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23 items tagged with "Law enforcement"

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Advancing Malawi’s efforts against corruption and environmental crime
26 May 2026

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.

How stronger borders can create smarter corruption: lessons from one of Europe's most strategic border crossings
26 May 2026

How stronger borders can create smarter corruption: lessons from one of Europe's most strategic border crossings

When Bulgaria joined the European Union in 2007, many believed it would lead to more secure, transparent and less corrupt borders. New regulations, infrastructure modernisation and digitalised customs procedures all followed. European standards and money arrived together. Yet corruption did not disappear at the Kapitan Andreevo border checkpoint, the main land crossing between Bulgaria and Türkiye and one of the busiest gateways between Europe and Asia. Instead, it evolved. This is the central finding of a recent article by the Prevention, Research and Innovation team of the Basel Institute on Governance – Dr Jacopo Costa, Dr Claudia Baez Camargo, Noémi Jäger and Dr Saba Kassa – published in the Journal of Illicit Trade, Financial Crime, and Compliance . The article examines how criminal networks, smugglers, businesses and corrupt officials adapted to Bulgaria’s EU integration. It illustrates how corruption behaves like an adaptive ecosystem: when regulations and border control technologies change, corruption changes with them. A border built for opportunity – legal and illegal Border spaces concentrate discretionary power in the hands of customs officers, border guards, inspectors and regulators, while bringing together also traders, transport companies, migrants, smugglers, criminal groups and political actors. Kapitan Andreevo is a particularly instructive case due to its strategic location, with thousands of trucks, travellers and goods passing through the border checkpoint daily. Before Bulgaria’s EU accession, corruption at the checkpoint was already deeply embedded. The 1990s brought economic crisis, shortages of consumer goods, weak state capacity and rapidly expanding informal markets. Smuggling became a profitable survival strategy. Border officials could be bribed to overlook undeclared goods, counterfeit products and tax evasion. Duty-free shops in the "no man's land" between Bulgaria and Türkiye became hubs for smuggling cigarettes, alcohol and petroleum products. Corruption operated at multiple levels: everyday exchanges between traders, drivers and officials, often based on long-standing personal relationships, at the lower level connections between politicians, senior civil servants, business elites and organised crime at the higher level. Smuggling routes required political protection. Profits flowed upward through patronage systems. EU accession changed the rules of the game Bulgaria’s EU accession radically transformed the legal and institutional environment. The country had to align its customs regulations, VAT rules, excise tax systems, phytosanitary standards and border procedures with EU standards – a gradual process requiring significant investment. The reforms affected almost every aspect of border governance. Customs procedures became increasingly digitalised. New systems such as the VAT Information Exchange System VIES and the Excise Movement and Control System EMCS improved cross-border monitoring. Phytosanitary and veterinary inspections became stricter. Migration controls tightened through alignment with Schengen rules and access to systems like the Schengen Information System SIS and international databases of stolen documents and vehicles. Meanwhile, new border control technologies – X-ray machines, scanners, thermal cameras and risk-analysis tools – expanded the state’s capacity to detect illicit activity. From a policy perspective, this appeared to be a modernisation success story. But criminal systems rarely remain static when the environment changes. Corruption did not decline – it adapted The most striking finding is that stronger controls often increase the strategic value of corruption. After EU accession, crossing the border illegally became more difficult, risky and expensive. Corruption became necessary not only to speed up procedures but to bypass sophisticated control and regulatory systems. In other words, modernisation transformed the function of corruption: Criminal actors began targeting specialised procedures, such as food safety inspections, VAT systems, automated license plate recognition, laboratory testing and digital customs controls. VAT fraud and the manipulation of digital systems VAT fraud illustrates this adaptation clearly. Within the EU, exports are often subject to a VAT rate of 0 zero percent, which means companies can reclaim any VAT they have already paid domestically. Criminal actors exploited this through "carousel fraud" schemes involving fictitious transactions chains. At Kapitan Andreevo border checkpoint, for example, corruption allegedly enabled traders to manipulate customs procedures. One method involved corrupt officials manually entering fake truck registrations into customs systems to simulate border crossings, enabling fraudulent VAT refunds for exports that never occurred. Even more revealing was the manipulation of automated license plate recognition: corrupt actors reportedly disabled automated recognition and manually entered altered plates using Cyrillic characters resembling Latin letters, allowing smugglers to bypass alerts and inspections. This illustrates a pattern seen in many modern corruption systems: digitalisation does not automatically eliminate corruption. Instead, corruption turns towards the technological systems themselves. Food safety, privatisation and rent-seeking EU food safety and phytosanitary regulations created new bottlenecks and forms of discretionary authority. The research describes two recurring manipulation strategies: selective sampling during inspections, where officials took samples only from "clean" sections of shipments; and falsification of laboratory tests to certify unsafe products as compliant. These risks increased after some border functions were outsourced to private companies. At Kapitan Andreevo, food testing, parking operations and vehicle disinfection were privatised. This reform, intended to increase efficiency, allegedly created new opportunities for rent extraction. The controversy surrounding Eurolab 2011, which reportedly obtained monopolistic control over food safety testing under questionable legal arrangements became emblematic of these tensions. The broader implication: privatisation of public functions does not necessarily reduce corruption risks. It can shift them into hybrid public-private arrangements where accountability is weaker and oversight is more fragmented. The rise of “routinised” corruption The study highlights the increased organisation of corruption itself. Today, no single official can independently guarantee a smuggling route. Procedures involve multiple agencies, overlapping inspections and layered oversight. As a result, corruption evolved towards collective coordination. Customs officers, border guards, supervisors, intermediaries and sometimes political actors participate in networks where bribes are pooled and redistributed. These schemes resemble coordinated organisational systems with revenue-sharing mechanisms, internal hierarchies and protection structures rather than isolated rogue actors. This reflects an important conceptual change: border corruption can function as an embedded institutional ecosystem sustained through cooperation, mutual dependence and political protection. Drug trafficking: when corruption becomes too risky Interestingly, corruption is not always the preferred strategy. In drug trafficking, for example, the risks are dramatically higher. Border officials caught facilitating drug trafficking could face severe criminal penalties, including organised crime charges and lengthy prison sentences. As a result, traffickers increasingly invest in sophisticated concealment methods. One example is the "twin trucks" strategy: several nearly identical trucks carrying similar cargo cross the border simultaneously during heavy traffic, with only one of them containing drugs. Since inspection capacity is limited, the probability is high that the "clean" trucks are checked while the drug shipment passes undetected. This shows that corruption and criminality do not always go hand in hand. Sometimes, stronger anti-corruption measures push criminals towards deception and concealment rather than bribery. The bigger lesson: criminal systems are adaptive The case study of the Kapitan Andreevo border crossing is not just about Bulgaria. Policymakers often assume that more technology, controls and regulation will automatically reduce corruption and illicit trade. But criminal systems and corruption adapt. Informal networks reorganise around the vulnerabilities created by reforms. Every regulatory innovation creates new incentives, bottlenecks and opportunities for exploitation. This does not mean reforms are useless. Many EU measures have clearly strengthened border management. However, reforms must be designed with an understanding of adaptive behaviour. Otherwise, states risk producing unintended consequences: stronger incentives for bribery, use of alternative trafficking routes, technological manipulation, new forms of collusion or opaque privatisation structures. I and my co-authors argue for a more integrated approach that combines anti-corruption and anti-crime strategies. We also emphasise the importance of anticipatory governance and foresight-oriented policymaking that try to predict how illicit actors will respond to institutional changes before reforms are implemented. This may be the most important lesson from Kapitan Andreevo. Borders are not static lines defended by static institutions against static threats. They are evolving ecosystems where states, markets, technologies and criminal actors constantly adapt to one another. Learn more Access the full article, “The Evolution of Corruption and Crimes at Kapitan Andreevo Border Checkpoint: The Impact of EU Accession”. Read our Quick Guide 38 to border corruption for a short introduction. Read our Working Paper 58, “Corruption as a facilitator of drug trafficking in the port of Rotterdam” for a related analysis.

From seedlings to saplings of hope: updated report on promising efforts to address environmental corruption
11 December 2025

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 corruption helps drug traffickers adapt to strengthened border enforcement
11 September 2025

How corruption helps drug traffickers adapt to strengthened border enforcement

Corruption at border points remains a pressing global issue, threatening not only border integrity but also the health, safety and security of our societies. It enables illicit trafficking, facilitates organised crime and undermines trust in public institutions. In our Working Paper 58 , Saba Kassa and Jacopo Costa examine how corruption facilitates drug trafficking through the port of Rotterdam. Through in-depth interviews with stakeholders, a review of judicial cases and desk research, the paper shows how trafficking and corruption strategies are changing in response to strengthened enforcement at border spaces. It contributes to the growing body of work that looks at corruption from a systemic viewpoint, analysing the relationships and adaptive capabilities that allow organised crime to thrive. The Working Paper was written as part of the FALCON Fight Against Large-scale Corruption and Organised Crime Networks project. The research supports efforts to develop more robust and forward-looking approaches to combat corruption and drug trafficking. Read the executive summary below. Unintended consequences of strengthened enforcement This Working Paper examines how corruption facilitates drug trafficking specifically cocaine through the port of Rotterdam, looking at the underlying drivers and strategies involved. Legal trade routes and commercial ports are especially attractive because of the high volumes of cargo, which make it possible to conceal illicit cargo under licit cargo. The spatial complexity of the port of Rotterdam also makes it difficult to fully secure it against criminal activity. Digging deeper into the facilitating factors of trafficking, the paper finds that, paradoxically, a main driver of rising border corruption is the increased political attention on and resources dedicated to fighting trafficking. Desk research and stakeholder interviews highlight that as authorities deploy new technology to improve detection, traffickers face more obstacles to operating effectively. Having someone on the inside then becomes increasingly important. So, an unintended but important consequence of the strengthened fight against drug trafficking is that corruption becomes even more essential for the operational success of organised crime networks. Customs officials are specifically vulnerable This study focuses specifically on the role of customs. Tasked with monitoring the import and export of goods, customs officers are important actors in the fight against drug trafficking. However, their role also makes them vulnerable: they have crucial knowledge on processes and procedures, access to systems and discretionary power that can be exploited by criminals. The desk research shows that corruption is used strategically to circumvent two important bottlenecks: the container screening and security as cargo enters the port, and the exit of drugs from the port. Traffickers may seek to obtain key information or direct assistance from customs officers. Collusion – coercion – infiltration These corrupt relationships and the emerging networks between members of crime groups and the customs officials are diverse. Some relationships can be characterised by collusion, where customs officials offer their services or are persuaded to cooperate. This collusion may be opportunistic or targeted. Other relationships can be characterised by coercion. Customs officials may be lured by financial reward, but this is accompanied by intimidation or the threat of violence to ensure that the officer cooperates and continues to cooperate. Our research highlights that the boundary between collusion and coercion is often blurred. Beyond collusion and coercion, we also see infiltration, which crosses the boundaries between the criminal, public and private. What emerges is less a matter of individual corruption and more akin to regulatory capture, where the public office position is held by a member of the criminal network. The review of the judicial cases shows that bribes involved in these schemes can amount to millions. To hide and use the illicit gains, traffickers rely on money laundering, disguising its source as legitimate. They often enlist the help of family and friends, a trusted inner circle or professional specialists. They may also hide cash at home or invest it in assets and businesses in the Netherlands or abroad. Adaptive corruption strategies A key finding of our research is that the criminal and corruption strategies used to facilitate drug trafficking are highly adaptive. The underlying driver of this adaptability is the unchanging demand for drugs and high profitability of the crime. This pushes traffickers to adopt new strategies to overcome hurdles in supplying the demand. Corruption strategies adapt in response to new enforcement measures. When control systems are changed and/or strengthened, corruption strategies evolve alongside them. This research identifies some key patterns: Stronger detection efforts increase the incentives for corruption. Evolving systems encourage a similar shift in corruption strategies. Anti-corruption and anti-trafficking measures may change the profile of those most vulnerable to being co-opted. The characteristics of corruption can also evolve, from collusion to coercion, to full infiltration of institutions and systems – with blurred lines in between. Trafficking strategies evolve, too Trafficking strategies are similarly adaptive. There have been increased efforts by the port to combat trafficking through enhanced detection and technology. This was initially reflected by increased drug seizures. But since 2024, drugs seizures have declined. The research findings provide an explanation for this: As detection strengthens, more drug seizures are made. But what may happen, too, is a response to these new measures. As the risk of detection increases, criminals may adapt their trafficking strategies to overcome the additional hurdles, including: changing concealment strategies; and changing modes of transport and trafficking routes, including to ports outside of the Netherlands. Red flags and risk indicators These developments highlight the complexity in understanding the impact of stronger anti-trafficking measures on both corruption and trafficking strategies. Trafficking and corruption are typically measured by detection, for example, by changes in the volume of drug seizures or the number of public officials caught engaging in corruption. But the elephant in the room is that increasingly sophisticated criminal strategies can hide what is really happening. This underscores the need to continuously strengthen our ability to recognise “red flags” of corruption and trafficking. Data-driven tools and refined risk indicators are critical for understanding how crime and corruption strategies are changing. A holistic understanding and improved foresight The evolving nature of criminal strategies is often likened to a game of chess: enforcement makes a move, and criminal networks adapt. But what now seems to be emerging is more troubling. When barriers to drug trafficking increase while demand remains unchanged, crime and corruption strategies adapt in ways that can deepen their impact on society, leading for example to the hardening of crime and associated violence. This makes anticipating how crime may adapt to changing anti-corruption and anti-trafficking strategies critical. Improved foresight and scenario-building capacities will be vital in order to develop more robust enforcement efforts against drug trafficking and mitigate the negative impact on society. A holistic approach is essential. Addressing corruption as a facilitator of drug trafficking requires a broad view of crime that focuses on understanding vulnerabilities, leveraging data and harnessing collaboration. The risk of trafficking routes changing are high, therefore, we must use every tool at our disposal to ensure effective and sustainable enforcement efforts. Learn more Download the full Working Paper 58: Corruption as a facilitator of drug trafficking in the port of Rotterdam: Drivers, strategies and implications View related online workshop for enforcement and research communities: Red flags at the frontier: detecting and disrupting border corruption in the EU , 23 September 2025 Acknowledgement and disclaimer FALCON is funded under the European Union’s Horizon Europe Framework Program Grant Agreement ID 101121281. The Basel Institute on Governance, as an associated partner without the right to receive funds directly from the European Research Executive Agency, has received funding from the Swiss State Secretariat for Education, Research and Innovation SERI . The contents of the Working Paper are the sole responsibility of the authors and do not necessarily reflect the views of the European Union, the European Research Executive Agency or SERI.

From prosecutor to asset recovery trainer: Tom Walugembe
17 June 2025

From prosecutor to asset recovery trainer: Tom Walugembe

The fight against corruption and financial crime provides career opportunities for people with different personal stories and backgrounds. In this blog, our colleague Tom Walugembe shares his journey from prosecutor in Uganda to asset recovery specialist in the training team of our International Centre for Asset Recovery. He reflects on the personal rewards of his work and the power of training to shape a meaningful path. This article is part of a new series on careers in fighting financial crime and opportunities to learn and study with the Basel Institute. Prosecuting financial crimes: challenging but enriching A career in fighting corruption is professionally enriching. Based on my experience as a former prosecutor, prosecution generally provides an excellent training and mentoring environment for a young lawyer. You get to practise your litigation skills almost daily, which is something you can hardly experience in law firms at that stage. I quickly realised that prosecuting financial crimes would be the pinnacle of my service as a prosecutor. After serving as a general crimes prosecutor for about four years, I was pleasantly surprised to be assigned to the Anti-Corruption department, which I had long dreamed of. Becoming a financial crimes prosecutor further honed my skills. Financial crime cases invariably attract the most accomplished criminal defence lawyers in any country. Prosecuting such cases against experienced and polished lawyers simultaneously enhances one's advocacy skills. Expanding skills, building networks, driving change Financial crimes are diverse, and practice in this area, whether as a prosecutor, investigator, or analyst, exposes individuals to various emerging fields such as cybercrime, cryptocurrencies, international trade law, capital markets, stocks and public procurement. This broadens practitioners' understanding across a wide range of issues, thereby enhancing their professional capabilities. Many financial crimes have a transnational dimension, and working in this field provides the opportunity to network with peers in the same field, whether at a national, regional or international level. Contributing to a nation's anti-corruption and asset recovery efforts brings job satisfaction in the knowledge that one is ultimately enhancing the security and economic development of one's country. Reflecting on my experiences, winning a significant corruption case gave me more fulfilment than any success I had in prosecuting general crime. How specialised training fuelled my career As financial crime is ever-evolving, combating it requires regular specialised training. Serving as a financial crimes prosecutor provided me with access to placement and on-the-job training opportunities, the most significant of which was becoming a certified Trainer through ICAR’s Train-the-Trainer programme. My service as a public prosecutor was a huge determinant in my award of a Chevening Scholarship to pursue my LLM at Queen Mary University of London. Attaining further education propelled me towards even better opportunities and eventually led to my joining the Basel Institute and ICAR team. My current role involves developing and delivering training programmes on financial investigations, asset recovery and related topics, primarily across Africa and other regions of the world. Over the past five years, working in this position at an internationally diverse institution such as the Basel Institute has enabled me to collaborate closely with exceptionally talented and dedicated individuals from various parts of the globe. Contributing to capacity building and transferring skills to practitioners from diverse countries brings immense satisfaction. The opportunity to network and forge friendships with professionals diligently working in their nations to combat financial crime is invaluable. While nothing comes without hurdles, I would unreservedly encourage young professionals to enter the anti-corruption field without hesitation. Inspired? Learn more about our Basel STUDY programmes on anti-corruption and asset recovery – a chance to boost your skills, knowledge and career.

Publications

14 items
Case Study 13: The Beauty Queen case: non-conviction based forfeiture across borders
Case Study

Case Study 13: The Beauty Queen case: non-conviction based forfeiture across borders

31 Mar 2026·Basel Institute on Governance

This Case Study analyses how Colombian authorities recovered assets linked to drug trafficking and held in a trust in Guernsey. It sets out the legal tools and procedures in Colombia and in Guernsey that enabled Colombia’s first international recovery under its non-conviction based forfeiture model Extinción de dominio. The Case Study highlights lessons for international cooperation between jurisdictions with different forfeiture systems or even legal traditions.

The International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance provided technical assistance as part of a Memorandum of Understanding with the General Prosecutor’s Office of Colombia.

Download Case Study here

On 30 November 2023, the Fourth Court of the Specialised Extinción de Dominio Circuit of Colombia ordered the non-conviction based forfeiture of a Guernsey trust account issued by Northern Trust Fiduciary Services (Guernsey) Limited. The beneficiary was María Marcela Serrano Camacho, a Colombian model and former beauty queen.

The Colombian forfeiture order extinguished property rights over the account – amounting to GBP 361,146 – on the grounds that the funds were the proceeds of drug trafficking offences committed by Efraín Antonio Hernández Ramírez (“Don Efra”), a well-known Colombian drug trafficker, and his former spouse María Serrano in the 1990s.

On 30 January 2025, following successful mutual legal assistance proceedings between Colombia and the Bailiwick of Guernsey, the two jurisdictions concluded an asset sharing agreement for the repatriation of the confiscated assets.

This marked Colombia’s first successful international recovery through non-conviction based forfeiture.

This Case Study examines how early and effective coordination between Colombia and Guernsey enabled the identification, freezing, forfeiture and repatriation of the assets. It analyses the legal framework underpinning Colombia’s Extinción de dominio regime and how it was applied, leading to the forfeiture of the Guernsey acccount. It also describes the procedural mechanisms used in Guernsey to execute foreign non-conviction based forfeiture orders.

The interaction between the authorities in both jurisdictions offers valuable lessons and examples of good practices.

Main takeaways of the case:

  • Early and trust-based international cooperation is decisive
  • Non-conviction based forfeiture is indispensable when criminal routes are closed
  • Identifying beneficial ownership is central to effective asset recovery
  • Direct enforcement of foreign forfeiture orders increases efficiency and legal certainty
  • Asset sharing agreements strengthen cooperation incentives

The Case Study can be read alongside Policy Brief 16: “Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres”.

About this Case Study

This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BYNC-ND 4.0).

The Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery.

This is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.

Disclaimer: This Case Study is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. The contents are the sole responsibility of the authors and do not necessarily reflect the views or the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.

Non-conviction based forfeitureInternational cooperationAnti-money launderingLaw enforcementAsset recovery
Policy Brief 16: Enforcing foreign non-conviction based forfeiture orders
Policy Brief

Policy Brief 16: Enforcing foreign non-conviction based forfeiture orders

31 Mar 2026·Basel Institute on Governance

This Policy Brief analyses emerging international standards aimed at addressing recurring challenges in judicial practice with regard to the enforcement of non-conviction based forfeiture orders issued by foreign states. It focuses in particular on the historical absence of a binding obligation on requested states to cooperate in such cases and, where cooperation is available, on the structural tension between direct and indirect enforcement models.

Download Policy Brief here

Revisions in 2023 to the Financial Action Task Force (FATF) Recommendations 4 and 38 seek to clarify and strengthen states’ cooperation in the enforcement of foreign forfeiture orders. In this context, the recognition and execution of foreign non-conviction based forfeiture orders are central components of the evolving international asset recovery framework.

Through analysis and case studies involving Latin American states and international financial centres, this Policy Brief demonstrates that the choice of procedural model for enforcing foreign forfeiture orders – direct or indirect – has significant implications, while acknowledging the competing legal and institutional interests involved.

In line with FATF Recommendation 38, the Policy Brief argues in favour of direct enforcement in the requested state, based on the facts established by the foreign authority. This promotes efficiency, legal certainty and mutual trust. Indirect enforcement models that may require domestic investigations by the requested state, on the other hand, often lead to delays, duplication and increased costs, which hinders international asset recovery efforts.

The analysis provides empirical insight into how the revised FATF standards address practical deficiencies and the implications for judicial practice in requested states. For the Latin American context, the Policy Brief suggests to go beyond technical compliance of domestic non-conviction based forfeiture regimes with the FATF standards to strengthen the effectiveness of cross-border enforcement in practice.

This Policy Brief can be read alongside Case Study 13: “The Beauty Queen case: non-conviction based forfeiture across borders. Lessons learned from Colombia–Guernsey cooperation.”

About this Policy Brief

This publication is part of the Basel Institute on Governance Policy Brief series ISSN 2624-9669. You may freely share or republish it under a Creative Commons BY-NC-ND 4.0 licence.

It is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.

Disclaimer: This Policy Brief is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.

Suggested citation: Solórzano, Oscar. 2026. “Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres.” Policy Brief 16, Basel Institute on Governance. Available at: baselgovernance.org/publications/pb-16.

Non-conviction based forfeitureInternational cooperationAnti-money launderingLaw enforcement
Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8/12 and beyond
Working Paper

Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8/12 and beyond

11 Dec 2025·Basel Institute on Governance

At the 8th session of the Conference of the States Parties to the United Nations Convention against Corruption (UNCAC), in December 2019, States Parties adopted a resolution recognising the relationship between corruption and environmental crimes.

Resolution 8/12 – Preventing and combating corruption as it relates to crimes that have an impact on the environment – is a landmark Resolution. With its 23 operative paragraphs (OPs), it underlies the importance of addressing corruption linked to crimes that have an impact on the environment. It urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.

Saplings of hope presents an updated overview of emerging and promising prevention and enforcement actions, initiatives and measures implemented by UNCAC States Parties to combat corruption as it pertains to crimes that have an impact on the environment. It focuses specifically on initiatives from 2024 and 2025.

The Working Paper also underscores the valuable contributions made by non-state actors, in particular civil society, academia and the media, in this collective endeavour.

Finally, it makes the case for a paradigm shift, moving from “corruption as it relates to crimes that have an impact on the environment” to “corruption that has an impact on the environment”. The shift is necessary, because corruption can harm the environment without being linked to a crime that has an impact on the environment. Section 5 thus explores two interconnected issues which have a devastating impact on the environment: corruption linked to climate finance and renewable energy as well as corruption tied to the exploitation of critical minerals.

About this Working Paper

This report is part of the Green Corruption programme at the Basel Institute on Governance and was prepared in the context of the 11th Conference of the States Parties to the UN Convention against Corruption in Doha, Qatar, from 14–19 December 2025.

It provides an update to Working Paper 50, 'Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8/12’, which was prepared in the context of CoSP10 in Atlanta, Georgia, US in 2023.

The report is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. You may share or republish the report under a Creative Commons CC BY-NC-ND 4.0 licence.

It was made possible by the generous support of the Principality of Liechtenstein.

The contents are the sole responsibility of the authors and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.

EnvironmentCorruption preventionLaw enforcementCivil societyNatural resources
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