its four indicators, at 1.25 percent each. Change 4: A new Financial, Tax & Customs Transparency indicator In the Financial Transparency and Standards domain, the Tax Justice Network’s Financial Secrecy Index will be replaced by a new Financial, Tax & Customs Transparency indicator developed by the Basel AML Index team. It keeps the existing weight of 15 percent. The new indicator reduces duplication with data from the Financial Action Task Force, which the Index already uses directly. It also aims to improve consistency with the Index’s other indicators and extends coverage to 173 jurisdictions. It has two components: - Financial, tax and customs transparency. This uses 15 selected sub-indicators from the Global Forum on Transparency and Exchange of Information for Tax Purposes and the World Bank Business Ready framework. They cover tax information exchange, beneficial ownership, customs and border management, interoperability of public information systems, insolvency frameworks, commercial lending and safeguards for electronic payments. - Exposure through cross-border financial services. This uses International Monetary Fund IMF Balance of Payments data on financial services exports. It measures both materiality a jurisdiction’s share of global financial services exports and intensity the value of those exports relative to the size of its economy . Statistical testing shows that the new indicator is positively associated with the other components of the Basel AML Index, while remaining sufficiently distinct from them. New features for Expert Edition subscribers The following features are also being introduced to enhance the user experience. The Expert Edition of the Basel AML Index will introduce: - Wider coverage. The Expert Edition and Expert Edition Plus subscriptions will cover 247 jurisdictions, including additional dependencies and other areas covered by the ISO 3166-1 standard, which many international financial and compliance systems use. Where jurisdiction-specific data are unavailable, the score of the relevant sovereign state or administering jurisdiction will be used as a proxy. All proxy scores will be clearly identified in the dataset. - Faster sanctions updates. Sanctions lists will be updated within six working days of the relevant sanctions decisions, without waiting for the next quarterly data update. - Easier tracking of changes. Three new fields – Previous Score , Change in Overall Score and Change in Risk Level – show changes over time without the need to compare separate editions. This supports regular reviews of geographical risk assessments and internal jurisdiction risk classifications. - Version control. New Version Number and Last Updated On fields allow users to document which version of the Basel AML Index they applied in their risk assessments. This supports internal record-keeping and supervisory audits. - Metadata sheet. A new dedicated sheet will describe every column in the dataset. This provides a common reference for interpreting the data and makes it easier to integrate them into internal risk assessment and compliance systems. A new streamlined subscription process, with clearer access rules for free and paid access to Basel AML Index data, is also in the works. What to expect in December The changes will apply from the 2026 edition of the Basel AML Index, to be published in early December 2026. As several indicators are changing, some jurisdictions’ scores and risk levels may shift as a result of the new methodology rather than a change in underlying risk. We recommend that users take this into account when updating their geographical risk assessments. Learn more - Explore the Basel AML Index and its current methodology. - Find out about Expert Edition and Expert Edition Plus subscriptions. - Register for the 2026 Basel AML Index launch event. - Contact the Basel AML Index team at index@baselgovernance.org.

What can corruption sanctions really achieve?

For victims of corruption and related human rights abuses, justice is often out of reach. Courts may be compromised, prosecutors unwilling to act and political leaders implicated in the wrongdoing. In such cases, corruption sanctions cannot deliver justice on their own. They may, however, provide something else: accountability, recognition and consequences. These questions were at the heart of a Basel Institute on Governance webinar marking the launch of the working paper Corruption sanctions: What governments need to know. Commissioned by the Basel Institute's International Centre for Asset Recovery ICAR and written by Dr Anton Moiseienko, the paper examines how governments can use corruption sanctions more strategically as part of wider anti-corruption efforts. Andrew Dornbierer, Head of Policy and Research at ICAR moderated the online launch event bringing together experts with experience across sanctions policy, litigation, advocacy and victims' rights. Dr Anton Moiseienko was joined by Sir William Browder KCMG, CEO of Hermitage Capital and Head of the Global Magnitsky Justice Campaign, Michael O'Kane , Senior Partner at Peters & Peters, and Lyra Nightingale , Senior Legal Advisor at REDRESS. Recognition matters Sanctions are often judged by whether they change behaviour, recover assets or deter future wrongdoing. Lyra Nightingale argued that this overlooks another form of impact. If a targeted sanction, such as a corruption sanction, can convey recognition, acknowledgement and some sense of justice for victims, it has already had an impact. Drawing on REDRESS's work with survivors of torture and other serious abuses linked to corruption, Nightingale described how sanctions can validate victims' experiences and demonstrate international solidarity when other routes to justice have failed. Examples from Iran and Angola illustrated the point. Victims and civil society groups viewed sanctions not simply as restrictions imposed on perpetrators, but as public acknowledgement that wrongdoing had occurred and that it mattered. Sanctions cannot provide a complete remedy, but they help signal that impunity is not absolute. Success means different things A recurring theme throughout the webinar was that sanctions are expected to achieve many things at once. Moiseienko argued that governments use corruption sanctions for a range of purposes: disrupting access to international financial systems, deterring future misconduct, condemning wrongdoing and supporting accountability efforts. Given this broad scope: It would be perverse to conclude that if corruption does not stop, sanctions have failed. That observation goes to the heart of the debate. Corruption sanctions are often directed at the most powerful and entrenched offenders. Eliminating corruption entirely is rarely a realistic objective. The more relevant question is whether sanctions increase pressure, restrict opportunities and support broader accountability efforts. The answer depends on what governments are trying to achieve. Do sanctions work? Here the panellists diverged. Drawing on years of experience representing sanctioned individuals, Michael O'Kane cautioned against assuming that sanctions automatically produce meaningful results. For some people, sanctions are profoundly impactful. For others, they are not particularly impactful at all. He argued that sanctions are most effective when they form part of a broader strategy that includes enforcement, asset recovery and clear incentives for behavioural change. Sir William Browder took a more forceful view. Reflecting on Russia's response to Magnitsky sanctions, he pointed to the extraordinary lengths taken to challenge and discredit the measures. So we know that we hit the Achilles' heel. For Browder, the reaction itself is evidence of effectiveness. Sanctions restrict access to assets, travel and international financial networks. They also create uncertainty among others who may fear becoming targets themselves. The disagreement was less about whether sanctions matter than about how much they can achieve on their own. Legitimacy is part of effectiveness The discussion repeatedly returned to legitimacy. Several speakers warned that sanctions derive much of their power from public confidence in their fairness and credibility. If they are perceived as arbitrary or politically motivated, their effectiveness may weaken over time. Moiseienko argued that governments should resist the temptation to use sanctions indiscriminately. The moment governments begin to look trigger-happy, indiscriminate or undisciplined in their use of sanctions, confidence in the entire system risks collapsing. Questions of transparency, evidence and due process therefore matter not only for legal reasons but also for practical ones. The legitimacy of sanctions is one of their greatest strengths. It can also be one of their greatest vulnerabilities. An evolving tool Corruption sanctions are now firmly established in the international anti-corruption landscape. Yet many of the questions surrounding them remain unresolved. - How should success be measured? - What role should sanctions play alongside criminal investigations and asset recovery efforts? - How can governments maintain public confidence while responding to evolving geopolitical pressures? As Andrew Dornbierer noted: Corruption sanctions are still a relatively new area of law and policy, and there will undoubtedly be significant developments in the years ahead. The webinar offered no single answer to these questions, but gave a sense of both the promise and the limitations of corruption sanctions. They are neither a cure-all nor a symbolic gesture. Used strategically, they can support accountability, recognise victims and increase pressure on those who have long operated with impunity. Learn more ::: links - Working Paper "Corruption sanctions: What governments need to know" - For policymakers grappling with these challenges, this Basel Institute’s Working Paper provides a valuable starting point. - Quick Guide to corruption sanctions - For an easy introduction to the concept. - Webinar recording - Watch the full webinar on YouTube. :::

Holding the corrupt to account: the promise and potential of corruption sanctions

When states fail to hold corrupt actors to account, ordinary citizens pay the price. Corruption sanctions were born from the idea that no one should be above the law, no matter where they are in the world. In a new Working Paper, Dr Anton Moiseienko explores how these tools have evolved and offers recommendations for their more effective and legitimate use. Here we share the foreword to his paper by the Basel Institute's Andrew Dornbierer, Head of Policy and Research, International Centre for Asset Recovery. Foreword Every state has an obligation to investigate and prosecute corruption within their jurisdiction. Unfortunately, many states around the world are not willing to fulfil this responsibility. As a result, the very individuals within these states tasked with serving the public interest are instead given free rein to commit acts that not only serve themselves but also corrode the fabric of the state. And ordinary citizens have no alternative but to endure the ensuing economic and social damage. The development of sanctions tools targeting corruption stemmed from the idea that justice should be universal; that no one in any society around the world should be above the law. They are powerful tools, built on powerful principles. States introducing them understand that unchecked corruption will always suffocate a state’s ability to provide security, fairness and prosperity to its citizens. Comparatively though, corruption sanctions are still an underdeveloped concept and are far from perfect. Only a handful of states have introduced them, and those that have are not often using them to their full potential. They also spark valid concerns surrounding due process. These criticisms shouldn’t be ignored: they offer an insight on how these tools could be further developed and enhanced to ensure that they are more credibly and consistently applied. In his paper, Anton Moiseienko provides an excellent and well-researched overview of how corruption sanctions could be designed and employed to better achieve their potential. He explains how these tools have evolved over the last two decades and how they could be further refined to be more effective and achieve a wider range of impact. Critically, his paper is an indispensable resource for those looking to understand exactly how such sanctions can help states deter, disrupt and debilitate the notoriously corrupt that are unreachable through standard criminal justice tools. Learn more Read Dr Anton Moiseienko’s Working Paper “Corruption sanctions: What governments need to know” for a deeper analysis of the topic and key policy recommendations. Get a brief introduction to corruption sanctions from our related Quick Guide. Register for our public webinar "Corruption sanctions – reaching those beyond the law" on 18 June 2026, marking the launch of Dr Moiseienko's Working Paper.

EU closes sanctions loophole and validates the confiscation of proceeds of sanctions violations

A recent judgment of the Court of Justice of the European Union CJEU addresses two significant weaknesses in the effectiveness of EU sanctions enforcement. First, it makes it clear that an EU-wide ban on “brokering services” for military goods to or from Russia applies even when these goods do not physically enter EU territory. Second, it clarifies that the administrative confiscation of proceeds of sanctions violations is compatible with EU law, in effect allowing for confiscation orders to be issued automatically rather than through drawn-out criminal proceedings. The CJEU is the EU’s judicial authority, comprising the Court of Justice and General Court. The judgement is highly significant in the context of questions over the effectiveness of the EU’s enforcement of sanctions against Russia. It is also relevant to the efforts of EU member states to confiscate assets that are involved in sanctions violations. As argued in our 2023 Working Paper, states should have in place robust legal mechanisms to target assets that are involved in sanctions violations, including proceeds generated by companies that operate in violation of sanctions. The case: Russian military radios The Romania-based company Neves 77 Solutions SRL brokered a transaction involving the supply of 32 radio sets, 20 of which had been manufactured in Russia, on behalf of two companies based in non-EU countries. Neves received over EUR 2.98 million for the transaction, and the radios never entered EU territory. Even though the radios never physically entered the EU, the Romanian authorities still classified the deal as one involving “military goods” and ruled it a violation of EU sanctions under Article 2 2 a of Council Decision 2014/512/CFSP, as well as a violation of Romania’s own sanctions laws. The Article forbids the provision of brokering services related to military activities to persons and entities in Russia. Brokering services include “the negotiation or arrangement of transactions for the purchase, sale or supply”, as well as the selling or buying “of goods and technology or of financial and technical services”. As a result, the authorities imposed an administrative fine of RON 30,000 approximately EUR 6,000 and confiscated the entire proceeds of the transaction i.e. EUR 2.98 million . The Bucharest Regional Court referred to the CJEU seeking clarification on whether the prohibition on brokering services applied despite the goods never having physically entered the territory of the EU. It also asked whether Council Decision 2014/512/CFSP allowed for the confiscation of the entire proceeds of a brokering transaction. Closing the "brokering" loophole The CJEU considered that there is no requirement for goods to be imported into the EU in order for the deal to count as a sanctions violation under the above-mentioned Council Decision. This makes it clear that the prohibition on brokering services for military goods to or from Russia applies even if the latter never physically entered the territory of any EU member state. According to the CJEU, this interpretation ensures the effectiveness of the EU’s sanctions regime by preventing someone from simply bypassing them by routing relevant goods outside the EU paragraph 69 of the judgement . Confiscating proceeds of sanctions violations The CJEU found that the automatic confiscation of the proceeds in a brokering transaction through an administrative decision is compatible with EU law, provided it is based on clear legal provisions and serves the purpose of deterring violations. Ultimately, this also achieves the objectives pursued by Decision 2014/512/CSFP in response to Russia's actions in Ukraine paragraph 89 of the judgement . The Court also found that the confiscation was proportionate to the infringement, given the severity of the violation and the relatively low maximum fine under Romanian law approximately EUR 6,000 . In fact, the Court actually considered that the fine alone in this case would not be sufficient to deter such violations and that the confiscation of all the proceeds over EUR 2.98 million was necessary to dissuade companies from violating such prohibitions. The Court also affirmed that the right to property enshrined in Article 17 of the Charter of Fundamental Rights of the European Union is not absolute and can be subject to restrictions justified by objectives of general interest pursued by the EU. Finally, the CJEU called upon European Court of Human Rights case law to assert that where confiscation “is imposed separately from a criminal penalty” paragraph 95 of the judgement , sufficient procedural safeguards should be put in place to allow such measures to be challenged effectively. Why does this matter? The Neves 77 Solutions judgement addresses some of the uncertainties competent authorities and companies face when dealing with sanctions in the context of Russia’s war on Ukraine, especially concerning the scope of prohibited conducts such as brokering and the consequences of violations. The case also demonstrates how sanctions enforcement can lead to asset recovery: specifically, through the pursuit of the proceeds of sanctions violations. The judgment ensures greater legal consistency across the EU. It strengthens sanctions enforcement by providing clarity and closing loopholes, and by affirming the possibility of confiscating proceeds from violations, including through administrative proceedings. It not only enhances the rule of law but also widens the toolkit to recover assets related to sanctions through established legal means. Read more Working Paper 42: ‘From sanctions to confiscation while upholding the rule of law’ , by Andrew Dornbierer.

Task Force KleptoCapture: Unravelling illicit assets in the wake of Russia's invasion

A blog by Meraal Hakeem, a law student at the Arizona State University who is undertaking a legal research internship at the Basel Institute on Governance. In the aftermath of Russia’s invasion of Ukraine, the United States’ Department of Justice launched “Task Force KleptoCapture” in March 2022 to enhance its capacity to enforce sanctions and target assets suspected of bolstering the Russian regime. A stated objective of the Task Force was to use civil and criminal asset forfeiture mechanisms to seize confiscate assets of US-sanctioned individuals that could also be considered proceeds of crime. Spearheaded by the Department of Justice and drawing on the skills and resources of multiple law enforcement agencies including the Federal Bureau of Investigation, Marshals Service, Secret Service, Department of Homeland Security, Internal Revenue Service and Postal Inspection Service , the Task Force has now had almost 18 months to hunt down, freeze and subsequently confiscate proceeds of corruption, money laundering and sanctions evasion. But have they been successful in this part of their mission? Some major achievements In terms of permanent confiscation, the Task Force has already achieved a significant milestone. In February this year, USD 5.4 million belonging to Russian oligarch Konstantin Malofeyev was forfeited through unchallenged civil proceedings on the basis that he had been involved in an attempted sanctions violation. This figure, while substantial, pales in comparison to the total amount the Task Force has in its sights for potential criminal and civil confiscation. As of February 2023, the Task Force had frozen/restrained well over USD 500 million in assets belonging to individuals linked to the Russian regime, including: A USD 90 million luxury yacht owned by sanctioned Russian oligarch Viktor Vekselberg, allegedly involved in the violation of US bank fraud, money laundering and sanction statutes. A USD 300 million mega-yacht owned by Suleiman Kerimov, for violations of the International Emergency Economic Powers Act, money laundering and conspiracy laws. Two aircraft worth over USD 400 million owned by Roman Abramovich for violations of the Export Control Reform Act. A USD 45 million Boeing 737-7EM aircraft owned by Russian energy company PJSC LUKOIL and a USD 90 million Airbus A319-100 owned by sanctioned Russian oligarch Andrei Skoch for alleged sanctions violations and money laundering offences. 10 properties with a combined value of over USD 100 million linked to Russian oligarchs and agents, including luxury properties in Beverly Hills, New York, Washington DC and Florida. A clear early impact Having already achieved the forfeiture of USD 5.4 million, and with hundreds of millions more frozen or restrained, Task Force KleptoCapture has already shown it can have an impact. At the very least, the US has demonstrated how a concerted effort to target the proceeds of crime can achieve rapid results when backed by adequate resources and a strong asset recovery legislative framework. Beyond this, the Task Force has demonstrated an interesting approach to sanctions enforcement that goes beyond the norm, showing that it is possible to target sanctioned assets for forfeiture by proving that they are also the proceeds of crime. Taking this a step further, the US has also demonstrated how such funds can be subsequently repurposed to help victims of regimes under sanctions. In the context of Russia’s invasion of Ukraine, the US passed the Consolidated Appropriations Act of 2023, which authorises the US Attorney General to transfer any forfeited Russian-linked assets to Ukraine. The USD 5.4 million confiscated by Task Force KleptoCapture has already been authorised for transfer in this way, and it is likely that any future funds seized by the Task Force will be similarly directed. The required investment in infrastructure to rebuild Ukraine was estimated at approximately USD 411 billion back in March, and the number continues to grow as Russia’s war wages on. Initiatives such as Task Force KleptoCapture and the related Consolidated Appropriations Act have arguably provided one possible way for how at least a very small part of this bill could be funded. Learn more View our Working Paper 42: From sanctions to confiscation while upholding the rule of law by Andrew Dornbierer.

Quick Guide 43: Corruption sanctions

Working Paper 62: Corruption sanctions: What governments need to know

Policy Brief 12: De-risking of Russian clients: best intentions, unintended consequences

Working Paper 42: From sanctions to confiscation while upholding the rule of law