Corruption prevention

Advancing Malawi’s efforts against corruption and environmental crime

Malawi’s forests and wildlife are under growing pressure from illegal exploitation, driven by rising demand for natural resources and enabled by corruption and illicit financial flows. From illegal logging to wildlife trafficking, environmental crimes not only threaten biodiversity and local livelihoods, but also weaken public institutions and deprive the country of vital resources for sustainable development. Charcoal illustrates the complex challenges involved: According to Malawi’s National Charcoal Strategy 2017–2027, 97% of households rely on illegally and unsustainably sourced charcoal and firewood for cooking and heating. In response to the resulting deforestation and forest degradation, the government has tightened enforcement against illegal wood harvesting and charcoal production while promoting alternative cooking fuels. Building on several years of collaboration with government partners in Malawi, the Basel Institute on Governance is launching a new project to strengthen the country’s response to environment-related financial crime and corruption. The three-year initiative, Mainstreaming Malawi’s progress in tackling environment-related financial crime and corruption , is funded by the UK Department for Environment, Food & Rural Affairs DEFRA and implemented through the Basel Institute’s Green Corruption programme. Activities have commenced on the ground and will run through to June 2028. A joined-up approach: enforcement and prevention The project supports Malawi’s Department of National Parks and Wildlife, Department of Forestry and Anti-Corruption Bureau in strengthening both enforcement capacities and corruption prevention systems linked to wildlife and forestry crimes. Rather than focusing solely on individual criminal cases, the initiative takes a broader institutional approach. It combines financial investigation techniques and case-based mentoring with efforts focusing on prevention to strengthen internal controls, improve inter-agency coordination and reduce corruption vulnerabilities within environmental agencies themselves. Among the planned activities are: mentoring investigators and prosecutors working on corruption and money laundering cases linked to wildlife and forestry crime; supporting the development of digital case registration and tracking systems to strengthen case management from investigation to prosecution; helping Institutional Integrity Committees and internal auditors identify and mitigate corruption risks; and developing training, practical guidance and knowledge products to support long-term institutional capacity. Dr Amanda Cabrejo le Roux, Deputy Director of Green Corruption and the project lead, said: “This project represents a significant step forward in our efforts to support environmental agencies in protecting Malawi’s wildlife and natural resources, while also reinforcing institutional integrity. By combining financial investigation techniques with robust prevention systems, we help our government partners create a sustainable framework for countering financial crime linked to the environment.” Building on proven partnerships The project expands on earlier DEFRA-funded work implemented jointly by the Basel Institute and the Lilongwe Wildlife Trust, which helped strengthen anti-corruption responses to wildlife crime through a combination of enforcement support and corruption prevention measures. Through this and over a decade of engagement in Malawi, we enjoy strong working relationships with Malawi’s Anti-Corruption Bureau, Department of National Parks and Wildlife, Department of Forestry and Malawi Police Service – partnerships that now provide the foundation for broader and more ambitious work on environment-related financial crime. The initiative also connects to the Basel Institute’s wider Green Corruption programme, which supports governments and partners around the world in addressing corruption linked to environmental crime, climate change and the global energy transition. As global demand for timber, minerals and other natural resources increases, corruption risks linked to environmental exploitation are becoming more complex and transnational. Through our work in Malawi and beyond, the Basel Institute aims to strengthen the governance systems needed to protect natural resources, safeguard communities and ensure environmental policies can be effectively enforced. Learn more Find out about the Green Corruption programme. Interested in corruption and governance in the environmental space? Join the Countering Environmental Corruption Practitioners Forum, a global community of practitioners jointly led by the Basel Institute on Governance, Transparency International, WWF and TRAFFIC.

From seedlings to saplings of hope: updated report on promising efforts to address environmental corruption

The diversity of activities to prevent and combat corruption that harms the environment is laudable. But it is far from the scale needed to tackle today's corruption and environmental challenges. Adopted in 2019, UNCAC Resolution 8/12 – Preventing and combating corruption as it relates to crimes that have an impact on the environment – urges States Parties to the UN Convention Against Corruption UNCAC to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment. In 2023, the Basel Institute on Governance published its Working Paper 50, Seedlings of hope , providing a panorama of emerging and promising initiatives across the world since the adoption of Resolution 8/12. The new Working Paper Saplings of hope , prepared for the 11th Conference of the States Parties CoSP in Doha, Qatar in December 2025, highlights what progress has been achieved since then. The report was made possible by the generous support of the Principality of Liechtenstein. Below are the main takeaways, but we urge you to read the full Working Paper for concrete examples from Bolivia, Canada, Indonesia, Kenya, Madagascar, Malawi, Namibia, Ukraine and other countries. Corruption prevention measures States have implemented a host of initiatives to strengthen integrity systems. Most commonly, this included the revision and adoption of internal control policies, more dedicated risk management efforts, including through the establishment of corruption prevention committees, and a range of capacity building efforts to strengthen environmental agencies’ ability to mitigate their own corruption risks, such as workshops on ethics codes and other integrity measures. Whistleblower protection programmes were increasingly designed, implemented and promoted. Corruption risk assessments were conducted in sectors such as wildlife management, forestry and fisheries. Promising corruption prevention interventions include: Conducting regular corruption perception and experience surveys among staff. This can help assess both progress and the effectiveness of corruption prevention measures. It can also create baselines against which to measure progress. Not enough interventions and reform efforts start with such a baseline, which means they then struggle to assess progress. Involving high-level management and leadership at each stage of the corruption prevention approach. This can help develop ownership and accountability. Explaining how integrity efforts support the strategic and political priorities of the leadership is crucial to achieve this. It requires adapting technocratic approaches to be relevant to the institutional leadership. Stipulating a mandatory budget for corruption prevention across ministries, agencies and departments. This can help ensure that minimal investments in integrity and anti-corruption activities are effectively prioritised and implemented. Sanctions for not respecting the mandatory budget should be imposed. Launching awareness-raising campaigns to promote knowledge of anti-corruption measures. This is an important first step to their effective implementation. Developing whistleblowing mechanisms. They can help increase reporting and detection of corruption. To achieve their potential, whistleblower mechanisms require a strong system, reliable protections and an institutional culture that welcomes such feedback. Peer-to-peer learning for government representatives from different countries and institutions to exchange on corruption prevention actions. This can be relevant, as anti-corruption officials often struggle with similar institutional challenges. Peer exchanges can help people and institutions to learn from each other’s successes and challenges and jointly identify effective mitigation measures. Enforcement actions Several countries have investigated and prosecuted corruption cases linked to crimes that have an impact on the environment. Financial investigations and money laundering legislation are more frequently used to tackle these crimes. The systematic seizure and confiscation of assets is still just beginning, as is the creation of multi-agency and interdisciplinary task forces, nationally and internationally. However, enforcement actions on corruption as it relates to crimes that have an impact on the environment are still limited. Promising enforcement interventions include: Assessing the economic, social and environmental losses from cases of corruption linked to crimes that have an impact on the environment – and using these to calculate associated penalties and fines – can help compensate and restore some of the harm done. Combining calculations of losses due to corruption with those of losses due to the environmental crimes can result in stiffer sentences and penalties. Seizing and confiscating proceeds and instrumentalities of crime bank accounts, real estate, vehicles, machineries, etc. through the diverse legal instruments available in jurisdictions can help ensure that crime does not pay. It also removes the resources needed to continue activities that harm the environment, thereby halting ongoing destruction. Exploring legal avenues outside the anti-corruption field can help strengthen enforcement. These include legislation on money laundering and tax offences as well as the social re-use of seized and confiscation assets, sanctions and visa bans. Essential role of civil society and the media Alongside States, civil society organisations and the media have played an essential role in increasing our understanding of the relationship between corruption and crimes that have an impact on the environment. Their efforts span investigative reporting, publishing evidence-based research, capacity building, creating networks to bridge the gap between anti-corruption and environmental practitioners, as well as initiating strategic litigation cases. Their involvement is all the more commendable given that they are facing an increasingly repressive environment. The way forward As the Working Paper highlights, various activities are taking place to tackle corruption linked to crimes that have an impact on the environment. The paper picks out those that show significant promise. The diversity of engagements is laudable, but it is far from the scale needed to make a systemic difference to both societal corruption and environmental challenges. States Parties need to adapt and scale up initiatives that are effective or look promising, by, among other things: Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources. Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment. Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms. Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment. Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment. Making use of legal frameworks and testing new legal avenues to hold individuals and legal persons accountable, including through asset recovery and remedies to repair the damage. Engaging in platforms for representatives from governments, civil society and other stakeholder groups to exchange experiences and know-how in tackling corruption that has an impact on the environment. Sharing knowledge, case law, success stories, etc. Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity. Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related issues. As these initiatives have now been conducted for six years, there is a sufficient body to scrutinise their effectiveness and efficiency. It is therefore essential to rigorously assess these measures, especially in an environment of increasingly scarce financial resources. Addressing corruption that has an impact on the environment The Working Paper also makes a case for moving from the concept of “corruption as it relates to crimes that have an impact on the environment” to “corruption that has an impact on the environment”. Focusing solely on corruption linked to crimes that have an impact on the environment overlooks situations where corruption causes environmental harm without an associated criminal offence. It does not take into consideration pressing issues such as corruption linked to climate finance, renewable energy and the exploitation of critical minerals. Adopting a holistic approach is crucial to address all forms of corruption that affect the environment, and thus to protect the environment and people. Learn more Read the full Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8/12 and beyond View the recordings of the "Environment Day" at the 11th CoSP. Learn more about our Green Corruption programme

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.

Money dirtying: shining a light on how clean money turns into bribes

There’s a lot of attention to the laundering of “dirty money” – but very little about how clean money can be turned into bribes, kickbacks or payments to terrorists. Together with David Jancsics, I examined the money-dirtying strategies at the heart of one of the world’s most dramatic corruption scandals: the Lava Jato or Car Wash case. How did the multinational company Odebrecht manage to secretly channel millions in legitimately earned funds to bribe politicians and bureaucrats across the continent? Our article Turning Legally Obtained Resources into Illegal Payments: A Money Dirtying Scheme attempts to answer this question and to explore the networks of individuals and entities that made the schemes possible. Exploring the concept and practice of money dirtying could help practitioners get a more holistic view of major financial crime cases. It could also potentially lead to new ways to prevent, detect and intercept illicit financial flows. What is “money dirtying”? We use the term “money dirtying” to refer to the process by which clean, legitimate resources are turned into illicit payments used for corruption, the financing of terrorism and other illegal activities. The term was originally coined to describe the mechanisms of terrorism financing in the late 1990s and early 2000s. Following the terrorist attacks of 9/11, researchers worked to understand the financial structures that allowed Al-Qaeda to finance the attacks. We have repurposed the term to fit the field of corruption, but the underlying idea is the same. What are the typical characteristics? On the face of it, money dirtying has similar characteristics to money laundering: Complex, multi-layered schemes using redundant payments and fake contracts to make funds difficult to trace. The use of specialised professionals who can create sophisticated financial infrastructures and know all the tricks to evade detection. The use of informal actors such as halawadars or doleiros to escape regulatory radars. Often transnational, with money, resources and information shared along a cross-border network of individuals and entities. What makes it different to money laundering? The key differences lie in the purpose and the direction of the flow. Money laundering seeks to clean dirty money by reintegrating it into the legal financial system. It is a circular system, where the funds return to their point of origin. Money dirtying serves to transfer money undetected from the bribe giver to the bribe taker. It is linear. For example, in our case study, the money took the following route: In reality, it looked more like this: The Lava Jato case The Lava Jato case Operation Car Wash was a major judicial investigation launched in Brazil in 2009. Initially focused on money laundering and illegal activities linked to a car wash company, it quickly expanded into one of the largest corruption investigations in history. By the early 2010s, investigations and plea deals had exposed the intricate financial structures and corrupt management systems of the Odebrecht Group at the heart of a web of illicit payments in countries across the region. Unlike other cases, there is significant public information available about Lava Jato thanks to judicial investigations, journalistic work, academic studies and other reports. This allowed us to map and analyse the “money dirtying” network in detail. The case is also an ideal case study in advanced corruption schemes. It was large, long-running and used complex, multi-layered networks that spread across the world. Skeleton and muscles To map the complex networks of the Odebrecht Group’s money dirtying networks we looked at the data in two ways: We analysed the transactions, performing a social network analysis and looking at the “skeleton” of the network – how it was shaped, where transactions centred and how they moved. At the same time, we tried to understand the substance of the network. If you like, the muscles surrounding the skeleton. We read interviews and wiretaps, and looked at personal histories to understand the relationships between people in the network and how they operated together. We then created a coherent framework of both the “skeleton” and “muscles”. This includes a description of each role and its function within the network. So what? Paying more attention to how legitimate funds are channelled towards illegal activities can help anti-corruption practitioners to gain a more holistic view of major corruption schemes. With the increase in internal controls and regulatory scrutiny, those that engage in corruption are forced to use more sophisticated methods than just declaring bribes as “consultancy fees”, for example. A better understanding of these methods could help inform stronger internal controls and compliance systems. This focus also helps practitioners to see how some of the same methods – legal structures in offshore financial centres, shell companies, professional enablers, informal value transfer service providers for example – can be misused not only for money laundering but for other parts of a corruption scheme. The research also showcases the power of social network analysis in mapping the key individuals and entities involved in transforming clean money into illicit payments. Combined with evidence of their relations and interactions, this can create a valuable source of information for both law enforcement and the development of evidence-based strategies for targeting corrupt networks. Learn more Organisational forms of corruption networks: the Odebrecht-Toledo case Quick Guide 4: Social network analysis in combating organised crime and trafficking Research Case Study 3: Exposing the networks behind transnational corruption and money laundering schemes

New guidance for governments to engage business in preventing corruption

Companies and business associations play an important role in preventing and reducing corruption in the markets where they operate – something that governments also want to achieve. So how can governments and the private sector work together better to raise standards of integrity and fair business in specific countries and industries? To answer this, our Collective Action team has worked with the people on the front lines of governments’ corruption prevent efforts – anti-corruption authorities – to develop practical guidance with real examples. Published today, the guidance was co-developed with members of the Network of Corruption Prevention Authorities NCPA , of which the Basel Institute is an affiliated partner. Three avenues, global examples The user-friendly guidance document explains how governments and their anti-corruption agencies can engage with the private sector to prevent corruption in three ways: Collaborate and consult on corruption prevention activities in the private sector - by setting up events and platforms, providing advisory support, and engaging the private sector in developing national anti-corruption strategies. Support and incentivise the private sector to engage in corruption prevention activities and initiatives – by creating tangible business benefits for companies investing in compliance, incentivising companies to externalise their compliance programmes, and supporting compliance certification. Demonstrate leadership by becoming an active participant in Collective Action - by establishing Collective Action as the go-to approach for engaging with the private sector, implementing integrity tools in public procurement, and fostering compliance in state-owned enterprises. Many of the members involved in the collaboration are at the forefront of efforts to engage business in anti-corruption activities, often through Collective Action or similar multi-stakeholder approaches. The examples they provide cover France, Brazil, Malawi and others. Conference discussions – exploring further The first panel of our upcoming International Collective Action Conference will further explore this crucial topic – the importance of government engagement and support for Collective Action. The panel “Tailwind for Collective Action” on 30 June features the Comptroller General of Chile, the Director General of the Independent Commission Against Corruption of Mauritius and the International Affairs Officer of the French Anti-Corruption Agency. Moderated by our Head of Compliance and Collective Action Gemma Aiolfi, the panellists will discuss their support for Collective Action and share experiences in translating commitments into action. The speakers' experiences, along with the new guidance, will hopefully help governments progress from committing to using Collective Action to prevent corruption to actually using it to its full potential. Learn more Download the guidance here: Engaging the private sector in Collective Action against corruption We are grateful to the NCPA members who contributed their time and expertise to the discussions and document. We also thank the Siemens Integrity Initiative for supporting both the Conference and our participation in developing the guidance with our partners at the NCPA. The guidance will be updated on a regular basis to continue the discussion around government and private-sector engagement on issues of corruption. Contact Scarlet Wannenwetsch of our Collective Action team for more information or to contribute to future editions.

Research Case Study 3: Exposing the networks behind transnational corruption and money laundering schemes