[{"data":1,"prerenderedAt":964},["ShallowReactive",2],{"tag-1227":3,"tag-events-1227-1":6,"tag-stories-1227-1":9,"tag-publications-1227-1":11,"tag-news-1227-1":545},{"id":4,"name":5},1227,"Sanctions",{"items":7,"total":8},[],0,{"items":10,"total":8},[],{"items":12,"total":544},[13,230,376],{"id":14,"status":15,"sort":16,"date_created":17,"date_updated":18,"nid":19,"slug":20,"title":21,"body":22,"citation":23,"language":24,"year":25,"publisher":26,"date_published":27,"external":28,"topic":29,"link_internal":31,"link_external":41,"featured":28,"topics":45,"languages":16,"type":47,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"image":49,"countries":60,"tags":134,"pdf":187,"authors":211},2446,"published",null,"2026-06-04T21:25:14.000Z","2026-06-04T21:40:35.000Z",2971,"quick-guide-43-corruption-sanctions","Quick Guide 43: Corruption sanctions","How can governments respond to serious corruption when those responsible are beyond the reach of the law?\n\nWeak institutions, political protection or limited law enforcement capacity can make it difficult to investigate or prosecute powerful individuals suspected of corruption. In response, some governments have turned to corruption sanctions.\n\nCorruption sanctions allow governments to impose restrictions on people suspected of serious corruption even without a criminal conviction.\n\nThis Quick Guide introduces corruption sanctions, explains how they work and highlights both their potential and the concerns they raise.\n\n### About this Quick Guide\n\nYou are free to share and republish this work under a Creative Commons \u003Ca href=\"http:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">BY-NC-ND 4.0 Licence\u003C\u002Fa>. It is part of the Basel Institute on Governance Quick Guide series, \u003Ca href=\"https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428\">ISSN 2673-5229\u003C\u002Fa>.","","English",2026,"Basel Institute on Governance","2026-06-02",false,[30],"Asset Recovery",[32,35,38],{"url":33,"caption":34},"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-62"," Read related Working 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PDF",[212],{"id":85,"publications_id":213,"authors_id":227},{"id":14,"status":15,"sort":16,"user_created":64,"date_created":17,"user_updated":65,"date_updated":18,"nid":19,"slug":20,"image":50,"title":21,"body":22,"citation":23,"language":24,"year":25,"publisher":26,"date_published":27,"external":28,"topic":214,"link_internal":215,"link_external":219,"featured":28,"topics":221,"languages":16,"type":222,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":223,"tags":224,"pdf":225,"authors":226},[30],[216,217,218],{"url":33,"caption":34},{"url":36,"caption":37},{"url":39,"caption":40},[220],{"url":43,"caption":44},[46],[48],[62,76,77],[79,80,81],[83],[85],{"id":228,"name":229,"position":16,"image":16},597,"Dr Anton Moiseienko",{"id":231,"status":15,"sort":16,"date_created":232,"date_updated":233,"nid":234,"slug":235,"title":236,"body":237,"citation":23,"language":24,"year":238,"publisher":26,"date_published":239,"external":28,"topic":240,"link_internal":242,"link_external":246,"featured":28,"topics":250,"languages":251,"type":252,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"image":254,"countries":261,"tags":262,"pdf":335,"authors":357},2295,"2023-06-30T08:38:07.000Z","2026-06-02T14:09:08.000Z",2480,"pb-12","Policy Brief 12: De-risking of Russian clients: best intentions, unintended consequences","After the Russian invasion of Ukraine and the wide-reaching sanctions which ensued, many Western financial institutions began to de-risk Russian clients. Dealing with Russian clients, in many cases, has become expensive from a compliance point of view and toxic from the reputational side.\n\nHowever, the de-risking of unsanctioned Russian individuals may have a significant impact on the fight against financial crime by potentially causing:\n\n\n- an increase in the use of shadow\u002Funregulated channels of moving money;\n- a withdrawal of funds away from the European zone to sanctioned countries or non-cooperative jurisdictions;\n- severe burdens on the investigation of financial crimes (especially in relation to Russian assets and investments) and on international cooperation in criminal matters;\n- increased opportunities for enablers, such as unscrupulous lawyers and accountants, to take advantage of the situation.\n\n\nThis Policy Brief outlines the current situation and suggests how to better manage risk without having a negative impact on the fight against financial crime.\n\n### About this Policy Brief\n\nThis publication is part of the Basel Institute on Governance Policy Brief series, \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications?type[]=257\">ISSN 2624-9669\u003C\u002Fa> and relates to the Basel AML Index of money laundering risk.\n\nYou may freely share or republish it under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (\u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa>). Suggested citation: Boguslavska, Kateryna. 2023. ‘De-risking of Russian clients: best intentions, unintended consequences.’ Policy Brief 12, Basel Institute on Governance, \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12\">https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12\u003C\u002Fa>.",2023,"2023-06-30",[241,30],"Anti-Money Laundering",[243],{"url":244,"caption":245},"\u002Fresources\u002Fpublications?type=Policy%20Brief"," View all Policy Briefs",[247],{"url":248,"caption":249},"https:\u002F\u002Findex.baselgovernance.org\u002F"," Visit Basel AML Index website",[241,46],[24],[253],"Policy Brief",{"id":255,"storage":51,"filename_disk":256,"filename_download":257,"title":258,"type":55,"created_on":232,"modified_on":232,"charset":16,"filesize":259,"width":57,"height":58,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":260,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":232},"8013d7b0-82aa-46f8-bde7-a8790f71a59e","8013d7b0-82aa-46f8-bde7-a8790f71a59e.jpg?itok=GwqFtxs0","Pages-from-230630-PB-12.jpg?itok=GwqFtxs0","Cover page of Policy Brief 12",59130,{},[],[263,286,303,318],{"id":264,"publications_id":265,"tags_id":283},4475,{"id":231,"status":15,"sort":16,"user_created":64,"date_created":232,"user_updated":65,"date_updated":233,"nid":234,"slug":235,"image":255,"title":236,"body":237,"citation":23,"language":24,"year":238,"publisher":26,"date_published":239,"external":28,"topic":266,"link_internal":267,"link_external":269,"featured":28,"topics":271,"languages":272,"type":273,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":274,"tags":275,"pdf":279,"authors":281},[241,30],[268],{"url":244,"caption":245},[270],{"url":248,"caption":249},[241,46],[24],[253],[],[264,276,277,278],4476,4772,4773,[280],2333,[282],2503,{"id":284,"name":285},818,"Anti-money 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PDF",[358],{"id":282,"publications_id":359,"authors_id":372},{"id":231,"status":15,"sort":16,"user_created":64,"date_created":232,"user_updated":65,"date_updated":233,"nid":234,"slug":235,"image":255,"title":236,"body":237,"citation":23,"language":24,"year":238,"publisher":26,"date_published":239,"external":28,"topic":360,"link_internal":361,"link_external":363,"featured":28,"topics":365,"languages":366,"type":367,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":368,"tags":369,"pdf":370,"authors":371},[241,30],[362],{"url":244,"caption":245},[364],{"url":248,"caption":249},[241,46],[24],[253],[],[264,276,277,278],[280],[282],{"id":373,"name":374,"position":16,"image":375},301,"Kateryna Boguslavska","24433c58-4115-4c6c-b220-142b5a1b135b",{"id":377,"status":15,"sort":16,"date_created":378,"date_updated":379,"nid":380,"slug":381,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":385,"link_internal":386,"link_external":387,"featured":28,"topics":388,"languages":389,"type":390,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"image":392,"countries":400,"tags":454,"pdf":526,"authors":527},2266,"2023-02-20T17:04:17.000Z","2026-05-31T22:52:10.000Z",2338,"wp-42","[Forthcoming] Working Paper 42: Confiscating assets frozen under sanctions without undermining the rule of law","This paper will be released on 21 February 2023.\n\nWritten in the light of Russia's war of aggression in Ukraine, the Working Paper explores whether it is justifiable to confiscate assets frozen under financial sanctions in order to redirect them to the victims of state aggression. \n\nThe paper first explores the concept of sanctions and financial sanctions (asset freezes) and what they mean in practice.\n\nUsing the example of Canada, which has introduced a legislative mechanism for this purpose, the paper analyses whether states should be able to confiscate sanctioned assets purely on the basis that they have been sanctioned.\n\nIt then looks at more established measures that states could adopt and apply to target sanctioned assets, including:\n\n\n- Traditional conviction based confiscation measures, including 'extended confiscation' mechanisms\n- Non-conviction based confiscation (forfeiture) measures\n- Unexplained wealth laws\n\n\nThe paper recommends ways to maximise the effectiveness of these alternative avenues for recovering assets, which are much less controversial and can arguably be applied without infringing on legal rights. \n\nOpting for mechanisms that abide by established legal rights will not only significantly increase the chance of recovering assets without subsequent legal challenges. It will also ensure that the very reason for targeting the assets in the first place – namely to seek justice and compensation for acts of aggression – is not undermined through the erosion of the rule of law. \n\n### About this Paper\n\nThis Working Paper was prepared by the Basel Institute on Governance.\n\nIt 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 (\u003Ca href=\"mailto:https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa>).\n\nSuggested citation: Dornbierer, Andrew. 2023. ‘Confiscating assets frozen under sanctions without undermining the rule of law.’ Working Paper 42, Basel Institute on Governance. Available at: \u003Ca href=\"mailto:https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42\">baselgovernance.org\u002Fpublications\u002Fwp-42\u003C\u002Fa>.\n\n### Acknowledgements\n\nThe Basel Institute would like to thank Isys Lam and the law firms of \u003Ca href=\"https:\u002F\u002Fbonifassi-avocats.com\u002Fen\u002F\">Bonifassi Avocats\u003C\u002Fa> (France), \u003Ca href=\"https:\u002F\u002Fwww.hengeler.com\u002Fen\">Hengeler Mueller\u003C\u002Fa> (Germany), \u003Ca href=\"https:\u002F\u002Fwww.bennettjones.com\u002F\">Bennett Jones\u003C\u002Fa> (Canada) and \u003Ca href=\"https:\u002F\u002Fwww.raassociados.pt\u002F\">Rogério Alves & Associados\u003C\u002Fa> (Portugal) for their support in providing research for this paper.\n\nThe Basel Institute would also like to thank Stefan Lenz, Stefan Cassella, Maria Nizzero, Nicola Bonucci and Oscar Solórzano for their support in reviewing the content of the paper and recommending amendments.","2023-02-20",[30],[],[],[46],[24],[391],"Working Paper",{"id":393,"storage":51,"filename_disk":394,"filename_download":395,"title":396,"type":55,"created_on":378,"modified_on":378,"charset":16,"filesize":397,"width":57,"height":398,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":399,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":378},"aaa4fae3-eea5-4be3-95b1-4de7e87fabb4","aaa4fae3-eea5-4be3-95b1-4de7e87fabb4.jpg?itok=PR2fFkgl","Pages-from-230213-Working-Paper-42-cover.jpg?itok=PR2fFkgl","Cover page of Working Paper 42",51358,708,{},[401,423,441],{"id":402,"publications_id":403,"countries_id":422},1057,{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":404,"link_internal":405,"link_external":406,"featured":28,"topics":407,"languages":408,"type":409,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":410,"tags":413,"pdf":419,"authors":420},[30],[],[],[46],[24],[391],[402,411,412],1058,1059,[414,415,416,417,418],4439,4444,4788,4789,4790,[],[421],2481,{"id":108,"name":109,"code":110,"latitude":111,"longitude":112},{"id":411,"publications_id":424,"countries_id":435},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":425,"link_internal":426,"link_external":427,"featured":28,"topics":428,"languages":429,"type":430,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":431,"tags":432,"pdf":433,"authors":434},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":436,"name":437,"code":438,"latitude":439,"longitude":440},188,"Russia","RU",61.52401,105.31876,{"id":412,"publications_id":442,"countries_id":453},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":443,"link_internal":444,"link_external":445,"featured":28,"topics":446,"languages":447,"type":448,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":449,"tags":450,"pdf":451,"authors":452},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":87,"name":88,"code":89,"latitude":90,"longitude":91},[455,468,483,496,511],{"id":414,"publications_id":456,"tags_id":467},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":457,"link_internal":458,"link_external":459,"featured":28,"topics":460,"languages":461,"type":462,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":463,"tags":464,"pdf":465,"authors":466},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":4,"name":5},{"id":415,"publications_id":469,"tags_id":480},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":470,"link_internal":471,"link_external":472,"featured":28,"topics":473,"languages":474,"type":475,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":476,"tags":477,"pdf":478,"authors":479},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":481,"name":482},821,"Unexplained wealth",{"id":416,"publications_id":484,"tags_id":495},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":485,"link_internal":486,"link_external":487,"featured":28,"topics":488,"languages":489,"type":490,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":491,"tags":492,"pdf":493,"authors":494},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":167,"name":168},{"id":417,"publications_id":497,"tags_id":508},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":498,"link_internal":499,"link_external":500,"featured":28,"topics":501,"languages":502,"type":503,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":504,"tags":505,"pdf":506,"authors":507},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":509,"name":510},1379,"Non-conviction based forfeiture",{"id":418,"publications_id":512,"tags_id":523},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":513,"link_internal":514,"link_external":515,"featured":28,"topics":516,"languages":517,"type":518,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":519,"tags":520,"pdf":521,"authors":522},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":524,"name":525},1215,"Illicit financial flows",[],[528],{"id":421,"publications_id":529,"authors_id":540},{"id":377,"status":15,"sort":16,"user_created":64,"date_created":378,"user_updated":65,"date_updated":379,"nid":380,"slug":381,"image":393,"title":382,"body":383,"citation":23,"language":24,"year":238,"publisher":26,"date_published":384,"external":28,"topic":530,"link_internal":531,"link_external":532,"featured":28,"topics":533,"languages":534,"type":535,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":536,"tags":537,"pdf":538,"authors":539},[30],[],[],[46],[24],[391],[402,411,412],[414,415,416,417,418],[],[421],{"id":541,"name":542,"position":16,"image":543},306,"Andrew Dornbierer","89aae58b-3e50-4375-9b9b-5b31370dab64",3,{"items":546,"total":963},[547,662,739,797],{"id":548,"status":15,"date_created":549,"date_updated":550,"title":551,"type":552,"body":553,"date":554,"topic":555,"slug":556,"activity":557,"nid":560,"topics":561,"activities":562,"programme":16,"area":16,"websites":16,"language":24,"image":563,"translation_of":16,"countries":572,"tags":605,"authors":645,"images":659,"translations":660,"content":661},10611,"2026-06-04T21:13:40.000Z","2026-06-04T21:13:41.000Z","Holding the corrupt to account: the promise and potential of corruption sanctions","Blog","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.\n\nHere we share the foreword to his paper by the Basel Institute's Andrew Dornbierer, Head of Policy and Research, International Centre for Asset Recovery.\n\n> ### Foreword\n> \n> 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.\n> \n> 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.\n> \n> 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.\n> \n> 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.\n> \n> 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.\n> \n> 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.\n> \n> 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.\n> \n> 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.\n\n### Learn more\n\n*   Read Dr Anton Moiseienko’s Working Paper “[Corruption sanctions: What governments need to know](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-62)” for a deeper analysis of the topic and key policy recommendations.\n*   Get a brief introduction to corruption sanctions from our related [Quick Guide](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fqg43).\n*   Register for our public webinar \"[Corruption sanctions – reaching those beyond the law](https:\u002F\u002Fbaselgovernance.org\u002Fnode\u002F2968)\" on 18 June 2026, marking the launch of Dr Moiseienko's Working Paper.","2026-06-03",[30],"holding-the-corrupt-to-account-the-promise-and-potential-of-corruption-sanctions-2979",[558,559],"Reports","Insights",2979,[30],[558,559],{"id":564,"storage":51,"filename_disk":565,"filename_download":566,"title":551,"type":567,"created_on":549,"modified_on":549,"charset":16,"filesize":568,"width":569,"height":570,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":571,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":549},"9f5fad98-9243-40da-98d0-1271edd00df2","9f5fad98-9243-40da-98d0-1271edd00df2.webp","tmp.webp","image\u002Fwebp",13600,800,453,{},[573,592],{"id":574,"news_id":575,"countries_id":591},7808,{"id":548,"status":15,"user_created":64,"date_created":549,"user_updated":64,"date_updated":550,"title":551,"type":552,"body":553,"image":564,"date":554,"topic":576,"slug":556,"activity":577,"nid":560,"topics":578,"activities":579,"programme":16,"area":16,"websites":16,"translation_of":16,"language":24,"countries":580,"tags":582,"authors":586,"images":588,"translations":589,"content":590},[30],[558,559],[30],[558,559],[574,581],7809,[583,584,585],5995,5996,5997,[587],1372,[],[],[],{"id":129,"name":130,"code":131,"latitude":132,"longitude":133},{"id":581,"news_id":593,"countries_id":604},{"id":548,"status":15,"user_created":64,"date_created":549,"user_updated":64,"date_updated":550,"title":551,"type":552,"body":553,"image":564,"date":554,"topic":594,"slug":556,"activity":595,"nid":560,"topics":596,"activities":597,"programme":16,"area":16,"websites":16,"translation_of":16,"language":24,"countries":598,"tags":599,"authors":600,"images":601,"translations":602,"content":603},[30],[558,559],[30],[558,559],[574,581],[583,584,585],[587],[],[],[],{"id":108,"name":109,"code":110,"latitude":111,"longitude":112},[606,619,632],{"id":583,"news_id":607,"tags_id":618},{"id":548,"status":15,"user_created":64,"date_created":549,"user_updated":64,"date_updated":550,"title":551,"type":552,"body":553,"image":564,"date":554,"topic":608,"slug":556,"activity":609,"nid":560,"topics":610,"activities":611,"programme":16,"area":16,"websites":16,"translation_of":16,"language":24,"countries":612,"tags":613,"authors":614,"images":615,"translations":616,"content":617},[30],[558,559],[30],[558,559],[574,581],[583,584,585],[587],[],[],[],{"id":4,"name":5},{"id":584,"news_id":620,"tags_id":631},{"id":548,"status":15,"user_created":64,"date_created":549,"user_updated":64,"date_updated":550,"title":551,"type":552,"body":553,"image":564,"date":554,"topic":621,"slug":556,"activity":622,"nid":560,"topics":623,"activities":624,"programme":16,"area":16,"websites":16,"translation_of":16,"language":24,"countries":625,"tags":626,"authors":627,"images":628,"translations":629,"content":630},[30],[558,559],[30],[558,559],[574,581],[583,584,585],[587],[],[],[],{"id":167,"name":168},{"id":585,"news_id":633,"tags_id":644},{"id":548,"status":15,"user_created":64,"date_created":549,"user_updated":64,"date_updated":550,"title":551,"type":552,"body":553,"image":564,"date":554,"topic":634,"slug":556,"activity":635,"nid":560,"topics":636,"activities":637,"programme":16,"area":16,"websites":16,"translation_of":16,"language":24,"countries":638,"tags":639,"authors":640,"images":641,"translations":642,"content":643},[30],[558,559],[30],[558,559],[574,581],[583,584,585],[587],[],[],[],{"id":185,"name":186},[646],{"id":587,"news_id":647,"authors_id":658},{"id":548,"status":15,"user_created":64,"date_created":549,"user_updated":64,"date_updated":550,"title":551,"type":552,"body":553,"image":564,"date":554,"topic":648,"slug":556,"activity":649,"nid":560,"topics":650,"activities":651,"programme":16,"area":16,"websites":16,"translation_of":16,"language":24,"countries":652,"tags":653,"authors":654,"images":655,"translations":656,"content":657},[30],[558,559],[30],[558,559],[574,581],[583,584,585],[587],[],[],[],{"id":541,"name":542,"position":16,"image":543},[],[],[],{"id":663,"status":15,"date_created":664,"date_updated":665,"title":666,"type":552,"body":667,"date":668,"topic":669,"slug":670,"activity":671,"nid":672,"topics":673,"activities":674,"programme":16,"area":16,"websites":675,"language":16,"image":677,"translation_of":16,"countries":685,"tags":686,"authors":718,"images":736,"translations":737,"content":738},10519,"2024-12-11T11:01:45.000Z","2026-05-29T22:22:33.000Z","EU closes sanctions loophole and validates the confiscation of proceeds of sanctions violations","A recent [judgment](https:\u002F\u002Fcuria.europa.eu\u002Fjuris\u002Fdocument\u002Fdocument.jsf?text=&docid=289926&pageIndex=0&doclang=EN&mode=req&dir=&occ=first&part=1&cid=4234034) of the Court of Justice of the European Union (CJEU) addresses two significant weaknesses in the effectiveness of EU sanctions enforcement.\n\nFirst, 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.\n\nSecond, 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.\n\nThe 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.\n\nIt 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](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42), 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.\n\n### The case: Russian military radios\n\nThe 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.\n\nEven 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\u002F512\u002FCFSP](https:\u002F\u002Feur-lex.europa.eu\u002Flegal-content\u002FEN\u002FTXT\u002F?uri=CELEX%3A32014D0512), as well as a violation of Romania’s own sanctions laws.\n\nThe 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”.\n\nAs 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).\n\nThe 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\u002F512\u002FCFSP allowed for the confiscation of the entire proceeds of a brokering transaction.\n\n### Closing the \"brokering\" loophole\n\nThe 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.\n\nAccording 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).\n\n### Confiscating proceeds of sanctions violations\n\nThe 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\u002F512\u002FCSFP in response to Russia's actions in Ukraine (paragraph 89 of the judgement).\n\nThe 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.\n\nThe Court also affirmed that the right to property enshrined in Article 17 of the [Charter of Fundamental Rights of the European Union](https:\u002F\u002Fwww.europarl.europa.eu\u002Fcharter\u002Fpdf\u002Ftext_en.pdf) is not absolute and can be subject to restrictions justified by objectives of general interest pursued by the EU.\n\nFinally, 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.\n\n### Why does this matter?\n\nThe 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.\n\nThe case also demonstrates how sanctions enforcement can lead to asset recovery: specifically, through the pursuit of the proceeds of sanctions violations.\n\nThe 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.\n\n### Read more\n\nWorking Paper 42: ‘[From sanctions to confiscation while upholding the rule of law](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42)’_,_ by Andrew Dornbierer.","2024-12-11",[30],"eu-closes-sanctions-loophole-and-validates-the-confiscation-of-proceeds-of-sanctions-violations-2732",[559],2732,[46],[559],[676],"Main page",{"id":678,"storage":51,"filename_disk":679,"filename_download":566,"title":666,"type":567,"created_on":680,"modified_on":680,"charset":16,"filesize":681,"width":682,"height":683,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":684,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":680},"22c6bf5c-045b-44c8-b222-bed6645b3caf","22c6bf5c-045b-44c8-b222-bed6645b3caf.webp","2025-05-12T21:10:00.000Z",88764,1400,933,{},[],[687,704],{"id":688,"news_id":689,"tags_id":703},5682,{"id":663,"status":15,"user_created":64,"date_created":664,"user_updated":65,"date_updated":665,"title":666,"type":552,"body":667,"image":678,"date":668,"topic":690,"slug":670,"activity":691,"nid":672,"topics":692,"activities":693,"programme":16,"area":16,"websites":694,"translation_of":16,"language":16,"countries":695,"tags":696,"authors":698,"images":700,"translations":701,"content":702},[30],[559],[46],[559],[676],[],[688,697],5683,[699],1097,[],[],[],{"id":4,"name":5},{"id":697,"news_id":705,"tags_id":717},{"id":663,"status":15,"user_created":64,"date_created":664,"user_updated":65,"date_updated":665,"title":666,"type":552,"body":667,"image":678,"date":668,"topic":706,"slug":670,"activity":707,"nid":672,"topics":708,"activities":709,"programme":16,"area":16,"websites":710,"translation_of":16,"language":16,"countries":711,"tags":712,"authors":713,"images":714,"translations":715,"content":716},[30],[559],[46],[559],[676],[],[688,697],[699],[],[],[],{"id":167,"name":168},[719],{"id":699,"news_id":720,"authors_id":732},{"id":663,"status":15,"user_created":64,"date_created":664,"user_updated":65,"date_updated":665,"title":666,"type":552,"body":667,"image":678,"date":668,"topic":721,"slug":670,"activity":722,"nid":672,"topics":723,"activities":724,"programme":16,"area":16,"websites":725,"translation_of":16,"language":16,"countries":726,"tags":727,"authors":728,"images":729,"translations":730,"content":731},[30],[559],[46],[559],[676],[],[688,697],[699],[],[],[],{"id":733,"name":734,"position":16,"image":735},553,"Rita Simões","bd333e72-3950-4c12-b55b-b6bc5cd448c7",[],[],[],{"id":740,"status":15,"date_created":741,"date_updated":742,"title":743,"type":552,"body":744,"date":745,"topic":746,"slug":747,"activity":748,"nid":749,"topics":750,"activities":751,"programme":16,"area":16,"websites":752,"language":16,"image":753,"translation_of":16,"countries":761,"tags":778,"authors":793,"images":794,"translations":795,"content":796},10390,"2023-09-25T10:01:31.000Z","2026-05-29T22:22:27.000Z","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._\n\nIn the aftermath of Russia’s invasion of Ukraine, the United States’ Department of Justice [launched “Task Force KleptoCapture”](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Fattorney-general-merrick-b-garland-announces-launch-task-force-kleptocapture) in March 2022 to enhance its capacity to enforce sanctions and target assets suspected of bolstering the Russian regime.\n\nA 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.\n\nSpearheaded 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?\n\n### Some major achievements\n\nIn 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](https:\u002F\u002Fwww.reuters.com\u002Fworld\u002Fus\u002Fhead-us-kleptocapture-unit-targeting-russian-oligarchs-leaves-doj-2023-07-27\u002F) through unchallenged civil proceedings on the basis that he had been involved in an attempted sanctions violation.\n\nThis figure, while substantial, pales in comparison to the total amount the Task Force has in its sights for [potential criminal and civil confiscation](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42). [As of February 2023](https:\u002F\u002Fwww.justice.gov\u002Fd9\u002Fpress-releases\u002Fattachments\u002F2023\u002F02\u002F24\u002F2023.02.23_doj_ukr_fact_sheet_final_1.pdf), the Task Force had frozen\u002Frestrained well over USD 500 million in assets belonging to individuals linked to the Russian regime, including:\n\n*   A [USD 90 million luxury yacht](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002F90-million-yacht-sanctioned-russian-oligarch-viktor-vekselberg-seized-spain-request-united) owned by sanctioned Russian oligarch Viktor Vekselberg, allegedly involved in the violation of US bank fraud, money laundering and sanction statutes.\n*   A [USD 300 million mega-yacht](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002F300-million-yacht-sanctioned-russian-oligarch-suleiman-kerimov-seized-fiji-request-united) owned by Suleiman Kerimov, for violations of the International Emergency Economic Powers Act, money laundering and conspiracy laws.\n*   [Two aircraft worth over USD 400 million](https:\u002F\u002Fwww.justice.gov\u002Fusao-sdny\u002Fpr\u002Funited-states-obtains-warrant-seizure-two-airplanes-russian-oligarch-roman-abramovich) owned by Roman Abramovich for violations of the Export Control Reform Act.\n*   A [USD 45 million Boeing 737-7EM](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Funited-states-obtains-warrant-seizure-45-million-airplane-owned-russian-energy-company-pjsc) aircraft owned by Russian energy company PJSC LUKOIL and a [USD 90 million Airbus A319-100](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Funited-states-obtains-warrant-seizure-airplane-sanctioned-russian-oligarch-andrei-skoch-worth) owned by sanctioned Russian oligarch Andrei Skoch for alleged sanctions violations and money laundering offences.\n*   [10 properties with a combined value of over USD 100 million](https:\u002F\u002Fwww.justice.gov\u002Fd9\u002Fpress-releases\u002Fattachments\u002F2023\u002F02\u002F24\u002F2023.02.23_doj_ukr_fact_sheet_final_1.pdf) linked to Russian oligarchs and agents, including luxury properties in Beverly Hills, New York, Washington DC and Florida.\n\n### A clear early impact\n\nHaving 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.\n\nAt 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.\n\nBeyond 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.\n\nTaking 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](https:\u002F\u002Fwww.congress.gov\u002F117\u002Fbills\u002Fhr2617\u002FBILLS-117hr2617enr.pdf), 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](https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Fattorney-general-merrick-b-garland-statement-anniversary-russia-s-invasion-ukraine), and it is likely that any future funds seized by the Task Force will be similarly directed.\n\nThe required investment in infrastructure to rebuild Ukraine was estimated at [approximately USD 411 billion](https:\u002F\u002Fwww.worldbank.org\u002Fen\u002Fnews\u002Fpress-release\u002F2023\u002F03\u002F23\u002Fupdated-ukraine-recovery-and-reconstruction-needs-assessment) 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.\n\n### Learn more\n\n*   View our [Working Paper 42: From sanctions to confiscation while upholding the rule of law](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42) by Andrew Dornbierer.","2023-09-25",[30],"task-force-kleptocapture-unravelling-illicit-assets-in-the-wake-of-russia039s-invasion-2506",[23],2506,[46],[],[676],{"id":754,"storage":51,"filename_disk":755,"filename_download":566,"title":756,"type":567,"created_on":757,"modified_on":757,"charset":16,"filesize":758,"width":682,"height":759,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":760,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":757},"348225aa-e25d-45e5-b179-d0c3f4c7090c","348225aa-e25d-45e5-b179-d0c3f4c7090c.webp","Task Force KleptoCapture: Unravelling illicit assets in the wake of Russia's invasion","2025-05-12T21:11:37.000Z",107412,1049,{},[762],{"id":763,"news_id":764,"countries_id":777},7168,{"id":740,"status":15,"user_created":64,"date_created":741,"user_updated":65,"date_updated":742,"title":743,"type":552,"body":744,"image":754,"date":745,"topic":765,"slug":747,"activity":766,"nid":749,"topics":767,"activities":768,"programme":16,"area":16,"websites":769,"translation_of":16,"language":16,"countries":770,"tags":771,"authors":773,"images":774,"translations":775,"content":776},[30],[23],[46],[],[676],[763],[772],4903,[],[],[],[],{"id":436,"name":437,"code":438,"latitude":439,"longitude":440},[779],{"id":772,"news_id":780,"tags_id":792},{"id":740,"status":15,"user_created":64,"date_created":741,"user_updated":65,"date_updated":742,"title":743,"type":552,"body":744,"image":754,"date":745,"topic":781,"slug":747,"activity":782,"nid":749,"topics":783,"activities":784,"programme":16,"area":16,"websites":785,"translation_of":16,"language":16,"countries":786,"tags":787,"authors":788,"images":789,"translations":790,"content":791},[30],[23],[46],[],[676],[763],[772],[],[],[],[],{"id":4,"name":5},[],[],[],[],{"id":798,"status":15,"date_created":799,"date_updated":800,"title":801,"type":552,"body":802,"date":803,"topic":804,"slug":805,"activity":806,"nid":808,"topics":809,"activities":810,"programme":16,"area":16,"websites":811,"language":16,"image":812,"translation_of":16,"countries":822,"tags":874,"authors":945,"images":960,"translations":961,"content":962},10339,"2023-02-21T17:01:25.000Z","2026-05-29T22:22:25.000Z","Working Paper sheds fresh light on the sanctions and confiscation debate","As the war in Ukraine intensifies, calls are growing for states to confiscate Russian assets frozen under sanctions and redirect them to provide support to Ukraine. Our latest Working Paper argues that states can and should do this by enhancing the effectiveness and scope of established asset recovery measures​​​​ – not by introducing new untested mechanisms that risk inviting future legal challenges, defeating the purpose of sanctions and violating the rule of law. \n\nGo straight to [Working Paper 42: From sanctions to confiscation while upholding the rule of law​​​​](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42) or read the key takeaways:\n\n### Executive summary\n\nIn light of recent world events, political leaders around the world have questioned whether it is justifiable to confiscate assets frozen under financial sanctions in order to redirect them to the victims of state aggression.\n\nSome states have even sought to introduce legislative mechanisms to make it possible to confiscate an asset frozen under sanctions, purely on the basis that the asset has been made subject to a sanction. One state – Canada – has already done so.\n\nThe intention behind these mechanisms is clear: assets frozen under sanctions could be confiscated and repurposed to provide assistance and compensation to the victims of the sanctioned target.\n\nIn the context of the Ukraine war, for example, proponents argue that these measures will allow states to permanently confiscate Russian-linked assets under sanction and redirect them to provide support to Ukraine.\n\n### The debate\n\nShould states be able to confiscate sanctioned assets\\* purely on the basis that they have been sanctioned?\n\nThe justifiability and legality of mechanisms such as Canada’s is currently the subject of debate. Two key issues include whether the confiscation of assets in such circumstances:\n\n*   is acceptable in the context of established legal rights and norms; \n*   defeats the primary purpose of sanctions as a tool of coercion.\n\n### Issues of property and due process rights\n\nWith regards to the first point, the lack of adequate judicial oversight included in such mechanisms, and the fact that these mechanisms aim to permanently deprive sanctioned targets of their assets, raises serious questions surrounding property and due process rights.\n\nIf such a mechanism was introduced in Europe for example, it is likely to be challenged on the grounds that it violates Protocol 1 Article 1 as well as Article 6 of the European Convention on Human Rights.\n\nIf such mechanisms were also applied to state-linked assets (such as sanctioned assets belonging to central banks) then this would also raise concerns regarding a possible infringement of domestic and international laws relating to state immunity.\n\n### Undermining the purpose of sanctions\n\nWith regards to the second point, permitting the confiscation of sanctioned assets arguably annuls the coercive purpose of sanctions regimes to act as a tool to persuade targets to cease their adverse behaviour.\n\nIf states are permitted to confiscate sanctioned assets (and make it impossible for a target to retrieve their frozen assets) then this effectively removes any incentive for the target to change their behaviour. In such cases, rather than operating as tools of coercion, sanctions would instead primarily operate to punish a target and provide compensation to the victims for the harm that has been caused.\n\nOf course, some have argued that there is a greater need for these latter objectives, particularly in the context of the war in Ukraine where financial assistance is required urgently.\n\nOthers however argue that despite the urgency this situation presents, the long-term objective of sanctions should remain coercion, particularly if sanctioning states wish to compel the aggressing state, Russia, to contribute to post-war reconstruction efforts in the future.\n\n### Other options through which to confiscate assets under sanction\n\nThere are, in addition, several established avenues for seeking war reparations that should also be explored.\n\nSuch established measures that states could adopt and apply to target sanctioned assets include:\n\n*   Traditional conviction-based confiscation measures, including ‘extended confiscation’ mechanisms\n*   Non-conviction based confiscation (NCB) measures\n*   Unexplained wealth laws\n\nThese measures could be used to target:\n\n*   Assets that are involved in sanctions violations\n*   Sanctioned assets that are also the proceeds of crimes unrelated to the sanctions regime, such as corruption or organised crime offences\n*   Unexplained wealth\n\n### Maximising effectiveness of established asset recovery mechanisms\n\nWhile these avenues may be limited, and can only result in the permanent confiscation of a portion of sanctioned assets, states could take various steps to maximise their effectiveness.\n\nFor example legislative amendments could be considered to broaden the scope of relevant terms like ‘money laundering’ and to specifically permit confiscated assets to be redirected to the victims of state aggression.\n\nDomestic and international coordination could be improved by creating dedicated law enforcement bodies for example, or through participating in international coordination initiatives.\n\nImportantly, these avenues target established criminal activity and\u002For include defined judicial processes through which a targeted person can challenge any attempts to confiscate their property. Therefore they can be applied without unacceptably infringing on legal rights.\n\nMoreover, if states take measures to enhance the effectiveness and scope of established asset recovery measures, additional benefits can be derived for the broader fight against financial crime and kleptocracy.\n\n### The bottom line: maintaining the rule of law\n\nOpting for mechanisms that abide by established legal rights will not only significantly increase the chance of recovering assets without subsequent legal challenges.\n\nIt will also ensure that the very reason for targeting the assets in the first place – namely to seek justice and compensation for acts of aggression – is not undermined through the erosion of the rule of law.\n\n_\\* The term ‘[sanctioned assets](https:\u002F\u002Fwww.lawinsider.com\u002Fdictionary\u002Fsanctioned-assets)’ is used as a shorthand to refer to assets of a sanctioned person or country._\n\n### Learn more\n\n*   [Download the Working Paper](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2023-03\u002F230309%20Working%20Paper%2042.pdf).\n*   Watch or read the main takeaways from a December 2022 panel discussion on [asset recovery developments since the start of the war in Ukraine](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fasset-recovery-developments-start-war-ukraine).","2023-02-21",[30],"working-paper-sheds-fresh-light-on-the-sanctions-and-confiscation-debate-2347",[807,559],"Research",2347,[46],[807,559],[676],{"id":813,"storage":51,"filename_disk":814,"filename_download":815,"title":801,"type":567,"created_on":816,"modified_on":817,"charset":16,"filesize":818,"width":819,"height":820,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":821,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":817},"f3b37dcf-a8eb-4ee4-9ef0-767e01dde1cf","f3b37dcf-a8eb-4ee4-9ef0-767e01dde1cf.webp","WP-42-mock-website.webp","2025-05-12T21:15:42.000Z","2026-05-06T07:35:02.000Z",104270,1200,801,{},[823,846,860],{"id":824,"news_id":825,"countries_id":845},7198,{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":826,"slug":805,"activity":827,"nid":808,"topics":828,"activities":829,"programme":16,"area":16,"websites":830,"translation_of":16,"language":16,"countries":831,"tags":834,"authors":840,"images":842,"translations":843,"content":844},[30],[807,559],[46],[807,559],[676],[824,832,833],7199,7200,[835,836,837,838,839],4913,4918,5712,5713,5714,[841],1148,[],[],[],{"id":108,"name":109,"code":110,"latitude":111,"longitude":112},{"id":832,"news_id":847,"countries_id":859},{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":848,"slug":805,"activity":849,"nid":808,"topics":850,"activities":851,"programme":16,"area":16,"websites":852,"translation_of":16,"language":16,"countries":853,"tags":854,"authors":855,"images":856,"translations":857,"content":858},[30],[807,559],[46],[807,559],[676],[824,832,833],[835,836,837,838,839],[841],[],[],[],{"id":436,"name":437,"code":438,"latitude":439,"longitude":440},{"id":833,"news_id":861,"countries_id":873},{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":862,"slug":805,"activity":863,"nid":808,"topics":864,"activities":865,"programme":16,"area":16,"websites":866,"translation_of":16,"language":16,"countries":867,"tags":868,"authors":869,"images":870,"translations":871,"content":872},[30],[807,559],[46],[807,559],[676],[824,832,833],[835,836,837,838,839],[841],[],[],[],{"id":87,"name":88,"code":89,"latitude":90,"longitude":91},[875,889,903,917,931],{"id":835,"news_id":876,"tags_id":888},{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":877,"slug":805,"activity":878,"nid":808,"topics":879,"activities":880,"programme":16,"area":16,"websites":881,"translation_of":16,"language":16,"countries":882,"tags":883,"authors":884,"images":885,"translations":886,"content":887},[30],[807,559],[46],[807,559],[676],[824,832,833],[835,836,837,838,839],[841],[],[],[],{"id":4,"name":5},{"id":836,"news_id":890,"tags_id":902},{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":891,"slug":805,"activity":892,"nid":808,"topics":893,"activities":894,"programme":16,"area":16,"websites":895,"translation_of":16,"language":16,"countries":896,"tags":897,"authors":898,"images":899,"translations":900,"content":901},[30],[807,559],[46],[807,559],[676],[824,832,833],[835,836,837,838,839],[841],[],[],[],{"id":481,"name":482},{"id":837,"news_id":904,"tags_id":916},{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":905,"slug":805,"activity":906,"nid":808,"topics":907,"activities":908,"programme":16,"area":16,"websites":909,"translation_of":16,"language":16,"countries":910,"tags":911,"authors":912,"images":913,"translations":914,"content":915},[30],[807,559],[46],[807,559],[676],[824,832,833],[835,836,837,838,839],[841],[],[],[],{"id":167,"name":168},{"id":838,"news_id":918,"tags_id":930},{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":919,"slug":805,"activity":920,"nid":808,"topics":921,"activities":922,"programme":16,"area":16,"websites":923,"translation_of":16,"language":16,"countries":924,"tags":925,"authors":926,"images":927,"translations":928,"content":929},[30],[807,559],[46],[807,559],[676],[824,832,833],[835,836,837,838,839],[841],[],[],[],{"id":509,"name":510},{"id":839,"news_id":932,"tags_id":944},{"id":798,"status":15,"user_created":64,"date_created":799,"user_updated":65,"date_updated":800,"title":801,"type":552,"body":802,"image":813,"date":803,"topic":933,"slug":805,"acti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