[{"data":1,"prerenderedAt":1311},["ShallowReactive",2],{"tag-1375":3,"tag-events-1375-1":6,"tag-stories-1375-1":9,"tag-news-1375-1":11,"tag-publications-1375-1":460},{"id":4,"name":5},1375,"Civil society",{"items":7,"total":8},[],0,{"items":10,"total":8},[],{"items":12,"total":459},[13,161,235,318,394],{"id":14,"status":15,"date_created":16,"date_updated":17,"title":18,"type":19,"body":20,"date":21,"topic":22,"slug":24,"activity":25,"nid":28,"topics":29,"activities":30,"programme":31,"area":31,"websites":31,"language":32,"image":33,"translation_of":31,"countries":43,"tags":44,"authors":126,"images":158,"translations":159,"content":160},10604,"published","2026-02-27T15:07:21.000Z","2026-02-27T15:07:22.000Z","From seedlings to saplings of hope: updated report on promising efforts to address environmental corruption","Blog","> 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.\n\nAdopted in 2019, UNCAC Resolution 8\u002F12 – _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.\n\nIn 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\u002F12.\n\nThe new Working Paper _Saplings of hope_, prepared for the [11th Conference of the States Parties (CoSP)](https:\u002F\u002Fwww.unodc.org\u002Fcorruption\u002Fen\u002Fcosp\u002Fconference\u002Fsession11.html) in Doha, Qatar in December 2025, highlights what progress has been achieved since then.\n\nThe report was made possible by the generous support of the Principality of Liechtenstein.\n\nBelow are the main takeaways, but we urge you to read the full [Working Paper](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-61) for concrete examples from Bolivia, Canada, Indonesia, Kenya, Madagascar, Malawi, Namibia, Ukraine and other countries.\n\n### Corruption prevention measures\n\nStates have implemented a host of initiatives to strengthen integrity systems.\n\nMost 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.\n\nWhistleblower protection programmes were increasingly designed, implemented and promoted. Corruption risk assessments were conducted in sectors such as wildlife management, forestry and fisheries.\n\nPromising corruption prevention interventions include:\n\n*   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.\n*   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.\n*   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.\n*   Launching awareness-raising campaigns to promote knowledge of anti-corruption measures. This is an important first step to their effective implementation.\n*   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.\n*   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.\n\n### Enforcement actions\n\nSeveral 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.\n\nThe 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.\n\nPromising enforcement interventions include:\n\n*   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.\n*   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.\n*   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.\n\n### Essential role of civil society and the media\n\nAlongside 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.\n\nTheir 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.\n\n### The way forward\n\nAs 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.\n\nThe 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:\n\n*   Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources.\n*   Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment.\n*   Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms.\n*   Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment.\n*   Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment.\n*   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.\n*   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.\n*   Sharing knowledge, case law, success stories, etc.\n*   Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity.\n*   Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related issues.\n\nAs 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.\n\n### Addressing corruption that has an impact on the environment\n\nThe 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”.\n\nFocusing 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.\n\nAdopting a holistic approach is crucial to address all forms of corruption that affect the environment, and thus to protect the environment and people.\n\n### Learn more\n\n*   Read the full Working Paper 61: [_Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-61)\n*   View the recordings of the \"[Environment Day](https:\u002F\u002Fbaselgovernance.org\u002Fcosp11env-day)\" at the 11th CoSP.\n*   Learn more about our [Green Corruption programme](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption)","2025-12-11",[23],"Green Corruption","from-seedlings-to-saplings-of-hope-updated-report-on-promising-efforts-to-address-environmental-corruption-2926",[26,27],"Reports","Insights",2926,[23],[26,27],null,"English",{"id":34,"storage":35,"filename_disk":36,"filename_download":37,"title":18,"type":38,"created_on":16,"modified_on":16,"charset":31,"filesize":39,"width":40,"height":41,"duration":31,"embed":31,"description":31,"location":31,"tags":31,"metadata":42,"focal_point_x":31,"focal_point_y":31,"tus_id":31,"tus_data":31,"uploaded_on":16},"186e3dc8-1f6d-4d45-ad33-596b4a3a7bb0","local","186e3dc8-1f6d-4d45-ad33-596b4a3a7bb0.webp","tmp.webp","image\u002Fwebp",17012,800,533,{},[],[45,68,83,98,111],{"id":46,"news_id":47,"tags_id":65},5627,{"id":14,"status":15,"user_created":48,"date_created":16,"user_updated":48,"date_updated":17,"title":18,"type":19,"body":20,"image":34,"date":21,"topic":49,"slug":24,"activity":50,"nid":28,"topics":51,"activities":52,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":53,"tags":54,"authors":59,"images":62,"translations":63,"content":64},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6",[23],[26,27],[23],[26,27],[],[46,55,56,57,58],5628,5629,5630,5631,[60,61],1369,1370,[],[],[],{"id":66,"name":67},1303,"Environment",{"id":55,"news_id":69,"tags_id":80},{"id":14,"status":15,"user_created":48,"date_created":16,"user_updated":48,"date_updated":17,"title":18,"type":19,"body":20,"image":34,"date":21,"topic":70,"slug":24,"activity":71,"nid":28,"topics":72,"activities":73,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":74,"tags":75,"authors":76,"images":77,"translations":78,"content":79},[23],[26,27],[23],[26,27],[],[46,55,56,57,58],[60,61],[],[],[],{"id":81,"name":82},1373,"Corruption prevention",{"id":56,"news_id":84,"tags_id":95},{"id":14,"status":15,"user_created":48,"date_created":16,"user_updated":48,"date_updated":17,"title":18,"type":19,"body":20,"image":34,"date":21,"topic":85,"slug":24,"activity":86,"nid":28,"topics":87,"activities":88,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":89,"tags":90,"authors":91,"images":92,"translations":93,"content":94},[23],[26,27],[23],[26,27],[],[46,55,56,57,58],[60,61],[],[],[],{"id":96,"name":97},1374,"Law enforcement",{"id":57,"news_id":99,"tags_id":110},{"id":14,"status":15,"user_created":48,"date_created":16,"user_updated":48,"date_updated":17,"title":18,"type":19,"body":20,"image":34,"date":21,"topic":100,"slug":24,"activity":101,"nid":28,"topics":102,"activities":103,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":104,"tags":105,"authors":106,"images":107,"translations":108,"content":109},[23],[26,27],[23],[26,27],[],[46,55,56,57,58],[60,61],[],[],[],{"id":4,"name":5},{"id":58,"news_id":112,"tags_id":123},{"id":14,"status":15,"user_created":48,"date_created":16,"user_updated":48,"date_updated":17,"title":18,"type":19,"body":20,"image":34,"date":21,"topic":113,"slug":24,"activity":114,"nid":28,"topics":115,"activities":116,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":117,"tags":118,"authors":119,"images":120,"translations":121,"content":122},[23],[26,27],[23],[26,27],[],[46,55,56,57,58],[60,61],[],[],[],{"id":124,"name":125},804,"Natural resources",[127,142],{"id":60,"news_id":128,"authors_id":139},{"id":14,"status":15,"user_created":48,"date_created":16,"user_updated":48,"date_updated":17,"title":18,"type":19,"body":20,"image":34,"date":21,"topic":129,"slug":24,"activity":130,"nid":28,"topics":131,"activities":132,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":133,"tags":134,"authors":135,"images":136,"translations":137,"content":138},[23],[26,27],[23],[26,27],[],[46,55,56,57,58],[60,61],[],[],[],{"id":140,"name":141,"position":31,"image":31},578,"Dr Sophie Lemaître",{"id":61,"news_id":143,"authors_id":154},{"id":14,"status":15,"user_created":48,"date_created":16,"user_updated":48,"date_updated":17,"title":18,"type":19,"body":20,"image":34,"date":21,"topic":144,"slug":24,"activity":145,"nid":28,"topics":146,"activities":147,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":148,"tags":149,"authors":150,"images":151,"translations":152,"content":153},[23],[26,27],[23],[26,27],[],[46,55,56,57,58],[60,61],[],[],[],{"id":155,"name":156,"position":31,"image":157},561,"Dr Amanda Cabrejo le Roux","46287e4a-0832-48cc-8cc3-02884e72eedf",[],[],[],{"id":162,"status":15,"date_created":163,"date_updated":164,"title":165,"type":19,"body":166,"date":167,"topic":168,"slug":170,"activity":171,"nid":172,"topics":173,"activities":175,"programme":31,"area":31,"websites":31,"language":32,"image":176,"translation_of":31,"countries":181,"tags":182,"authors":215,"images":232,"translations":233,"content":234},10579,"2025-11-11T17:01:39.000Z","2026-05-29T22:22:38.000Z","The FATF’s asset recovery guidance reflects real-world challenges and solutions","The Financial Action Task Force (FATF) has published new [Asset Recovery Guidance and Best Practices](https:\u002F\u002Fwww.fatf-gafi.org\u002Fcontent\u002Ffatf-gafi\u002Fen\u002Fpublications\u002FMethodsandtrends\u002Fasset-recovery-guidance-best-practices-2025.html), offering a comprehensive roadmap to help countries get better at recovering illicit assets.\n\nThrough our International Centre for Asset Recovery (ICAR), the Basel Institute is proud to have contributed to this initiative, which will be instrumental in strengthening asset recovery across jurisdictions globally.\n\nThe Guidance reflects real challenges and operational lessons encountered by jurisdictions worldwide. It incorporates innovative legal tools and best practices that have proven effective in practice, including those supported through our collaborative policy, training and technical assistance work with our partners.\n\n### The Guidance in brief\n\nThe Asset Recovery Guidance aims to help countries implement the 2023 [revisions](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Famendment-FATF-standards-global-asset-recovery.html#:~:text=Paris%2C%2016%20November%202023%20%E2%80%93%20The%20Financial,capture%20criminal%20proceeds%20at%20the%20opportune%20moment.) to the FATF Recommendations, which emphasise the crucial role of asset recovery in combating money laundering and related financial crimes. It provides policymakers and practitioners with clear practical steps for developing for more effective, transparent and victim-centred asset recovery systems.\n\nDrawing on the experience of 38 jurisdictions as well as 22 stakeholder organisations, including the Basel Institute, the Guidance brings together global best practices, operational lessons and legal innovations into a single reference document. Together, these set out how countries can more effectively trace, restrain, confiscate, manage and return criminal assets.\n\nThe Guidance also outlines the growing role of technology in asset recovery, including blockchain analytics and open-source intelligence, which are crucial to keep pace with crime in a digital economy. It highlights new international tools such as [Interpol’s Silver Notice](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Finterpols-silver-notice-paving-way-improved-asset-recovery), which facilitates the tracing of criminal assets across borders.\n\n### Key recommendations\n\nThe Guidance recommends that states and their relevant agencies adopt a number of key policies and practices to improve asset recovery outcomes:\n\n*   Asset recovery as a priority: Adopt clear policies, allocate human and technical resources and provide training for agencies involved in the process. Establish inter-agency coordination and cooperation mechanisms, guidelines for the reuse of recovered funds, monitoring mechanisms and partnerships with the private sector or civil society.\n*   Systematic approach to financial investigations: Initiate asset tracing efforts from the outset of serious crime cases, ensuring inter-agency coordination.\n*   Focus on preventing asset dissipation: Share intelligence and take immediate actions to safeguard assets. This includes the use of temporary suspension or withholding of consent for suspicious transactions by financial intelligence units, as well as rapid freezing or seizing mechanisms by law enforcement agencies.\n*   Beyond criminal confiscation: Introduce [non-conviction based confiscation](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fqg42) and [unexplained wealth measures](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fillicit-enrichment-guide-laws-targeting-unexplained-wealth) to recover illicit proceeds even where prosecution of the perpetrators is not possible.\n*   Cooperation in cross-border cases: Improve and facilitate cooperation, including the use of both [formal and informal cooperation mechanisms](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-9-international-cooperation-asset-recovery), joint investigation teams and networks, such as Asset Recovery Interagency Networks (ARINs) and the Egmont Group of Financial Intelligence Units.\n*   Asset management and allocation of recovered funds: Plan the [management of confiscated assets](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fqg41) to maximise the value of any assets that can be recovered and to ensure benefits for victims and communities.\n*   Fundamental rights: Make sure every step in the asset recovery process is proportional, in line with due process and subject to judicial oversight.\n\n### Role of civil society and the private sector\n\nThe guidance also underscores the vital roles of [civil society](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fguide-role-civil-society-organisations-asset-recovery) and the [private sector](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fqg34) in asset recovery:\n\n*   Civil society actors, including investigative journalists, help uncover illicit activities and drive advocacy for reforms.\n*   The private sector, including financial institutions and so-called designated non-financial service providers (DNFBPs), provide critical financial intelligence as well as support to take immediate action in safeguarding assets.\n\nTogether with authorities, they collaborate to detect, trace and return criminal proceeds. This collective effort enhances recovery outcomes and strengthens public trust through increased transparency and accountability.\n\n### How our work in the field reflects the Guidance\n\nWith our 20+ government partners, our specialist ICAR teams prioritise many of the key areas highlighted in the Guidance.\n\nThrough training and technical assistance, we help authorities strengthen their capacity to investigate, trace and recover illicit assets, with tangible results – from advancing major transnational corruption and money laundering investigations throughout Africa, Europe, South America, and Asia and through assisting in the development of asset recovery legislation such as unexplained wealth and non-conviction based confiscation laws.\n\nWe are also heavily focused on ensuring that recovered criminal assets or [proceeds of corruption](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-15) are either returned to victims or reinvested for good, such as in sustainable development or anti-corruption projects or in criminal justice reforms.\n\n### Why does this matter?\n\nAsset recovery continues to be one of the most challenging elements of the global fight against financial crime, with the effectiveness of recovering criminal proceeds still falling short. The FATF Guidance seeks to address this by raising global standards and ensuring greater consistency in their application.\n\nThe message is clear: recovering criminal assets is crucial to effective criminal justice and transparent financial systems. We support this approach and are committed to advancing it.\n\nAs the Director of ICAR, Iker Lekuona states:\n\n> _“We are encouraged to see many of our policy priorities align with the approach outlined by the Guidance, which will strengthen the support we provide to our partner jurisdictions. ICAR will continue to assist countries through technical assistance, training and policy development, helping turn these priorities into tangible outcomes for communities.”_","2025-11-11",[169],"Asset Recovery","the-fatfs-asset-recovery-guidance-reflects-real-world-challenges-and-solutions-2871",[27],2871,[174],"Asset Recovery and Enforcement",[27],{"id":177,"storage":35,"filename_disk":178,"filename_download":37,"title":165,"type":38,"created_on":163,"modified_on":163,"charset":31,"filesize":179,"width":40,"height":41,"duration":31,"embed":31,"description":31,"location":31,"tags":31,"metadata":180,"focal_point_x":31,"focal_point_y":31,"tus_id":31,"tus_data":31,"uploaded_on":163},"70451caa-5cc2-467a-ad38-cd422606a547","70451caa-5cc2-467a-ad38-cd422606a547.webp",13026,{},[],[183,200],{"id":184,"news_id":185,"tags_id":199},5633,{"id":162,"status":15,"user_created":48,"date_created":163,"user_updated":186,"date_updated":164,"title":165,"type":19,"body":166,"image":177,"date":167,"topic":187,"slug":170,"activity":188,"nid":172,"topics":189,"activities":190,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":191,"tags":192,"authors":194,"images":196,"translations":197,"content":198},"3d9ff205-1640-4f34-b5b6-86977f51bbd6",[169],[27],[174],[27],[],[184,193],5634,[195],1358,[],[],[],{"id":4,"name":5},{"id":193,"news_id":201,"tags_id":212},{"id":162,"status":15,"user_created":48,"date_created":163,"user_updated":186,"date_updated":164,"title":165,"type":19,"body":166,"image":177,"date":167,"topic":202,"slug":170,"activity":203,"nid":172,"topics":204,"activities":205,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":206,"tags":207,"authors":208,"images":209,"translations":210,"content":211},[169],[27],[174],[27],[],[184,193],[195],[],[],[],{"id":213,"name":214},1372,"Training",[216],{"id":195,"news_id":217,"authors_id":228},{"id":162,"status":15,"user_created":48,"date_created":163,"user_updated":186,"date_updated":164,"title":165,"type":19,"body":166,"image":177,"date":167,"topic":218,"slug":170,"activity":219,"nid":172,"topics":220,"activities":221,"programme":31,"area":31,"websites":31,"translation_of":31,"language":32,"countries":222,"tags":223,"authors":224,"images":225,"translations":226,"content":227},[169],[27],[174],[27],[],[184,193],[195],[],[],[],{"id":229,"name":230,"position":31,"image":231},553,"Rita Simões","bd333e72-3950-4c12-b55b-b6bc5cd448c7",[],[],[],{"id":236,"status":15,"date_created":237,"date_updated":238,"title":239,"type":240,"body":241,"date":242,"topic":243,"slug":246,"activity":247,"nid":250,"topics":251,"activities":252,"programme":31,"area":31,"websites":253,"language":31,"image":255,"translation_of":31,"countries":263,"tags":264,"authors":314,"images":315,"translations":316,"content":317},9553,"2022-05-26T22:52:24.000Z","2026-05-29T22:21:42.000Z","Registration open: 5th Global Conference on Criminal Finances and Cryptocurrencies","News","Registration is now open for the [5th Global Conference on Criminal Finances and Cryptocurrencies](https:\u002F\u002Fbaselgovernance.org\u002F5CrC) on 7–8 December 2021. The virtual conference explores trends, strategies and tactics in tackling crimes involving virtual assets.\n\nA joint initiative of the Basel Institute on Governance, INTERPOL and Europol, the annual event now draws hundreds of experts and interested parties from around the world.\n\nThrough presentations, discussions and case studies, the conference participants seek to illuminate how criminals can abuse the virtual asset ecosystem and develop recommendations on what law enforcement, regulators and the private sector can do about it.\n\nAttendance is free but pre-registration is required. Please note that day 2 (8 December) is restricted to law enforcement and related public authorities; attendance is subject to confirmation by the organising committee.\n\n### Agenda and registration\n\n#### 7 December, 12:00–15:30 GMT\n\nOpen to all, this day is dedicated to contrasting perspectives on virtual assets, regulation and compliance from the public and private sectors, media and regulatory bodies. Topics include:\n\n*   the challenges posed by decentralised finance for identifying and tracing suspicious cryptocurrency transactions;\n*   what media investigations reveal about how criminals launder the proceeds of crime using cryptocurrencies;\n*   changing scenarios of compliance with AML regulations relating to VASPs.\n\nThe agenda and speaker names will be published in November.\n\n[Register for day 1](https:\u002F\u002Fbaselgovernance.zoom.us\u002Fwebinar\u002Fregister\u002FWN_JtKkk8atRy-cRrTlduZLaQ)\n\n#### 8 December, 12:00–15:30 GMT\n\nLimited to law enforcement and related public authorities (judicial authorities, Financial Intelligence Units, anti-money laundering supervisors, etc.) the second day is an opportunity to explore the changing modi operandi of criminals abusing the cryptocurrency ecosystem to hide and launder money, and how law enforcement can fight back.\n\nThe agenda will be released to participants shortly before the conference.\n\n[Apply to attend day 2](https:\u002F\u002Fbaselgovernance.zoom.us\u002Fwebinar\u002Fregister\u002FWN_xBQ3LmOgRI-PeUUqdDrGuw)\n\n### More\n\n[Download the conference poster](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2021-10\u002FCryptocurrency_conference_A4%20poster.jpg).\n\nView the latest updates and more information about this and previous events, and browse related resources on cryptocurrencies and financial crime, at: [baselgovernance.org\u002F5CrC](https:\u002F\u002Fbaselgovernance.org\u002F5CrC)","2021-10-11",[244,169,245],"Anti-Money Laundering","Private Sector","registration-open-5th-global-conference-on-criminal-finances-and-cryptocurrencies-2114",[248,249],"Events","Partnerships",2114,[244,174,245],[248,249],[254],"Main page",{"id":256,"storage":35,"filename_disk":257,"filename_download":37,"title":239,"type":38,"created_on":258,"modified_on":258,"charset":31,"filesize":259,"width":260,"height":261,"duration":31,"embed":31,"description":31,"location":31,"tags":31,"metadata":262,"focal_point_x":31,"focal_point_y":31,"tus_id":31,"tus_data":31,"uploaded_on":258},"be50082b-8c5e-422a-88a8-52df846390d3","be50082b-8c5e-422a-88a8-52df846390d3.webp","2025-05-12T21:17:30.000Z",59086,1400,933,{},[],[265,284,300],{"id":266,"news_id":267,"tags_id":281},5081,{"id":236,"status":15,"user_created":48,"date_created":237,"user_updated":186,"date_updated":238,"title":239,"type":240,"body":241,"image":256,"date":242,"topic":268,"slug":246,"activity":269,"nid":250,"topics":270,"activities":271,"programme":31,"area":31,"websites":272,"translation_of":31,"language":31,"countries":273,"tags":274,"authors":277,"images":278,"translations":279,"content":280},[244,169,245],[248,249],[244,174,245],[248,249],[254],[],[266,275,276],5783,5784,[],[],[],[],{"id":282,"name":283},854,"Virtual assets",{"id":275,"news_id":285,"tags_id":297},{"id":236,"status":15,"user_created":48,"date_created":237,"user_updated":186,"date_updated":238,"title":239,"type":240,"body":241,"image":256,"date":242,"topic":286,"slug":246,"activity":287,"nid":250,"topics":288,"activities":289,"programme":31,"area":31,"websites":290,"translation_of":31,"language":31,"countries":291,"tags":292,"authors":293,"images":294,"translations":295,"content":296},[244,169,245],[248,249],[244,174,245],[248,249],[254],[],[266,275,276],[],[],[],[],{"id":298,"name":299},1193,"Financial investigations",{"id":276,"news_id":301,"tags_id":313},{"id":236,"status":15,"user_created":48,"date_created":237,"user_updated":186,"date_updated":238,"title":239,"type":240,"body":241,"image":256,"date":242,"topic":302,"slug":246,"activity":303,"nid":250,"topics":304,"activities":305,"programme":31,"area":31,"websites":306,"translation_of":31,"language":31,"countries":307,"tags":308,"authors":309,"images":310,"translations":311,"content":312},[244,169,245],[248,249],[244,174,245],[248,249],[254],[],[266,275,276],[],[],[],[],{"id":4,"name":5},[],[],[],[],{"id":319,"status":15,"date_created":320,"date_updated":321,"title":322,"type":240,"body":323,"date":324,"topic":325,"slug":326,"activity":327,"nid":329,"topics":330,"activities":331,"programme":31,"area":31,"websites":332,"language":31,"image":333,"translation_of":31,"countries":339,"tags":340,"authors":390,"images":391,"translations":392,"content":393},9693,"2022-05-26T22:54:23.000Z","2026-05-29T22:21:50.000Z","Now on LEARN: Guide to the role of civil society organisations in asset recovery","How can civil society organisations (CSOs) support efforts to recover stolen assets for their country? What are the different stages of the asset recovery process and what are potential actions in each one? What is the legal basis for the involvement of civil society in asset recovery? Where are the main risks and challenges, and how can CSOs overcome these?\n\nOur International Centre for Asset Recovery originally developed a guide to the role of CSOs in asset recovery in 2014, together with partners in the context of the Arab Forum on Asset Recovery (AFAR). \n\nFreshly updated, this guide is now available on the Basel Institute’s [LEARN platform.](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=14) \n\n[LEARN](https:\u002F\u002Flearn.baselgovernance.org) offers a suite of self-paced eLearning courses and other practical guidelines on asset tracing, intelligence gathering and financial analysis. The platform is also used for online delivery of some our instructor-led training programmes, including those offered by our ICAR training team.\n\nAll of our self-paced courses and guidelines are freely accessible and many are available in multiple languages. More are being added over the next weeks and months, so do check back regularly.\n\n### About the Guide\n\nThis easy-to-read _Guide to the role of CSOs in asset recovery_ covers:\n\n*   The fundamentals of asset recovery – what asset recovery is, the four key phases and relevant aspects of international law.\n*   An introduction to the role of civil society in anti-corruption and asset recovery.\n*   Four major areas in which CSOs can have an impact on asset recovery success:\n    *   Awareness raising and research\n    *   Advocacy\n    *   Casework and legal analysis\n    *   Return of confiscated assets\n*   Examples of CSOs actively involved in supporting asset recovery now or in the past.\n\nThe guidance is applicable globally to all types of CSOs. Arabic and Ukrainian versions are available as PDF downloads.\n\n### About the role of CSOs in asset recovery\n\nAsset recovery refers to the process by which the proceeds of crime are identified, traced, seized, confiscated and returned to their rightful owners. Generally speaking, States need to lead the process of recovering stolen assets. However, CSOs can also play an important role in the different stages of the asset recovery process. \n\nCSOs have traditionally engaged in the asset recovery process through awareness raising, research and advocacy.\n\nOver time, they have also increasingly assisted states in managing frozen assets or helped with considerations related to the end use of returned assets. CSOs have also sometimes been the recipients of returned assets.\n\nMore recently, CSOs have also assisted states in their enforcement efforts. This includes helping identify and investigate corruption-related offences, engaging with whistle-blowers or even initiating legal action.\n\nTo learn more, [click through to the guide](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=14) or [download the PDF](https:\u002F\u002Fwww.baselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2020-08\u002FCSOs_Asset_Recovery.pdf).\n\n### Acknowledgements\n\nIn developing the original guide in the context of the Arab Forum on Asset Recovery (AFAR), ICAR expresses its appreciation to the United Kingdom G8 Presidency, the World Bank\u002FUNODC [Stolen Asset Recovery Initiative (StAR)](http:\u002F\u002Fstar.worldbank.org\u002F) and Ambassador Muhyieddeen Touq of Jordan for their advice and support, and the following CSOs for their valuable contributions:\n\n*   Association Tunisienne pour la Transparence Financière (ATTF)\n*   Yemeni National Authority for Recovering Stolen Assets (AWAM)\n*   [Egyptian Initiative for Personal Rights (EIPR)](https:\u002F\u002Feipr.org\u002Fen)\n*   [Global Witness](https:\u002F\u002Fwww.globalwitness.org\u002F)\n*   [Open Society Justice Initiative](https:\u002F\u002Fwww.opensocietyfoundations.org\u002Fwho-we-are\u002Fprograms\u002Fopen-society-justice-initiative)\n*   [Sherpa](https:\u002F\u002Fwww.asso-sherpa.org\u002F)","2020-08-17",[169],"now-on-learn-guide-to-the-role-of-civil-society-organisations-in-asset-recovery-1836",[328],"eLearning",1836,[174],[328],[254],{"id":334,"storage":35,"filename_disk":335,"filename_download":37,"title":322,"type":38,"created_on":336,"modified_on":336,"charset":31,"filesize":337,"width":260,"height":261,"duration":31,"embed":31,"description":31,"location":31,"tags":31,"metadata":338,"focal_point_x":31,"focal_point_y":31,"tus_id":31,"tus_data":31,"uploaded_on":336},"07c2b9b2-dc40-4213-8b0d-c15cb0abc972","07c2b9b2-dc40-4213-8b0d-c15cb0abc972.webp","2025-05-12T21:19:52.000Z",53988,{},[],[341,360,376],{"id":342,"news_id":343,"tags_id":357},5324,{"id":319,"status":15,"user_created":48,"date_created":320,"user_updated":186,"date_updated":321,"title":322,"type":240,"body":323,"image":334,"date":324,"topic":344,"slug":326,"activity":345,"nid":329,"topics":346,"activities":347,"programme":31,"area":31,"websites":348,"translation_of":31,"language":31,"countries":349,"tags":350,"authors":353,"images":354,"translations":355,"content":356},[169],[328],[174],[328],[254],[],[342,351,352],5892,5893,[],[],[],[],{"id":358,"name":359},843,"Asset recovery",{"id":351,"news_id":361,"tags_id":373},{"id":319,"status":15,"user_created":48,"date_created":320,"user_updated":186,"date_updated":321,"title":322,"type":240,"body":323,"image":334,"date":324,"topic":362,"slug":326,"activity":363,"nid":329,"topics":364,"activities":365,"programme":31,"area":31,"websites":366,"translation_of":31,"language":31,"countries":367,"tags":368,"authors":369,"images":370,"translations":371,"content":372},[169],[328],[174],[328],[254],[],[342,351,352],[],[],[],[],{"id":374,"name":375},1300,"Education",{"id":352,"news_id":377,"tags_id":389},{"id":319,"status":15,"user_created":48,"date_created":320,"user_updated":186,"date_updated":321,"title":322,"type":240,"body":323,"image":334,"date":324,"topic":378,"slug":326,"activity":379,"nid":329,"topics":380,"activities":381,"programme":31,"area":31,"websites":382,"translation_of":31,"language":31,"countries":383,"tags":384,"authors":385,"images":386,"translations":387,"content":388},[169],[328],[174],[328],[254],[],[342,351,352],[],[],[],[],{"id":4,"name":5},[],[],[],[],{"id":395,"status":15,"date_created":396,"date_updated":397,"title":398,"type":240,"body":399,"date":400,"topic":401,"slug":402,"activity":403,"nid":404,"topics":405,"activities":406,"programme":31,"area":31,"websites":407,"language":31,"image":408,"translation_of":31,"countries":418,"tags":440,"authors":455,"images":456,"translations":457,"content":458},10467,"2024-08-13T22:01:58.000Z","2026-05-29T22:22:31.000Z","Equipping Malawi’s investigative journalists to report on corruption and anti-corruption efforts","Journalist Bertram Hill of the BBC Africa Eye Investigative Team joined media consultant Ladan Cher in March 2020 to lead an intensive open-source intelligence workshop for 13 of Malawi’s leading investigative journalists.\n\nDuring the four-day workshop, the participants explored the many possibilities of open-source intelligence gathering, including:\n\n*   Archiving and advanced search techniques\n*   Online monitoring\n*   Digital security\n*   Geolocation and mapping resources\n*   Advanced people search\n\nThe workshop was part of the Basel Institute’s Continuing Journalism Education (CJE) initiative in Malawi. Supported by the Tackling Serious and Organised Corruption programme of the UK’s Department for International Development (DFID), the CJE aims to help Malawi’s media practitioners develop and publish stories on corruption and anti-corruption activities.\n\nThe goals: to amplify public messages on corruption, help the media to present a clear and candid account of corrupt activities, and drive positive change.\n\nThe initiative, led by two journalist mentors, targets a small cadre of experienced investigative journalists in Malawi, as well as media houses and journalist support organisations.\n\nHighlights in the past year include conducting 10 story labs in Lilongwe and Blantyre, where the cohort of journalists pitch and develop their stories; and three topical workshops including the above BBC-led workshop, a Fact-Checking Workshop led by Africa Check and a Story Pitch and Build Workshop led by the J-School at Wits University in Johannesburg.\n\nA journalist was set to undertake a three-month fellowship with the _Mail and Guardian_ in South Africa, although this has been postponed due to the coronavirus pandemic.\n\nForty stories have been published by CJE journalists over the past year, including the stories that broke the judicial bribery scandal, on a ministry involved in a land-swap scandal, and the story of police uniforms and boots being sold on the open market.\n\nThe CJE programme has seen interest and support from media houses, newsrooms and journalist support organisations all over the world, including the [Media Institute of Southern Africa](https:\u002F\u002Fmisa.org\u002F) in Lilongwe, the Raphael Tenthani Centre for Media Excellence at the [Polytechnic College of the University of Malawi](http:\u002F\u002Fwww.poly.ac.mw\u002F) in Blantyre, the [AmaBhungane](https:\u002F\u002Famabhungane.org\u002F) Centre for Investigative Journalism, the _Mail & Guardian_ of South Africa, [Wits Journalism](http:\u002F\u002Fwits.journalism.co.za\u002F) of Witwatersrand University, The _Telegraph_ in the UK, the _Washington Post_, and Malawian newspapers The _Times, Nyasa Times_ and The _Nation_.","2020-04-08",[169],"equipping-malawis-investigative-journalists-to-report-on-corruption-and-anti-corruption-efforts-1558",[214],1558,[174],[214],[254],{"id":409,"storage":35,"filename_disk":410,"filename_download":411,"title":398,"type":38,"created_on":412,"modified_on":413,"charset":31,"filesize":414,"width":415,"height":416,"duration":31,"embed":31,"description":31,"location":31,"tags":31,"metadata":417,"focal_point_x":31,"focal_point_y":31,"tus_id":31,"tus_data":31,"uploaded_on":413},"5ee0a5d0-c0e7-4b89-90a4-3f28eaca41b1","5ee0a5d0-c0e7-4b89-90a4-3f28eaca41b1.webp","MalawiCJE2.webp","2025-05-12T21:20:47.000Z","2026-05-06T07:35:24.000Z",218226,1600,1200,{},[419],{"id":420,"news_id":421,"countries_id":434},7422,{"id":395,"status":15,"user_created":48,"date_created":396,"user_updated":186,"date_updated":397,"title":398,"type":240,"body":399,"image":409,"date":400,"topic":422,"slug":402,"activity":423,"nid":404,"topics":424,"activities":425,"programme":31,"area":31,"websites":426,"translation_of":31,"language":31,"countries":427,"tags":428,"authors":430,"images":431,"translations":432,"content":433},[169],[214],[174],[214],[254],[420],[429],5906,[],[],[],[],{"id":435,"name":436,"code":437,"latitude":438,"longitude":439},153,"Malawi","MW",-13.25431,34.30152,[441],{"id":429,"news_id":442,"tags_id":454},{"id":395,"status":15,"user_created":48,"date_created":396,"user_updated":186,"date_updated":397,"title":398,"type":240,"body":399,"image":409,"date":400,"topic":443,"slug":402,"activity":444,"nid":404,"topics":445,"activities":446,"programme":31,"area":31,"websites":447,"translation_of":31,"language":31,"countries":448,"tags":449,"authors":450,"images":451,"translations":452,"content":453},[169],[214],[174],[214],[254],[420],[429],[],[],[],[],{"id":4,"name":5},[],[],[],[],6,{"items":461,"total":1310},[462,632,823,1019,1154],{"id":463,"status":15,"sort":31,"date_created":464,"date_updated":465,"nid":466,"slug":467,"title":468,"body":469,"citation":470,"language":32,"year":471,"publisher":472,"date_published":473,"external":474,"topic":475,"link_internal":478,"link_external":479,"featured":474,"topics":483,"languages":31,"type":485,"area":31,"programme":31,"websites":31,"summary":31,"pdf_text":487,"main_points":488,"short_version":31,"subtitle":31,"image":489,"countries":499,"tags":522,"pdf":579,"authors":601},2432,"2026-01-28T17:05:36.000Z","2026-06-02T21:22:46.000Z",2910,"political-economy-weeds-embracing-complexity-anti-corruption-work-lessons-learned-anti","Political economy in the weeds: Embracing complexity in anti-corruption work – lessons learned from anti-corruption programme in Malawi","In this joint paper with Adam Smith International, authors Claudia Baez Camargo and Renee Kantelberg show how anti-corruption efforts require more than mere technical fixes, such as capacity building for civil society alone, to drive lasting change.\n\nAnti-corruption work is often embedded in complex, politically charged environments. This requires thinking and working politically. Engaging with complex social and economic systems also means recognising that change is not linear or even predictable. What to do then?\n\nOur years of anti-corruption research have demonstrated the centrality of having local stakeholders be in the driver’s seat for identifying priorities and finding solutions. This is how we have worked in Malawi in the Malawi Anti-Corruption Civil Society Support (MACCSS) project, funded by the UK Foreign, Commonwealth and Development Office and implemented with Adam Smith International.\n\nThis publication shares practical lessons and successes in applying this approach in the MACCSS project. It illustrates our joint efforts to navigate uncertainty and ground anti-corruption efforts in trust, resilience and local leadership. The key takeaways for practitioners who design or implement anti-corruption programmes (paraphrased) are:\n\n\n- **Embrace complexity.** Change is adaption and pivoting to reality, which is not linear. In governance programmes, unexpected developments and temporary reversals are signs that systems are shifting.\n- **Local ownership matters.** When partners are in the driver’s seat, impact and sustainability improve. This is true even if the route diverges from initial plans.\n- **Facilitation over funding.** Hands-on mentoring and relationship brokering build deeper capabilities than unidirectional training, grants and results frameworks.\n- **Learning by doing.** Regular reflection converts experience into strategy; failures become data for adaptation.\n- **Build trust and coalitions.** Reform depends on a collective effort with credible institutions and sister anti-corruption programmes. It also requires nurturing emergent anti-corruption networks, rather than merely building the capacity of individual actors.\n- **Resilience grows from below.** Sustainable accountability takes root when communities see anti-corruption as linked to livelihoods and services, not as an abstract governance agenda.\n- **Gender and inclusion strengthen legitimacy.** Integrating gender and social inclusion (GESI) principles by addressing corruption in mining, infrastructure and agriculture – sectors critical for women and marginalised groups – broadens both the reach and credibility of anti-corruption efforts.\n\n\nUltimately, the MACCSS experience reinforces a simple but profound insight: **anti-corruption work is not about perfect plans but about adaptive partnerships.** Change happens through relationships, experimentation and persistence. The task is not to eliminate uncertainty, but to navigate it with integrity and learning at the core. ","",2026,"Adam Smith International","2026-01-28",false,[476,477],"Prevention","Research and Innovation",[],[480],{"url":481,"caption":482},"https:\u002F\u002Fadamsmithinternational.com\u002Farticles\u002Fpolitical-economy-in-the-weeds-embracing-complexity-in-anti-corruption-work\u002F#resource:all"," View on Adam Smith International website",[484],"Prevention Research and Innovation",[486],"Report","\u003C!-- image -->\n\n## POLITICAL ECONOMY IN THE WEEDS\n\n## EMBRACING COMPLEXITY IN ANTI-CORRUPTION WORK\n\nBy Renee Kantelberg and Claudia Baez-Camargo\n\n## Introduction\n\nThe Malawi Anti-Corruption Civil Society Support (MACCSS) programme provides a powerful case for understanding how anti-corruption  (AC)  efforts  unfold  in  complex,  politically  charged  environments.  Jointly  funded  by  the  UK  Foreign, Commonwealth  and  Development  Office  (FCDO)  and  USAID,  MACCSS  (2024-2026)  combines  grants  and  technical assistance worth £1.75 million to strengthen civil society's role in promoting accountability. The initiative works through a  portfolio  of  civil  society  issue-focused  interventions  with  national  and  district  partners  across  sectors  such  as agriculture, mining, constituency development funds, justice and infrastructure.\n\nMalawi serves as both an opportunity-rich testing ground for systems-change initiatives and a cautionary case illustrating the constraints and pressure points such reforms face. This blend of promise and challenge renders Malawi pivotal for understanding governance transformations in comparable contexts. It is one of the poorest countries in the world, with corruption deeply embedded in its political and bureaucratic systems. Decades of clientelist politics, weak enforcement institutions  and  low  public-sector  pay  have  entrenched  behaviours  where  access  to  state  resources  is  viewed  as  an entitlement to extract rents for their own benefit and that of particular interests. In the wake of the September 2025 elections, these longstanding dynamics continue to shape the operating environment. Consequently, MACCSS's mandate remains unchanged: to equip committed civil-society organisations from national bodies to rural district groups with the knowledge, networks, and confidence to serve as policy-reform champions, watchdogs, and mobilisers of citizen voice and national advocacy priorities.\n\nAt first glance, the logic of working with civil society in contexts where state capacities are weak is straightforward: if CSOs are  trained  in  strategic  advocacy,  intervention  design,  operational  planning  and  media  engagement,  they  will become  effective  in  exposing  and  preventing  corruption,  thus  fulfilling  their  assumed  watchdog  function.  Yet  the experience of implementation shows that capacity alone does not guarantee influence and that change is difficult and non-linear. The real story of MACCSS lies in how its partners are learning to 'work in the weeds' - embracing uncertainty, adapting to shifting power dynamics, and building alliances that make accountability and anti-corruption transformation possible.\n\n## The Strategy: Ambition and Assumptions\n\nMACCSS's design draws from the classic anti-corruption playbook, which is reflected in the programme's strategy (Theory of  Change),  which  suggests  that  enhancing  CSO  technical  and  organisational  capacity  results  in  greater  citizen engagement and oversight and, ultimately, in reduced opportunities and incentives for corruption.\n\nConsequently, capacity building is pursued through three interdependent strands:\n\n- ∞ Financial resources - seed funding \u002F grants £10,000 - £50,000 to locally designed interventions.\n- ∞ Technical support -  training and mentoring in advocacy, media work, Political Economy Analysis, Gender and Social Inclusion (GESI), and thematic areas such as mining or procurement.\n- ∞ Organisational strengthening -  support  for  financial  management,  grant  compliance,  safeguarding,  MEL,  and other core systems essential for sustainable CSO operations.\n- ∞ Learning - facilitation and convening of peer exchanges where national and district level partners jointly reflect, share evidence and refine strategies.\n\nJust observing the above, it would be tempting to assume that technical support and trainings are enough to build stronger organisations and that the recipients of the support will automatically be able to translate skills into action and\n\n\u003C!-- image -->\n\n## ASI\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nresults.  Experience,  however,  shows  that  this  logic  fails  to  grasp  the  incremental  and  iterative  nature  of  building competencies, while also underestimating the political nature of corruption and the depth of systemic inertia. What MACCSS is revealing is that effectiveness depends less on training or resources than on learning by doing, building relationships, moving with opportunities and the capacity to adapt.\n\n## Working in the Weeds: Navigating Complexity and Adapting Practice\n\nAn overarching lesson from the MACCSS programme is that in practice, progress is messy and contested, which should not be surprising. As in many other countries, power in Malawi is acquired, shared and maintained through networks of patronage,  built  and  cemented  on  non-transparent  deals  that  cut  across  the  state,  business  and  political  parties. Corruption  trickles  down  to  the  grassroots,  where  public  service  providers  and  street  level  bureaucrats  routinely manoeuvre the prerogatives stemming from their official mandates to extract benefits and resources for themselves and their social networks.  Therefore, corruption in Malawi is woven into the political settlement itself and embedded in social norms that normalise and lend acceptability to corruption. As a result, when anti-corruption efforts begin to bite, they often provoke pushback: investigations stall, whistle-blowers face intimidation, and reform champions are side-lined or even threatened. The experience of the Zuneth Sattar case, in which high-level prosecutions led to institutional backlash, illustrates how success can generate its own resistance.\n\nCivil society faces additional constraints. Many organisations operate on shoestring budgets and remain dependent on donor funding, which is often project-based and problematises the continuity of their endeavours. Corruption fatigue also reflects public scepticism among intended beneficiaries that activism will not change anything. Legal restrictions on public-interest litigation, slow access to information, and the risk of regulatory reprisals further limit civic space. At district level, organisational inertia is strong: as one partner admitted, 'this is how we have always done things.'\n\n## From capacity building to facilitated partnership\n\nHere the lessons of MACCSS validate those of many other FCDO governance programmes in that conventional grant making  and  capacity  building  too  often  produces  donor-compliant  but  citizen-disconnected  CSOs.  Grants  managed without attention to the contextual conditions and needs can constrain flexibility, distort incentives, and monetise the engagement. MACCSS learned from this and adopted a facilitated partnership approach , deploying mixed local teams to broker relationships among civil society, media and AC institutions, and FCDO sister programmes while encouraging CSO implementing partners to be in the driver's seat in deciding priorities, providing them a safe space to innovate and to build their capacities through learning by doing. The focus shifted from funding activities to nurturing trust, reflection and adaptive learning within a cohort of champions.\n\nERROR! NO The Accountability Working Group (AWG) - made up of our core partner organisations, together with regular learning exchanges, sits at the centre of our work. MACCSS understands its role as a facilitation hub; encouraging trust building, peer exchanges and the emergence of coordinated action, decidedly moving away from focusing and insisting on preestablished  good  governance  practices  and  an  emphasis  on  procedures  and  delivery  mechanisms.  MACCSS-hosted convenings bring together partner CSOs, journalists \u002F media, communities and duty bearers to co-create interventions, share evidence and reflect on progress along with challenges. The emphasis is on brokering relationships and supporting iterative experimentation, not on enforcing rigid workplans. Mentoring and technical accompaniment are complemented by targeted and demand-led training, and small, flexible funding support is provided to pilot critical ideas whose design evolves as lessons and proof of concept emerge. Learning by doing and reflection\n\nFor MACCSS and its partners real capacity is being built iteratively, through cycles of action and reflection. The MACCSS Monitoring, Reporting, Evaluation and Learning (MREL) system promotes 'utilisation-focused' learning loops following the self-reinforcing logic of implementation, analysis, discussions and, adaptation. Quarterly Pause and Reflect meetings with the AWG provide a collective space to share not only achievements but also setbacks, echoing MACCSS core principle that mistakes are data and information that tell us something to consider . These reflection processes strengthen partners' confidence  and  sense  of  agency.    Gradually,  shifts  are  becoming  visible:  district  networks  collaborating  instead  of competing;  local  journalists  and  activists  pooling  evidence  from  civil  society  work;  civil  servants  recognising  that transparency can strengthen, not threaten, their legitimacy. These may seem like small wins, yet they build the bottomup resilience that sustains reform beyond donor and MACCSS project cycles.\n\nEmbracing uncertainty\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n## ASI\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nWorking this way demands tolerance for ambiguity and deviation from plans. Anti-corruption work that matters will always provoke contestation. MACCSS is still unfolding, but it demonstrates that technically skilled support and facilitation, pace that  is  set  by  the  stakeholders  themselves,  moving  on  needs  and  emerging  gaps  as  well  as  patience  and  political awareness are all more effective than rigid top-down management. Progress depends less on control than on cultivating curiosity and responsiveness with a relational approach that puts partners always in the driving seat. MACCSS recognises that grants alone can distort incentives encouraging compliance rather than collaboration.\n\nBy combining seed funding with tailored technical mentoring and facilitation, partners gain the freedom to adapt their strategies as contexts shift, as was experienced during the September 2025 election period when political will and action waned. Yet,  partners  acted  strategically  during  that  election  period  to  influence  the  Anti-Corruption  agenda  through political manifestos, providing evidence where doors opened by politicians. An indicative example of the success achieved through these means was the fact that the AWG was able to get several key questions into the 2025 Presidential Debate that reflected on issues related to corruption in specific sectors.\n\nSetbacks and detours are expected in the process, just as opportunities are; embracing the political landscape mix (and pivoting) is what partners know and do so well.\n\n## Key Lessons Learned\n\n- 1. Embrace complexity. Change is adaption and pivoting to reality, which is not linear. In governance programmes, unexpected developments and temporary reversals are signs that systems are shifting.\n- 2. Local ownership matters. When partners are in the driver's seat, as in MACCSS's co-creation of interventions, impact and sustainability improve, even if the route diverges from initial plans.\n- 3. Facilitation over funding. Hands-on mentoring and relationship-brokering build deeper capabilities than unidirectional training, grants and results frameworks.\n- 4. Learning by doing. Regular reflection converts experience into strategy; failures become data for adaptation.\n- 5. Build trust and coalitions. Engagement with credible institutions such as the Ombudsman, with champions in the state and in FCDO sister programmes, and leaning on the collective experience of the AWG, altogether shows that reform depends on collective effort, on nurturing emergent anti-corruption networks, rather than on building the capacity of individual actors.\n- 6. Resilience  grows  from  below. District  alliances  illustrate  that  sustainable  accountability  takes  root  when communities see anti-corruption as linked to livelihoods and services, not as an abstract governance agenda.\n- 7. Gender and inclusion strengthen legitimacy. Integrating GESI principles by addressing corruption in mining, infrastructure,  agriculture,  sectors  critical  for  women  and  marginalised  groups  broadens  both  the  reach  and credibility of anti-corruption efforts.\n\nERROR! NO Implications for Malawi and Beyond MACCSS demonstrates the  value  of working  politically  and  adaptively in  anti-corruption  programming  with  local stakeholders driving the agenda and the development of local approaches that work in Malawi for and by Malawians. Technical solutions and training alone cannot overcome entrenched incentives; transformation emerges from iterative learning, trust-building, and responsiveness to context. For donors, this means funding models that prioritise flexibility, process,  reflection  and  a  willingness  to  be  surprised  by  unexpected  gains  as  much  as  outputs  and  indicators.  For practitioners, it means patience, humility and a willingness to depart from the usual approaches and find out how to 'work with the grain' of local systems rather than against them.\n\nAs Malawi moves ahead of the 2025 elections result, the programme continues to focus on citizen energy with CSOs and media bringing collectively concrete accountability demands. The long-term vision is a network of capable, connected CSOs and local champions who can sustain anti-corruption momentum with decreasing external support.\n\nUltimately, the MACCSS experience reinforces a simple but profound insight: anti-corruption work is not about perfect plans but about adaptive partnerships. Change happens through relationships, experimentation and persistence. The task is not to eliminate uncertainty, but to navigate it with integrity and learning at the core.\n\n\u003C!-- image -->","- **Embrace complexity.** Change is adaption and pivoting to reality, which is not linear. In governance programmes, unexpected developments and temporary reversals are signs that systems are shifting.\n- **Local ownership matters.** When partners are in the driver’s seat, impact and sustainability improve. This is true even if the route diverges from initial plans.\n- **Facilitation over funding.** Hands-on mentoring and relationship brokering build deeper capabilities than unidirectional training, grants and results frameworks.\n- **Learning by doing.** Regular reflection converts experience into strategy; failures become data for adaptation.\n- **Build trust and coalitions.** Reform depends on a collective effort with credible institutions and sister anti-corruption programmes. It also requires nurturing emergent anti-corruption networks, rather than merely building the capacity of individual actors.\n- **Resilience grows from below.** Sustainable accountability takes root when communities see anti-corruption as linked to livelihoods and services, not as an abstract governance agenda.\n- **Gender and inclusion strengthen legitimacy.** Integrating gender and social inclusion (GESI) principles by addressing corruption in mining, infrastructure and agriculture – sectors critical for women and marginalised groups – broadens both the reach and credibility of anti-corruption 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Kantelberg",{"id":633,"status":15,"sort":31,"date_created":634,"date_updated":635,"nid":636,"slug":637,"title":638,"body":639,"citation":640,"language":32,"year":641,"publisher":642,"date_published":21,"external":474,"topic":643,"link_internal":644,"link_external":648,"featured":474,"topics":649,"languages":31,"type":650,"area":31,"programme":31,"websites":31,"summary":31,"pdf_text":652,"main_points":31,"short_version":653,"subtitle":31,"image":654,"countries":662,"tags":663,"pdf":739,"authors":795},2431,"2025-12-11T17:05:46.000Z","2026-06-02T14:08:56.000Z",2881,"wp-61","Working Paper 61: Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond","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.\n\nResolution 8\u002F12 – *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.\n\n*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.\n\nThe Working Paper also underscores the valuable contributions made by non-state actors, in particular civil society, academia and the media, in this collective endeavour.\n\nFinally, 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.\n\n### About this Working Paper\n\nThis 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.\n\nIt 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\u002F12’, which was prepared in the context of CoSP10 in Atlanta, Georgia, US in 2023.\n\nThe 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 \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">CC BY-NC-ND 4.0\u003C\u002Fa> licence.\n\nIt was made possible by the generous support of the Principality of Liechtenstein.\n\nThe 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.\n\n","Lemaître, Sophie. 2025. ‘Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond.’ Working Paper 61, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-61.",2025,"Basel Institute on Governance",[23],[645],{"url":646,"caption":647},"\u002Fresources\u002Fpublications\u002Fwp-50"," View related Working Paper 50",[],[23],[651],"Working Paper","\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n## Saplings of hope\n\n## Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond\n\nSophie Lemaître and Amanda Cabrejo le Roux | December 2025\n\n\u003C!-- image -->\n\n## About this report\n\nAdopted in 2019, UNCAC Resolution 8\u002F12 Preventing and combating corruption as it relates to crimes that have an impact on the environment - urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.\n\nSaplings of hope provides an updated overview of emerging and promising initiatives across the world since the adoption of Resolution 8\u002F12, focusing on progress in 2024 and 2025.\n\nThis report is part of the Green Corruption programme at the Basel Institute on Governance. It 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.\n\nIt 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\u002F12' , which was prepared in the context of CoSP10 in Atlanta, Georgia, US in 2023.\n\nThe report 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 (CC BY-NC-ND 4.0).\n\nIt was made possible by the generous support of the Principality of Liechtenstein.\n\nThe 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.\n\nSuggested citation: Lemaître, Sophie, and Amanda Cabrejo le Roux. 2025. 'Saplings of hope: Addressing corruption that has an impact on the environment in line with UNCAC Resolution 8\u002F12 and beyond.' Working Paper 61, Basel Institute on Governance. Available at: baselgovernance.org\u002Fpublications\u002Fwp-61.\n\n## About the authors\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n## Dr Sophie Lemaître, main author\n\nAnti-corruption and natural resources expert\n\nDr Sophie Lemaître is a lawyer by training with experience in anti-corruption issues, natural resources sector, and lawfare. She worked for various organisations and NGOs at the national and international level, including CIRAD, the Food and Agriculture Organisation of the United Nations, Sherpa and U4 Anti-Corruption Resource Centre.\n\nSophie holds a PhD degree in Law from the University of Rennes 1 (France) on illicit financial flows within the extractive industries. She also holds a Master's degree in International Business Law from the University of Toulouse (France) as well as an LL.M. in International and European Environmental Law and Policy from University College London (United Kingdom).\n\nEmail: sophie.lemaitre34@gmail.com\n\n## Dr Amanda Cabrejo le Roux\n\nSenior Specialist and Deputy Director of the Green Corruption programme, Basel Institute on Governance\n\nDr Amanda Cabrejo le Roux leads the implementation of the Basel Institute's Green Corruption activities in Africa, Asia and South America. She also leads research efforts and the involvement of the Green Corruption programme in the Countering Environmental Corruption Practitioners Forum.\n\nAmanda holds a PhD in International and Comparative Criminal Law from the Sorbonne Law School (University Paris I PantheonSorbonne). She also holds an LL.M. in International Criminal Law (University of Amsterdam\u002FColumbia Law School), Master's degrees in French Law and Comparative Criminal Law (Sorbonne Law School) and Spanish Law (Universidad Complutense), and Bachelor's degrees in History (University Paris 1) and Anthropology (University Paris 8).\n\nEmail: amanda.cabrejo@baselgovernance.org\n\n## Acknowledgements\n\nThis report benefited from contributions of numerous individuals who shared their expertise, insights and views during interviews and made themselves promptly available.\n\nThe authors would like to express their gratitude to: Paulus K. Noa from the AntiCorruption Commission Namibia; Jacob Phelps from Conservation-Litigation.org; Lisa Hartevelt from Wildlife Justice Commission; Laurent Szymkowiak from the World Customs Organization; Maria Adomeit, Daniela Sota Valdivia and Beatrice Fantacci from the United Nations Office on Drugs and Crimes; Liisa Kytola from the Thomson Reuters Foundation; Nicole Byrd and Andrea Crosta from Earth League International; John Mugendi from Kenya Wildlife Service; Alina Blaga-Smith from WWF and Jim Mtafya from the Malawi Anti-Corruption Bureau. Without their inputs, the report would not have been possible.\n\nThe authors are also grateful for the colleagues of the Green Corruption programme of the Basel Institute on Governance for their support, insights and first-hand experience in implementing corruption prevention and enforcement interventions with our government partners: Lakso Anindito, Aldo Bautista, Svitlana Lutsiuk and Joseph Rakotondramanana.\n\n## Executive summary\n\nAdopted in 2019, UNCAC Resolution 8\u002F12 Preventing and combating corruption as it relates to crimes that have an impact on the environment - urges States Parties to prevent, investigate and prosecute corruption offences where they may be linked to crimes that have an impact on the environment.\n\nIn 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\u002F12. The purpose of the updated report Saplings of hope is to highlight what progress has been achieved since then.\n\n## Corruption prevention measures\n\nStates 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.\n\nPromising corruption prevention interventions include:\n\n- · 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.\n- · 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.\n- · 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.\n- · Launching awareness-raising campaigns to promote knowledge of anti-corruption measures. This is an important first step to their effective implementation.\n\n- · 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.\n- · 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.\n\n## Enforcement actions\n\nSeveral 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.\n\nPromising enforcement interventions include:\n\n- · 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.\n- · 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.\n- · 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.\n\n## Essential role of civil society and the media\n\nAlongside 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.\n\nTheir 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.\n\n## The way forward\n\nAs this 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:\n\n- · Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources.\n- · Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment.\n- · Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms.\n- · Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment.\n- · Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment.\n- · 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.\n- · 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.\n- · Sharing knowledge , case law, success stories, etc.\n- · Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity.\n\n- · Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related issues.\n\nAs 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.\n\n## Addressing corruption that has an impact on the environment\n\nThe 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 ' .\n\nFocusing 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.\n\nAdopting a holistic approach is crucial to address all forms of corruption that affect the environment, and thus to protect the environment and people.\n\n## Acronyms and abbreviations\n\nACAMS\n\nAssociation of Certified Anti-Money Laundering Specialists\n\nAI\n\nArtificial intelligence\n\nCIJ\n\nCentre for Investigative Journalism\n\nCITES\n\nConvention on International Trade in Endangered Species of Wild Fauna and Flora\n\nDRC\n\nDemocratic Republic of the Congo\n\nEITI\n\nExtractive Industries Transparency Initiative\n\nFINTRAC\n\nFinancial Transactions and Reports Analysis Centre of Canada\n\nGUARD Wildlife\n\nGlobal United Action to Reduce and Dismantle Wildlife Crime\n\nICJ\n\nInternational Consortium of Investigative Journalists\n\nIIC\n\nInstitutional Integrity Committee\n\nNRGI\n\nNatural Resource Governance Institute\n\nOP\n\nOperative paragraph of a UN Resolution\n\nSANParks\n\nSouth African National Parks\n\nSOP\n\nStandard operating procedure\n\nSTR\n\nSuspicious transaction report\n\nUNCAC\n\nUnited Nations Convention against Corruption\n\nUNODC\n\nUnited Nations Office on Drugs and Crime\n\nWCO\n\nWorld Customs Organization\n\nTable of contents\n\n| Executive summary ��������������������������������������������������������������������������������������������������5                                                    | Executive summary ��������������������������������������������������������������������������������������������������5                                                    |    |\n|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|\n| 1  Introduction   ��������������������������������������������������������������������������������������������������������������������������������������������������     | 1  Introduction   ��������������������������������������������������������������������������������������������������������������������������������������������������     | 12 |\n| 1.1                                                                                                                                                                      | What are crimes that have an impact on the environment?                                                                                                                  | 13 |\n| 1.2                                                                                                                                                                      | Corruption and crimes that have an impact on the environment  15                                                                                                         |    |\n| 1.3                                                                                                                                                                      | Purpose and structure of the report                                                                                                                                      | 16 |\n| 2  Prevention   ������������������������������������������������������������������������������������������������������������������������������������������������������   | 2  Prevention   ������������������������������������������������������������������������������������������������������������������������������������������������������   | 18 |\n| 2.1                                                                                                                                                                      | Promoting ethical practices, integrity and transparency (OP 6)                                                                                                           | 18 |\n| 2.2                                                                                                                                                                      | International Centre for Asset Recovery (ICAR)                                                                                                                           | 21 |\n| 2.3                                                                                                                                                                      | Assessing and mitigating corruption risks (OP 15)                                                                                                                        | 22 |\n| 3  Enforcement   ������������������������������������������������������������������������������������������������������������������������������������������������        | 3  Enforcement   ������������������������������������������������������������������������������������������������������������������������������������������������        | 26 |\n| 3.1                                                                                                                                                                      | Prosecuting corruption cases and holding legal and natural  persons accountable (OP 4, 9, 11)                                                                            | 27 |\n| 3.2                                                                                                                                                                      | Using anti-money laundering legislation and financial  investigation techniques (OP 11)                                                                                  | 29 |\n| 3.3                                                                                                                                                                      | Seizing and confiscating assets (OP 3 and 4)                                                                                                                             | 31 |\n| 3.4                                                                                                                                                                      | Strengthening cooperation (OP 10)                                                                                                                                        | 32 |\n| 3.5                                                                                                                                                                      | Making use of legal instruments available (OP 5)                                                                                                                         | 35 |\n| 4  Civil society and the media as key actors   ������������������������������������������������������������������������                                                  | 4  Civil society and the media as key actors   ������������������������������������������������������������������������                                                  | 37 |\n| 4.1                                                                                                                                                                      | Raising awareness through investigative journalism                                                                                                                       | 37 |\n| 4.2                                                                                                                                                                      | Strengthening knowledge with practitioner-oriented   research and learning                                                                                               | 39 |\n| 4.3                                                                                                                                                                      | Building bridges between anti-corruption and environmental  practitioners                                                                                                | 40 |\n| 4.4                                                                                                                                                                      | Initiating litigation for lasting change                                                                                                                                 | 42 |\n| 5  A paradigm shift for corruption and the environment   �������������������������������������������                                                                     | 5  A paradigm shift for corruption and the environment   �������������������������������������������                                                                     | 44 |\n| 5.1                                                                                                                                                                      | Corruption linked to climate finance and renewable energy                                                                                                                | 44 |\n|                                                                                                                                                                          | Corruption and critical minerals                                                                                                                                         | 46 |\n| 5.2  Conclusion   ����������������������������������������������������������������������������������������������������������������������������������������������������   | 5.2  Conclusion   ����������������������������������������������������������������������������������������������������������������������������������������������������   | 49 |\n| References   ����������������������������������������������������������������������������������������������������������������������������������������������������������� | References   ����������������������������������������������������������������������������������������������������������������������������������������������������������� | 54 |\n\n| Annex 1 - Relevant resources   �������������������������������������������������������������������������������������������������������������� 60                        |    |\n|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|\n| Resource hubs, learning platforms and tools                                                                                                                             | 60 |\n| Main publications since 2019 providing a global overview of  corruption, money laundering and financial crimes linked to crimes  that have an impact on the environment | 61 |\n| Annex 2 - Initiatives from the 2023  Seedlings of hope  report   ��������������������������������                                                                       | 64 |\n\n## 1 Introduction\n\nAt the 8th session of the Conference of the States Parties to the United Nations Convention against Corruption (UNCAC), in December 2019, States Parties adopted, for the first time, a resolution recognising the relationship between corruption and environmental crimes.1\n\nResolution 8\u002F12 Preventing and combating corruption as it relates to crimes that have an impact on the environment - is a landmark Resolution.2 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. Since then, several related resolutions have been passed (Box 1).\n\n## Box 1: A growing body of UN Resolutions addressing the link between corruption and crimes that have an impact on the environment\n\nFollowing the adoption of Resolution 8\u002F12, several other United Nations processes have adopted a similar approach such as:\n\n- · December 2020: Resolution 10\u002F6 Preventing and combating crimes that affect the environment falling within the scope of the United Nations Convention against Transnational Organized Crime -by the Conference of the Parties to the United Nations Convention against Transnational Organized Crime.3\n- · December 2021: Resolution 76\u002F185 Preventing and combating crimes that affect the environment - by the United Nations General Assembly.4\n- · October 2024: Resolution 12\u002F4 Enhancing measures to prevent and combat crimes that affect the environment falling within the scope of the United Nations Convention against Transnational Organized Crim e - by the Conference of the Parties to the United Nations Convention against Transnational Organized Crime.5\n- 1 It should be noted that at the 17th meeting of the Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) in 2016, States adopted Resolution 17.6 on Prohibiting, preventing, detecting and countering corruption, which facilitates activities conducted in violation of the Convention . This Resolution is nevertheless narrower in scope than Resolution 8\u002F12 of UNCAC in so far as the former focuses on corruption linked to violations of CITES while the latter covers a wider range of crimes that have an impact on the environment.\n- 2 Read the full text of Resolution 8\u002F12 at: https:\u002F\u002Fwww.unodc.org\u002Fdocuments\u002Ftreaties\u002FUNCAC\u002FCOSP\u002Fsession8\u002FV2006805e. pdf\n- 3 See: https:\u002F\u002Fwww.unodc.org\u002Fdocuments\u002Ftreaties\u002FUNTOC\u002FCOP\u002FSESSION\\_10\u002FResolutions\u002FResolution\\_10\\_6\\_-\\_English.pdf\n- 4 See: https:\u002F\u002Fdigitallibrary.un.org\u002Frecord\u002F3954773?ln=en\n- 5 See: https:\u002F\u002Fwww.unodc.org\u002Fdocuments\u002Ftreaties\u002FCOP12\u002FResolutions\u002FE\u002FResolution\\_12\\_4.pdf\n\n- · May 2025: Resolution on Tackling illicit trafficking in wild fauna and flora, including timber and timber products, the illegal mining of and illicit trafficking in minerals and precious metals, the illicit trafficking in waste and other crimes that affect the environment - by the UN Commission on Crime Prevention and Criminal Justice (CCPCJ).6\n\nIt is also worth highlighting Resolution 048\u002F052 on Crimes that Affect the Environment adopted by the International Union for Conservation of Nature at its World Conservation Congress in October 2025.7\n\n## 1�1 What are crimes that have an impact on the environment?\n\n'Environmental crimes' , 'crimes that affect the environment' , 'crimes related to the environment' , 'crimes that have an impact on the environment' and 'nature crimes' are terms that refer to the same reality: criminal activities that have a detrimental effect on the environment.\n\nThese terms are nevertheless rarely defined. When they are, the definitions often revolve around lists of specific offences or categories of offences that harm the environment rather than providing a comprehensive global definition.\n\nFor example, Resolution 8\u002F12 does not explicitly specify the meaning or the scope of what constitutes a crime that has an impact on the environment, leaving room for interpretation. It does, however, mention various criminal activities, e.g. illegally obtained natural resources and illicitly trafficked waste.\n\nOn the other hand, Resolution 76\u002F185 provides an initial outline of what these crimes entail. According to the Resolution, crimes that affect the environment encompass activities such as 'illicit trafficking in wildlife, including, inter alia, flora and fauna as protected by the Convention on International Trade in Endangered Species of Wild Fauna and Flora, in timber and timber products, in hazardous wastes and other wastes and in precious metals, stones and other minerals, as well as, inter alia, poaching' .\n\nThe lack of a universally agreed-upon definition reflects the fact that countries have different perspectives on the matter. They have also not yet reached a common understanding of what the term 'environment' encompasses. As there is no global consensus on a specific definition, this report will refer to crimes that have an impact on the environment as covering any offences (e�g� a breach of legislation, an unlawful act or conduct) that result in harm or pose a risk to the environment such as:\n\n- · Wildlife trafficking\u002Fwildlife crimes\n- · Crimes in the forestry sector\n- · Crimes in the fisheries sector\n- · Illegal mining and trafficking of metals and minerals\n- · Waste trafficking\n- · Air, water, noise and soil pollution\n- · Illegal trade of hydrofluorocarbons or ozone-depleting substances\n\nCrimes that have an impact on the environment are among the most lucrative criminal activities in the world (see Figure 1 for an estimate per crime category). However, finding recent and reliable statistics is challenging. Hence, the true extent of the financial gains made from these crimes is difficult to ascertain. These estimates may well, in fact, underestimate the actual criminal revenues.\n\nSources: World Atlas of Illicit Flows , Interpol, RHIPTO, and The Global Initiative against Transnational Organized Crime (2018, 15).\n\n\u003C!-- image -->\n\nCrimes that have an impact on the environment have disastrous consequences that extend far beyond the illicit profits generated by these activities. They significantly impact, and are detrimental to, the environment, public health and safety, and social and economic development.\n\nFor example, the World Bank estimated that governments lose between USD 7 and 12 billion annually in potential tax revenue. Nevertheless, measuring in financial terms the true cost and loss for the environment and human beings is extremely difficult.\n\n## 1�2 Corruption and crimes that have an impact on the environment\n\nThere is no universally agreed-upon definition of corruption. The UNCAC defines corruption by enumerating various categories of offences such as bribery, embezzlement, abuse of functions, trading in influence, money laundering and illicit enrichment. Transparency International's widely used definition describes corruption more broadly as the abuse of entrusted power for private gain.\n\nCorruption plays a crucial role in facilitating crimes that have an impact on the environment. Research and reporting by the United Nations Office on Drugs and Crime (UNODC), civil society organisations, academia and journalists have highlighted the connection between corruption and crimes that have an impact on the environment (see Section 4 and Annex 1). Adjudicated cases also provide information on this issue.\n\nThe analysis of this evidence shows that corruption linked to crimes that have an impact on the environment takes many forms. For example:\n\n- · bribery to obtain a CITES export permit for poached protected species or to be awarded a waste import permit;\n- · bribery to prevent inspection or control in a protected area, at border controls, etc.;\n- · bribery to be released from custody, to avoid prosecution and conviction or to receive minimal sanctions for crimes that have an impact on the environment.\n\nIn fact, corrupt practices facilitate all aspects of crimes that have an impact on the environment (Figure 2). They involve multiple actors from public officials to companies and organised crime.\n\nMeasuring the scale of corruption linked to crimes that have an impact on the environment is, however, challenging.8 This is due to the complexity and clandestine nature of corruption, along with the wide range of corrupt acts involved in enabling crimes that have an impact on the environment.\n\nIn 2016, Interpol estimated the global cost of corruption in the forestry sector to be around USD 29 billion (Interpol 2016). To the authors' knowledge, this is the only attempt at measuring corruption as it relates to crimes that have an impact on the environment.\n\nFigure 2: Intrinsic link between corruption and crimes that have an impact on the environment\n\n\u003C!-- image -->\n\n## Crimes that affect the environment\n\n\u003C!-- image -->\n\n## 1�3 Purpose and structure of the report\n\nIn 2021, UNODC published an overview of the efforts made by UNCAC States Parties to prevent and counter corruption related to crimes that have an impact on the environment at the national and international levels (UNODC 2021).\n\nTwo years later, in 2023, it appeared important to take stock and assess progress ahead of the 10th Conference of the States Parties to the UN Convention against Corruption which took place in Atlanta, Georgia, US, from 11-15 December 2023. Therefore, the Basel Institute on Governance provided a panorama of emerging initiatives across the world since the adoption of Resolution 8\u002F12.9 By showcasing the actions taken by UNCAC States Parties as well as civil society, academia and the media, the report aimed at encouraging States to expand their efforts and share their progress.\n\nThe present Working Paper builds on our 2023 report. It provides an overview of prevention and enforcement actions, initiatives and measures implemented by UNCAC States Parties in 2024 and 2025 to combat corruption as it pertains to crimes that have an impact on the environment.\n\nSpecifically, Section 2 focuses on prevention and Section 3 on enforcement actions. Section 4 underscores the valuable contributions made by non-state actors, in particular civil society organisations, academia and the media in this collective endeavour. Section 5 highlights main trends and marks a crucial\n\nchange from the 2023 report. Indeed, it makes the case that time has come 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 Conclusion includes a list of promising initiatives for corruption prevention and enforcement.\n\n## Caveat\n\nThe report is based on publicly available information and relies on desk-based research as well as insights shared by experts interviewed between 16 October and 24 November 2023 as well as between 20 October and 28 November 2025. It does not aim to provide an exhaustive list of actions and measures taken by UNCAC States Parties, civil society organisations, the media and academia to prevent and combat corruption in relation to crimes that have an impact on the environment.\n\nFurthermore, the report does not assess whether these actions can be considered as 'good practices' . Given that many of these interventions are still in their early stages of implementation, it would be premature to draw final conclusions. Further research and monitoring are needed to assess the impacts of these measures in addressing corruption linked to crimes that have an impact on the environment.\n\nNonetheless, the report does present various ongoing and promising initiatives that can serve as inspiration and guidance for States and other stakeholders seeking to explore new strategies and adopt similar approaches to address this critical challenge.\n\n## 2 Prevention\n\nFigure 3: Operative paragraphs of Resolution 8\u002F12 relating to prevention\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nOP 6: Strengthen anti-corruption frameworks, promote ethical practices, integrity and transparency, and endeavour to prevent conflicts of interest\n\nOP 12: Establish confidential complaint systems, whistle-blower protection programmes, including protected reporting systems, and effective witness protection measures\n\nOP 7: Ensure integrity throughout the entire crime prevention and criminal justice system\n\nOP 15: Take measures to assess and mitigate corruption risks along the value chains\n\nOP 8: Promote the active participation of non-State actors in preventing corruption and raising awareness\n\nResolution 8\u002F12 includes five operative paragraphs focusing on prevention measures to reduce corrupt practices. This report provides examples of interventions and initiatives taken by States in three areas: promoting ethical practices (OP 6), establishing whistleblowing protection programmes (OP 12) and assessing and mitigating corruption risks (OP 15).\n\n## 2�1 Promoting ethical practices, integrity and transparency (OP 6)\n\nStrengthening integrity and ethical practices within governmental institutions and agencies tasked with preventing crimes that have an impact on the environment is essential for building strong institutions that can effectively tackle corruption linked to the environment. Over the last six years, States have taken various initiatives to promote a culture of integrity, in particular by involving leadership and toplevel management in the implementation of corruption prevention measures and by developing public officials' skills and adherence to shared ethical values, standards of conduct and principles.\n\nSince the publication of the report in 2023, Kenya Wildlife Service ,10 with support from UNODC, has continued working towards fostering a culture of integrity among its over 6,000 staff members. It has organised eight training sessions on integrityrelated issues such as the corruption prevention committees,11 the corruption risk assessment matrix, the integrity office, etc.\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nIn 2024, Kenya Wildlife Service adopted its 2024-2028 strategic plan in which accountability and integrity were defined as two of the organisation's core values. It also created a gift register, setting clear rules on thresholds and types of gifts allowed. Moreover, in July 2025, it updated its corruption risk assessment matrix to reflect the current corruption risks across various departments. The institution also plans to conduct a new corruption perception and experience survey in 2026 to measure progress and changes since 2019. 12  This upcoming survey will help Kenya Wildlife Service to assess the effectiveness of its corruption prevention initiatives.\n\nIn addition to Kenya Wildlife Service, other institutions have taken steps to promote ethical practices in Kenya. For example, in 2024, Kenya Fisheries Service , with support from UNODC, developed a corruption prevention policy that includes, among other aspects, a code of conduct and a whistleblowing policy. These documents aim to mitigate 30 corruption risks identified and prioritised as 'high risks' by Kenya Fisheries Service. They were approved in 2025 by the institution's senior management, its board of trustees, the Ethics and Anti-Corruption Commission and the Public Service Commission. Dissemination activities are planned in Nairobi and along the coastal region.\n\nAuthorities in Bolivia, Ecuador and Peru , with support from the Basel Institute on Governance, have promoted transparency and integrity in the forestry and mining sectors with the ultimate goal to induce behaviour change. In total, 6,172 public officials and civil servants from agencies in these three countries have participated in integrity workshops designed to encourage ethical reflection and strengthen public integrity in the exercise of their public functions.\n\nIn Malawi , a distinct approach to promoting ethical practices, integrity and transparency has been adopted (see Box 2).\n\n## Box 2: Malawi - promoting a holistic corruption prevention approach\n\nSince 2019, Malawi has adopted a holistic approach to preventing corruption. Each ministry, department and agency must allocate a minimum of 1 percent of its annual budget to tackle corruption . 13 For example, the Department of Forestry under the Ministry of Natural Resources and Climate Change has dedicated 1 percent of its total annual budget in 2024 to anti-corruption initiatives and has used 75 percent of the amount allocated.\n\n\u003C!-- image -->\n\nIn addition, each ministry, department and agency must establish an Institutional Integrity Committee (IIC) to promote integrity, transparency and accountability and to improve service delivery.\n\nThe Department of Forestry established its IIC in 2023. Since then, its members have participated in various training sessions on corruptionrelated issues with support from the Malawi Anti-Corruption Bureau and the Basel Institute on Governance. IIC members have subsequently conducted awareness sessions in six locations across the country, reaching 233 staff members. In collaboration with the Anti-Corruption Bureau, the IIC has also developed a corruption prevention policy, including a code of ethics and an awareness brochure, available in English and in Chichewa.\n\nThe Department of National Parks and Wildlife , too, has established an IIC in 2023 with support from the Anti-Corruption Bureau, the Basel Institute on Governance and UNODC. Its IIC members have taken part in training sessions, including on conducting initial corruption investigations and on public procurement.\n\nThe Department of National Parks and Wildlife has also consulted 500 staff members in the Central, Northern, Upper-Shire and Lower-Shire divisions to develop a corruption prevention policy which reflects the insights, experiences and day-to-day realities of the Department. 14\n\nFurthermore, the Department of National Parks and Wildlife adopted a code of ethics in 2023. To increase knowledge of the ethics code among staff and disseminate it across the different parks and border posts, the department used printed posters and a short video shared via WhatsApp.\n\nThe Anti-Corruption Bureau has played an instrumental role to create a culture of integrity within the Department of Forestry and the Department of National Parks and Wildlife.\n\n## 2�2 Establishing whistleblower protection programmes (OP 12)\n\nWhistleblowers have played a crucial role in exposing corruption and crimes that have an impact on the environment, but they often face retaliation for their actions. An appropriate legal framework and effective whistleblowing protection programmes are crucial not only to enable individuals to safely report wrongdoing, but also to deter unethical behaviours.\n\nWhile article 33 of UNCAC provides that appropriate measures shall be incorporated to grant protection to those who report corruption, many countries do not have dedicated legislation. When they do, the scope, the forms of protection and the effectiveness of the laws vary widely (Feinstein, Devine et al. 2021). It should be noted that these laws do not specifically focus on corruption or on crimes that have an impact on the environment.\n\nIn addition to adopting a dedicated legal framework, it is essential to establish effective whistleblowing protection programmes.\n\nIn Kenya, to encourage the reporting of corruption, Kenya Wildlife Service , with support from UNODC, developed an automated integrity management system. An integrity office was established in 2023 and has been operational since 2024. Composed of two staff members, the office is responsible for receiving, analysing, processing and monitoring corruption reports through a separate server as well as ensuring that appropriate actions are taken. Complaints can be submitted via a dedicated hotline, by email, via integrity boxes and online. Each complaint is assigned a unique number to ensure anonymity.\n\nBetween July 2024 and July 2025, the integrity office received 87 alerts, of which 57 have been closed and 30 are still under enquiry, a result that highlights the success of the whistleblowing programme. Based on employee feedback and the upcoming whistleblowing legislation, Kenya Wildlife Service is reviewing its whistleblowing policy to further strengthen, among other aspects, confidentiality and anonymous reporting.\n\nFor whistleblowing protection programmes to be effective, they must be widely known and easily accessible�\n\nIn South Africa, South African National Parks (SANParks), with support from UNODC, developed an awareness-raising campaign and communication strategy to promote the whistleblowing hotline available for reporting corruption and wrongdoings. Launched in November 2024, the campaign targeted both SANParks employees and external stakeholders and led to an increase in the number of alerts received (from 44 reports for the year 2023-2024 to 65 in 2024-2025).\n\nIn Bolivia , a similar approach was implemented with UNODC's support. In 2025, the Authority of Forests within the Ministry of Environment prepared and distributed awareness-raising materials (handouts, roll-ups and reporting boxes) with the objective of enhancing public engagement and increasing the number of reported cases of corruption.\n\n## 2�3 Assessing and mitigating corruption risks (OP 15)\n\nCorruption risk assessments enable institutions to understand the wide range of corruption vulnerabilities linked to crimes that have an impact on the environment, map the corruption risks and associated mitigation measures, assign responsibility for implementing mitigation measures and outline how progress will be monitored .\n\nSince 2019, various methods and approaches for assessing corruption risks have been developed both at sectoral (e.g. forestry, fisheries or mining) and institutional levels. For instance, UNODC designed methodologies for the fisheries sector 15 and for wildlife management authorities 16 . The Basel Institute on Governance designed the Map, Characterise, Assess and Recommend (MCAR) method for law enforcement and criminal justice processes. 17\n\nOver the last six years, multiple countries have conducted corruption risk assessments. UNODC is supporting six wildlife authorities, six forest authorities, two fisheries authorities and one environmental authority from eight countries to assess their corruption risks. 18\n\nFor example, in South Africa, the Department for Forest, Fisheries and Environment conducted a corruption risk assessment in October 2024. The Department, then, organised a strategic management anti-corruption workshop in May 2025 to embed integrity measures into routine operations and accountability systems. With UNODC's support, the Fisheries branch developed a series of standard operating procedures (SOPs) related to the monitoring, control and surveillance functions, integrating anti-corruption safeguards under each SOP. As a next step, the Fisheries branch will review the workplans of different job categories to align them with the new SOPs and ensure that anti-corruption measures are streamlined.\n\nThe Basel Institute on Governance has been working in partnership with ministries and agencies in six countries to design and implement corruption risk assessments (see also Box 3). 19 In some cases, these assessments refer to widely used international standards. One such example is the development of corruption risk management plans for the timber value chain - based on ISO 31000 on risk management and ISO 37001 on anti-bribery management systems - by the Forest and Land Inspection and Social Control Authority in Bolivia and the Ministry of Environment and Energy in Ecuador in 2024. 20\n\n- 17 See: https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-guide-to-conducting-corruption-risk-assessments-in-a-wildlife-lawenforcement-context\n- 18 Bolivia, Kenya, Malawi, Mozambique, Nigeria, Solomon Islands, South Africa and Uganda.\n- 19 Bolivia, Ecuador, Indonesia, Malawi, Peru and Ukraine.\n- 20 Corruption risk assessments were conducted in 2023.\n\nWhile assessing corruption risks is essential, implementing the measures identified in the action plans is even more important for effective corruption prevention . With support from the Basel Institute on Governance, the Forest and Land Inspection and Social Control Authority in Bolivia reached implementation levels of 82 percent and the Ministry of Environment and Energy in Ecuador 79 percent by the end of the first year of implementation. 21\n\nCorruption risk assessments are often carried out at the national level, but in some cases they are developed at the regional level to better reflect local contexts and territorial vulnerabilities. This approach has been adopted in Peru by the Regional Government of San Martín, through its Regional Environmental Authority, and by the Regional Government of Ucayali, through its Regional Forest and Wildlife Management Office, with support from the Basel Institute on Governance.\n\nThis process resulted in the approval of a corruption risk management plan for the issuance of forest transport guides in December 2024. The plan includes control measures, the institutions responsible for implementation and timelines. Implementation is ongoing, with measures currently focusing on satellite monitoring in San Martín and on the transfer of seized or abandoned forest products in Ucayali.\n\nBox 3: Ukraine - continued anticorruption efforts despite the war\n\nHistorically, the forestry sector in Ukraine has been one of the areas of the national economy most exposed to systemic integrity risks. In 2023, a report published by the Basel Institute on Governance identified institutional gaps that enable corruption schemes and illegal logging. 22\n\nFollowing the report's findings, the National Agency on Corruption Prevention, the Prosecutor General's Office of Ukraine, the Basel Institute on Governance and WWF-Ukraine conducted an in-depth analysis of corruption risks in the forestry sector and proposed mitigation measures. 23\n\nThe outlined reforms are demanding in any context. For a country at war and given the difficult conditions under which authorities must operate, these reforms are particularly challenging. However, safeguarding its forestry sector through strengthened governance is a crucial priority for post-war economic reconstruction.\n\nLaw enforcement is pursuing numerous irregularities in Ukraine's forest management. To prevent such irregularities from occurring in the first place, corporate governance must be strengthened and stronger internal control measures must be built. These are ongoing priorities that need to be augmented with greater transparency measures to enable independent oversight of the industry.\n\n## Box 4: Fostering peer-to-peer learning exchanges on corruption prevention\n\nIn 2024, Bolivia, Ecuador and Peru met to review progress in implementing their corruption risk management plans and to exchange lessons learned. Field visits allowed participants to observe practical control tools. An example is the low-cost digital microscope used in San Martín to verify timber species, illustrating that corruption prevention can be effective even without substantial financial resources. The meeting also strengthened regional cooperation among institutions, helping to build a collaborative network dedicated to promoting more transparent and sustainable forest management practices.\n\nIn addition, the Basel Institute on Governance organised a workshop in 2024 on corruption risk management in the timber value chain, attended by representatives from forest authorities of Bolivia, Ecuador and Peru, as well as regional governments and Indigenous leaders. A second edition is taking place at the time of writing this report.\n\nFurthermore, the Forest and Land Inspection and Social Control Authority in Bolivia and the Basel Institute on Governance held an event on 'Satellite Monitoring for Crime Prevention and Forest Protection in Bolivia' in March 2025. This event brought together expert agencies from Bolivia, Ecuador and Peru to share knowledge and reflect on ways to strengthen satellite monitoring for the prevention of environmental crimes and acts of corruption in Bolivia's forests. As a result, participants recommended developing technical solutions, algorithms and institutionalised procedures to process, validate and use satellite information as evidentiary input in administrative and criminal proceedings.\n\nPeer-to-peer learning exchanges have also been organised in other regions. For instance, the Nigeria Park Service (in 2024) and the Ministry of Water and Environment of Uganda (in 2025) undertook a 'study tour' to meet with Kenya Wildlife Service and Kenya Fisheries Service, in collaboration with the Kenyan Ethics and Anti-Corruption Commission and UNODC.\n\nThe visits aimed to enhance knowledge and awareness of good practices related to corruption risk assessments in Kenya, learn how to establish corruption prevention or management committees at a sectoral level, share practical experiences, build lasting relationships with other countries and strengthen regional collaboration.\n\n## 3 Enforcement\n\nFigure 4: Operative paragraphs of Resolution 8\u002F12 relating to enforcement\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\nOP 3 and 4: Recovery and return of proceeds of crimes in accordance with UNCAC and of crimes that have an impact on the environment\n\nOP 4 and 11: Investigate and prosecute corruption as it relates to crimes that have an impact on the environment, including by using financial investigation techniques\n\nOP 9: Take measures to ensure that legal and natural persons are held accountable for corruption offences\n\nResolution 8\u002F12 puts a strong emphasis on enforcement actions. In particular, UNCAC States Parties are urged to take actions to investigate, prosecute, hold accountable legal and natural persons for corruption offences, strengthen cooperation, and recover and return proceeds of crimes. Accessing information on case laws is difficult (Box 5). Nevertheless, the report highlights interesting and promising enforcement approaches.\n\n## Box 5: Absence of publicly available statistics does not imply an absence of cases\n\nThe lack of publicly available statistics on investigations and convictions, coupled with the absence of systematic and specific data collection by countries on cases of corruption linked to crimes that have an impact on the environment, poses a challenge in assessing progress and determining the number of ongoing or adjudicated cases since 2019. 24 However, the absence of publicly available statistics should not be seen as an indication that corruption cases related to crimes that have an impact on the environment are non-existent.\n\n\u003C!-- image -->\n\nOP 5: Make use of legal instruments available to tackle corruption as it relates to crimes that have an impact on the environment, including through legislation related to money-laundering, corruption, fraud, racketeering and financial crime\n\nOP 10: Strengthen cooperation in criminal matters\n\nMoreover, while law enforcement authorities around the world have taken enforcement actions against crimes that have an impact on the environment, the degree of focus on potential corrupt practices in these cases varies. In other words, the absence of corruption in reported cases of crimes that have an impact on the environment does not necessarily mean that there was no corruption . Rather, it suggests that corruption might not be explicitly addressed in the reported cases. The actual number of corruption incidents linked to crimes that have an impact on the environment could, in fact, be much higher.\n\nAdditionally, States rarely disclose information about ongoing investigations due to confidentiality reasons. Hence, there is likely a more extensive number of cases involving corruption linked to crimes that have an impact on the environment than what is indicated in this report.\n\n## 3�1 Prosecuting corruption cases and holding legal and natural persons accountable (OP 4, 9, 11)\n\nSince 2019, law enforcement authorities have investigated and prosecuted individuals and companies for corruption offences linked to crimes that have an impact on the environment. There is anecdotal evidence in countries such as Cameroon, Kenya, Indonesia, Malawi, Namibia and The Gambia (see Box 6 on Namibia).\n\nWhen convicted, individuals and companies face imprisonment, fines and confiscation of assets (see Section 3.3 below). We are also starting to see specific financial penalties included in the sentencing to compensate for the environmental harm done and conduct restoration actions (see Annex 2 on Indonesia and Section 4.4 on strategic litigation by civil society). However, the number of investigations and prosecutions remains low compared to the number of suspected corruption incidents reported by media and civil society organisations.\n\n## Box 6: Namibia - bringing high-level public officials to justice\n\nIn December 2019, media outlet Al Jazeera exposed extensive corrupt practices in Namibia's fishing industry following the publication of over 30,000 documents by WikiLeaks from whistleblower Johánnes Stefánsson (Al Jazeera 2019). This scandal became known as the Fishrot case or Fishrot scandal.\n\n\u003C!-- image -->\n\nThis is the first transnational corruption case in the fisheries sector. 25 It involves public officials in Namibia (including the former Attorney General, who at the time of his arrest was the Minister of Justice, and the former Minister of Fisheries and Marine Resources), a fishing company headquartered in Iceland, a bank located in Norway and a total of 27 jurisdictions involved at various levels.\n\nThe investigation, prosecution and trials are taking place in Namibia, where the corruption offence took place. The suspects are indicted for racketeering, bribery, money laundering and tax evasion. International cooperation through mutual legal assistance contributed to the successful conclusion of the investigation. Law enforcement authorities did not face political interference despite the fact that high-level public officials were charged with corruption. Witnesses are also determined to testify notwithstanding the high visibility and stakes of the case. Paulus K. Noa, Director-General of the Namibian Anti-Corruption Commission, refers to the case as 'a true testimony of the Government of Namibia's commitment to fighting corruption and organised crimes' .\n\nWhile the trial was expected to open in 2024, the case has since been postponed and delayed due to the defendants' various applications. Though the final outcome is uncertain, the case is an illustration of a successful enforcement action in a grand corruption case.\n\n## 3�2 Using anti-money laundering legislation and financial investigation techniques (OP 11)\n\nFinancial investigations - also known as 'follow-the-money' methods - are instrumental to get an understanding of the locations, the networks of actors and assets involved, the movement of funds and how the criminal activities are financed (Reid, Parry-Jones and Keatinge 2020). They are necessary not only to combat crimes that have an impact on the environment, but also for exposing corrupt allies and gathering evidence to initiate corruption cases linked to these crimes. 26\n\nIt is also important that national legal frameworks recognise crimes that have an impact on the environment as a predicate offence in order to mobilise antimoney laundering legislation to tackle these crimes.\n\nSeveral countries, including Canada, Colombia, China, Kenya, Hong Kong, Indonesia, Malawi, Mozambique, South Africa, 27  Thailand and the US, have applied an anti-money laundering approach to wildlife trafficking (Hsu 2025). For instance, in at least eleven cases since 2019, the US indicted individuals for money laundering in connection with wildlife crimes.\n\nOne such example is Bhagavan Doc Antle who pleaded guilty in November 2023 to money laundering and to a conspiracy to violate the Lacey Act (U.S. Department of Justice 2023). He was sentenced to 12 months in prison, fined USD 55,000 and ordered to forfeit three chimpanzees and more than USD 197,000 to the US government (U.S. Department of Justice 2025). Bhagavan Doc Antle used bulk cash payments to hide the transactions and requested that payments for endangered species be made to his non-profit so they could appear as 'donations' (U.S. Department of the Treasury 2024).\n\nIn Mozambique , Chabane Assuba, a broker, was sentenced in 2024 to 30 years in prison and fines equivalent to two years for illegal possession and storage of wildlife products, criminal association and money laundering (English.news.cn 2024). More than 600 kg of products of prohibited species (such as lion bones, elephant bones and ivory tusks) were found at his residence.\n\nAnti-money laundering legislation and 'follow-the-money' methods can be applied to all crimes that have an impact on the environment and not only to wildlife crimes. Some countries have taken this approach (Box 7). In Brazil , federal authorities launched an investigation into the laundering of more than USD 16.4 million of\n\nillegally mined gold (Pope 2023). A shell company supposedly trading hospital supplies is alleged to have laundered over USD 12.3 million in gold.\n\nIn 2024, the Spanish Guardia Civil launched Operation Dashboard, with support from the European Anti-Fraud Office, against individuals who were introducing hazardous waste into the EU. They are under investigation for alleged crimes against natural resources and the environment, falsification of certificates, money laundering, tax fraud and membership in a criminal group (OLAF 2024).\n\nSince the adoption of Resolution 8\u002F12, there are nevertheless very limited examples of financial investigations targeting corruption linked to crimes that have an impact on the environment (see Annex 2 on Indonesia). 28\n\n\u003C!-- image -->\n\nBox 7: Indonesia - Environmental Ministry achieves first conviction for money laundering linked to illegal logging 29\n\nIn 2022, an Indonesian Court\n\nsentenced a businessman named Supono for illegal logging and then, in 2024, for money laundering. In both cases, he was sentenced to prison and ordered to pay a fine. Financial investigations revealed that the defendant earned approximately USD 127,000 from illegally sourced timber from Alas Purwo National Park and several other regions across Indonesia.\n\nSupono illegally traded rosewood with two sawmill companies. To conceal the illicit origin of the proceeds, the payments were channelled through his son's bank account. Supono then transferred the funds back to his own bank account in smaller transactions, integrating them with money he had loaned from the bank and using the illicit funds to pay back the loan.\n\nThis is a landmark conviction. It is notable because the investigations were led by investigators from Indonesia's Ministry of Environment and Forestry. Until a Constitutional Court's ruling in 2021, only a limited number of law enforcement authorities could use the provisions set in the 2010 Anti-Money Laundering Law No. 8\u002F2010. The court's 2021 decision extended the power to pursue money laundering offences\n\nlinked to crimes that have an impact on the environment to investigators from natural resources and environmental authorities. This is the first money laundering conviction achieved by the Ministry of Environment's investigators.\n\nWhile the amount of money laundered in this case and the imposed fines (approximately USD 29,900 for illegal logging and USD 3,000 for moneylaundering) were relatively modest, the case has opened the door to tackling more complex, high-value cases in the future.\n\n## 3�3 Seizing and confiscating assets (OP 3 and 4)\n\nRecovering assets (such as vehicles, houses or bank accounts) in a corruption or money laundering case linked to crimes that have an impact on the environment is crucial. Asset recovery is a powerful deterrent. It can mean seizing assets that were bought with illicit profits as well as seizing the instrumentalities of the crimes (the trucks, the boats or machinery used in illegal activities), and therefore directly disrupts operations of the networks of actors engaged in corruption and crimes that have an impact on the environment.\n\nOne example can be found in Mozambique . In 2024, two rhino horn traffickers Simon Valoi and Paulo Zucula - were convicted for illegal wildlife trade, criminal association and money laundering (Wildlife Justice Commission 2024). Simon Valoi was sentenced to 27 years in prison, the confiscation of assets worth approximately USD 140,625, and a USD 170,000 fine in compensation to the State. Paulo Zucula received a 24-year prison sentence, a USD 62,500 fine in compensation to the State and USD 265,625 of his assets were confiscated.\n\nIn October 2025, the Economic and Financial Crimes Division of the High Court of Zambia , a civil jurisdiction, ordered the confiscation of assets valued at more than USD 1 million to the benefit of the State (WCP News). These assets are tied to an illegal logging operation, including offices, trucks and trailers, over 1,900 logs, fork lifter and industrial machinery. 30  The National Prosecution Authority used nonconviction based forfeiture law.\n\nIn its judgement, the High Court of Zambia sent a clear message that owners must ensure their assets 'will not be used as instrumentalities in the commission or furtherance of economic and financial crimes' . It also added that 'Courts have a duty not to embolden people to engage in or perpetrate illegal logging but to protect the country's Natural Resources for future generations' .\n\nOnce confiscated, assets could be used to compensate, restore and\u002For repair the harm done . However, tracing, seizing and definitive confiscation of illicit assets related to corruption and crimes that have an impact on the environment are not yet systematic.\n\n## 3�4 Strengthening cooperation (OP 10)\n\nEnforcement actions to address corruption as it relates to crimes that have an impact on the environment require significant time and resources (for timely detection and adequate investigation), specialised knowledge and the involvement of multiple agencies or authorities. 31  Although the assistance and dedicated expertise of the respective agencies is generally needed, cooperation between the anti-corruption agency, the financial intelligence unit, prosecutors, police, customs and the agency in charge of the environment is often ad hoc at best.\n\nYet, multi-agency cooperation is a crucial step to tackle corruption linked to crimes that have an impact on the environment and dismantle criminal networks. Over the last six years, countries have worked to develop and improve inter-agency coordination at the country level and international level.\n\n## National multi-agency and interdisciplinary collaboration\n\nStates are more and more establishing multi-agency and interdisciplinary task forces within their own countries to tackle corruption linked to crimes that have an impact on the environment (Box 8).\n\nFor instance, in Kenya , under the leadership of the Ethics and Anti-Corruption Commission, an inter-agency arrangement was established comprised of Kenya Wildlife Service, the Assets Recovery Agency, the Directorate of Criminal Investigations and the Kenya Revenue Authority. The institutions meet regularly and have set specific targets to be achieved for the fiscal year July 2025 - July 2026.\n\nProactive law enforcement cooperation combined with partnerships with civil society organisations and\u002For the private sector is also essential for greater impact.\n\nFor example, the Nigeria Customs Service and Wildlife Justice Commission have been collaborating since 2021 to dismantle criminal networks involved in the trafficking of ivory and pangolin scales. This collaboration has produced tangible results: 42 suspected wildlife traffickers were arrested with 12 convictions secured, 13 major criminal networks have been disrupted, and over 25 tonnes of pangolin scales and more than one tonne of ivory have been seized (Wildlife Justice Commission 2025b). Moreover, there have been no significant pangolin scale seizures at seaports or airports for more than three years (Wildlife Justice Commission 2025a). This suggests that criminal networks have been severely disrupted.\n\nWhile this successful partnership does not focus on corruption linked to crimes that have an impact on the environment, it underscores the importance of cooperation, including with civil society organisations, to effectively halt criminal activities.\n\nBox 8: Madagascar - national and international interagency cooperation was key to dismantling a wildlife trafficking network 32\n\nIn May 2024, Thai customs authorities seized more than 1,000 radiated tortoises and 48 live lemurs from Madagascar (protected under CITES) at Suvarnabhumi International Airport in Bangkok, with support from Interpol, the Wildlife Justice Commission, the U.S. Fish and Wildlife Service and UNODC.\n\n\u003C!-- image -->\n\nWhile the case in Thailand is still ongoing, a positive outcome has already been achieved in Madagascar. Following the criminal complaint filed by the Malagasy Ministry of Environment and Sustainable Development in Madagascar, the investigation led to the identification of Malagasy, Thai and Burmese suspects. In addition to pursuing the trafficking offences, the Malagasy authorities adopted a 'follow-the-money' approach, bringing together relevant national authorities with support from the Basel Institute on Governance.\n\nOn 8 May 2025, for the first time in Madagascar, the specialised anticorruption court convicted 12 individuals for smuggling protected species, money laundering and criminal conspiracy. The defendants received prison sentences of up to ten years. They were ordered to pay a customs fine of over EUR 5 million and EUR 2.5 million in damages to the Ministry of Environment and Sustainable Development. Bank accounts, vehicles and motorcycles were also confiscated.\n\nThe Thai and Burmese nationals involved were tried in absentia (while on bail pending their related trial in Thailand), and international arrest warrants were issued. Moreover, the species seized in Thailand were safely returned to Madagascar thanks to successful international cooperation.\n\nThis case demonstrates the key role of inter-agency cooperation at the national and international levels as well as the effectiveness of applying money laundering and related criminal provisions to address crimes that have an impact on the environment. This approach is expected to be duplicated in ongoing and future cases in Madagascar.\n\n## Regional and international cooperation\n\nCross-border collaboration among law enforcement authorities is instrumental, as seen in the Fishrot case (Box 6). International cooperation takes many forms, from formal mutual legal assistance requests to information sharing between financial intelligence units through the Egmont Group  public-private , partnerships (Box 9) and informal exchanges facilitated by dedicated networks.\n\nCoordination and support from organisations like UNODC, Interpol, Europol and the World Customs Organization (WCO) are essential.\n\nThe publication of notices such as Interpol's red, silver or purple Notices helps States to find criminals and to better understand the modus operandi and methods used by criminals.\n\nProject TENTACLE, an initiative led by WCO since 2018 and funded by the U.S. Bureau of International Narcotics and Law Enforcement Affairs, places emphasis on collaboration between customs services and both financial intelligence units and police services to dismantle criminal networks.\n\nThe Informal Law Enforcement Network - an initiative launched by UNODC, WCO, OECD and Interpol in 2020 - provides a forum for government representatives, civil society organisations and the private sector to meet twice a year to discuss and facilitate the exchange of information on gold trafficking.\n\nSince the publication of the Seedlings of hope report in 2023, several joint crossborder law enforcement operations were conducted to combat crimes that have an impact on the environment. Operation Thunder 33  and Operation Panthera Onca 34 are examples from 2024.\n\nIn 2025, Operation Green Shield, 35  led by the United Arab Emirates, Brazil, Colombia, Ecuador and Peru, targeted activities linked to illegal mining, wildlife trafficking, illegal logging, fuel smuggling and illegal waste across the Amazon. The operation was part of the International Law Enforcement Initiative for Climate Change launched in February 2023. 36\n\nA new initiative, GUARD Wildlife (Global United Action to Reduce and Dismantle Wildlife Crime), was launched in February 2025 to enhance cooperation at the national, regional and international levels in order to tackle organised criminal networks involved in wildlife trafficking. It will be implemented by the International Consortium on Combating Wildlife Crime with funding from the European Union.\n\n- 36 See: https:\u002F\u002Fmoi.gov.ae\u002Fen\u002Fabout.moi\u002FInitiative\u002F040725m01.aspx#:~:text=The%20international%20law%20enforcement%20 initiative,resulted%20in%20the%20launch%20of\n\nDespite these many initiatives, multi-agency and interdisciplinary collaborations at the national, regional and international levels on corruption linked to crimes that have an impact on the environment remain limited.\n\n\u003C!-- image -->\n\nThrough the partnership, an 'operational alert' was issued to support financial institutions in recognising suspicious financial transactions. 37  In a span of two years, FINTRAC received over 150 suspicious transaction reports (STRs) with a total value equivalent to CAD 200 million - a significant rise compared to less than 200 STRs received in the ten years prior to Project Anton.\n\nThe initiative also enabled FINTRAC to increase the amount of intelligence it is sharing with domestic and international authorities (Countering Environmental Corruption Practitioners Forum 2025).\n\n## 3�5 Making use of legal instruments available (OP 5)\n\nResolution 8\u002F12 encourages States to make use of legal instruments available to tackle corruption as it relates to crimes that have an impact on the environment, 'including through legislation related to money-laundering, corruption, fraud, racketeering and financial crime' .\n\nIn the previous sections, we have seen that law enforcement authorities have been using anti-money laundering legislation to tackle this issue. Complementary approaches are possible:\n\n- · Imposing sanctions and visa bans on individuals and companies involved in corruption linked to crimes that have an impact on the environment.\n- · Using non-conviction based confiscation , i.e. the possibility to confiscate assets derived from criminal activity without the need for a criminal conviction (Spicer and Grossmann 2022).\n- · Applying social re-use of seized and confiscated assets for the benefit of citizens and the planet. The assets could be allocated to law enforcement involved in cases of corruption and crimes that have an impact on the environment or to anti-corruption and conservation civil society organisations, or used to restore nature (UNICRI 2025).\n- · Mobilising illicit enrichment or unexplained wealth laws (Dornbierer 2021).\n- · Using innovative legal instruments such as the presumption of money laundering , a mechanism adopted in France in 2023 to combat the laundering of the proceeds of crime (Brimbeuf and Bornstein 2023).\n- · Making the most of beneficial ownership and other available registers (asset declaration databases, land register, company register, procurement monitoring systems, etc.) to conduct criminal investigations.\n\nOther avenues to explore include tax-related laws, corporate due diligence legislation, misconduct and misstatements in relation to environmental, social and governance (ESG) considerations, and remedies via civil proceedings.\n\n## 4 Civil society and the media as key actors\n\nIn its preamble, Resolution 8\u002F12 highlights 'the important role of the media, civil society, academia and private sector entities in the prevention of and the fight against corruption as it pertains to crimes that have an impact on the environment' .\n\nOver the past six years, the media and civil society have played an essential role, despite facing many challenges. The space for civil society is shrinking worldwide. 72.4 percent of the global population now live in countries classified as closed or repressed (CIVICUS Monitor 2024). Press freedom is also declining in many regions. For the first time in the history of the World Press Freedom Index, Reporters Without Borders classified the global state of press freedom as a 'difficult situation' . 38\n\nThe following section looks at four areas where the media and civil society have been a driving force.\n\n## 4�1 Raising awareness through investigative journalism\n\nJournalists and media organisations have played a crucial role in exposing the links between corruption and crimes that have an impact on the environment . Major international media outlets such as Mongabay Cenozo  InSight Crime , , , The Gecko Project , the International Consortium of Investigative Journalists , and Organized Crime and Corruption Reporting Project have documented how corruption enables environmental crimes across the globe. For example, through Journalismfund Europe cross-border investigations have documented cases of waste trafficking, illegal logging, eels trafficking and exotic birds trafficking, exposing Europe's role. 39\n\nNational media have also contributed to raising awareness with support from organisations like the Thomson Reuters Foundation and the Internews' Earth Journalism Network (Box 10). In 2024, The Africa Report , together with the Pulitzer Center Rainforest Investigations Network, published a four-part series on timber trafficking in the Democratic Republic of the Congo (DRC) and how it is smuggled to Uganda and Kenya (Musinguzi 2024). The Bridge Magazine reported on corruption and wildlife trafficking along the DRC-Rwanda border (Umuhoza 2024). The Citizen documented how tax inconsistencies incentivise gold smuggling in Tanzania (Bahemu 2024) and Musoma News Hub explained how the country loses\n\ntax revenues from the illegal exploitation and trade of tin which is facilitated by corruption (Sebastian 2025). The Forefront Magazine investigated illegal mining and trafficking in minerals in Rwanda (Ntawurikura 2025) while Amazon Underworld looked at corruption and conflicts of interest in the exploitation of gold in Peru (Huerta 2025).\n\nWhile journalists and media organisations have shed essential light on the nexus between corruption and crimes that have an impact on the environment, they are particularly at risk . They face a wide range of threats, including arrest, imprisonment, surveillance, physical and digital aggressions and legal attacks such as administrative harassment or abusive lawsuits (International Press Institute 2024).\n\nBetween 2009 and 2023, at least 749 journalists, groups of journalists and news media outlets were targeted (UNESCO 2024). During the same period, 44 environmental journalists were killed in 15 different countries, with convictions secured in only five cases (UNESCO 2024). And more than 30 journalists covering issues such as waste, illegal mining, water pollution, deforestation, illegal sand extraction and renewable energy were obstructed, threatened or killed in 2024-2025 (RSF 2025).\n\nWhen journalists are killed or threatened, media organisations join forces to continue their work. In 2023, for example, 50 journalists from 16 news organisations, coordinated by Forbidden Stories, pursued the investigations on illegal fishing started by Dom Phillips and Bruno Pereira who were murdered in 2022 in the Amazon. In February 2025, Forbidden Stories investigated the murder of Cambodian journalist Chhoeung Chheng who had been documenting illegal deforestation. In Ghana, journalists reporting on illegal gold mining face abduction, beating and death threats. In response, The Fourth Estate , The Reporters' Collective and Forbidden Stories partnered to investigate the impacts of the illegal gold industry as well as the role of money and gold laundering (Abdelilah 2025).\n\nDespite the many challenges they face, journalists have kept investigating . Without their dedication and courage, our understanding of how corruption and crimes that impact the environment intersect would be far more limited.\n\nBox 10: Enhancing journalists' expertise on 'follow-the-money'\n\nReporting on corruption or money laundering linked to crimes that have an impact on the environment requires specialised skills and expertise . To strengthen media coverage of these issues and thereby raise public awareness, several organisations provide targeted training.\n\nThe East Africa Wildlife Journalism Project of Internews' Earth Journalism Network and the Thomson Reuters Foundation's Curbing Illicit Financial Flows programme organise training and workshops that build and develop expertise and knowledge of journalists to investigate corruption and trace illicit financial flows related to environmental crimes.\n\nThe Centre for Investigative Journalism (CIJ) and Finance Uncovered provide in-person and online courses on financial investigations and follow the money. CIJ has also offered in 2025 a training programme called 'Dark Green' , designed to equip European journalists with the tools and methods needed to more effectively 'follow the money' in environmental and climate related investigations.\n\nThese organisations also award grants that enable journalists to pursue their work.\n\n## 4�2 Strengthening knowledge with practitioneroriented research and learning\n\nCivil society has played a fundamental role in closing the knowledge gap in relation to crimes that have an impact on the environment.\n\nBetween 2023 and 2025, the Wildlife Justice Commission, Environmental Investigation Agency, the Igarapé Institute, the FACT Coalition, the Global Initiative against Transnational Organized Crime and Earth League International, among others, have provided evidence on wildlife trafficking, illegal logging, shark fin trafficking or gold trafficking. Launched in 2023 by the Global Initiative against Transnational Organized Crime, the ECO-SOLVE project monitors and analyses data on online wildlife trafficking.\n\nOne major change compared to 2023 is the increased number of research into illegal gold mining.\n\nWhile it is essential to strengthen knowledge on crimes that have an impact on the environment, the role of corruption is often overlooked . Limited research has focused on corruption related to crimes that have an impact on the environment.\n\nFor example, publications by the Igarapé Institute and the FACT Coalition analysed illicit financial flows (in particular money laundering) from environmental crimes, and the Basel Institute on Governance provided evidence on corruption in waste management and trade as well as on corruption in the forestry sector in Ukraine. A forthcoming report by Earth League International provides an in-depth analysis of corruption incidents linked to illegal logging, wildlife trafficking, illegal mining, land grabbing as well as illegal, unreported and unregulated fishing (Byrd et al., forthcoming). It also examines how corruption enables criminal networks to expand their activities through crime convergence.\n\nCivil society organisations have also designed self-paced e-learning courses available in different languages that are free and open to everyone with the objective of sharing knowledge and increasing awareness on the relationship between corruption and crimes that have an impact on the environment.\n\nFor example, U4 Anti-Corruption Resource Centre proposes self-paced courses on corruption linked to the forestry sector and wildlife trafficking, while ACAMS offers a self-paced course on illicit financial flows associated with illegal wildlife trade. Through Basel LEARN, the Basel Institute on Governance proposes a self-paced course on Open-source Intelligence with a case study about illegal fishing.\n\n## 4�3 Building bridges between anti-corruption and environmental practitioners\n\nSince 2019, various networks, coalitions and fora have emerged that bring together practitioners from the anti-corruption and environmental fields.\n\nThe UNCAC Coalition's Environmental Crime and Corruption working group , 40 established in 2021, offers a space for civil society organisations to coordinate and develop joint advocacy efforts, provide updates on policy developments and share knowledge and findings on corruption linked to environmental matters. More than 230 individuals are members of the working group, coming from civil society organisations working at the national, regional and international levels and specialised in a wide range of topics from wildlife trafficking and climate related issues to extractive industries.\n\nOne key advocacy output is a 2024 discussion paper to facilitate discussions on interlinkages between corruption, environmental crime and climate degradation (UNCAC Coalition 2024). A forthcoming publication aims to provide an overview of knowledge gaps and best practices to address corruption linked to crimes that have an impact on the environment.\n\nLaunched in December 2022, the Countering Environmental Corruption Practitioners Forum 41 brings together anti-corruption and conservation practitioners to discuss, exchange and foster peer-to-peer learning on issues related to corruption that impacts the environment.\n\nOver 800 members from the anti-corruption, conservation and governance communities around the globe have joined the Forum. They include practitioners from government institutions (such as anti-corruption agencies, financial intelligence units and environmental agencies), United Nations agencies, academia, civil society organisations, journalists and the private sector.\n\nPlenary sessions are held twice a year, covering a wide range of cross-cutting topics such as the nexus between human rights and environmental corruption. Five working groups have also been established to address key issues: land corruption; follow-the-money and financial investigations; climate finance; open data; and minerals corruption (the latter was launched in December 2025). Members meet regularly to exchange knowledge and strengthen collaboration. Events are recorded and made publicly available on the Forum's website, which also includes blog posts by members.\n\nThe Nature Crime Alliance , 42 launched in 2023 and hosted by the World Resources Institute, has set up a knowledge database compiling relevant research on nature crimes, a wildlife expert directory as well as an index of tools gathering publicly available data on technologies. Even though the Nature Crime Alliance does not focus its work on the nexus between corruption and the environment, the resources it provides are useful.\n\n## Box 11: Actions taken by the private sector\n\nThe private sector takes part in several global initiatives . For example, with United for Wildlife, financial institutions and the transport industries (airline and shipping companies, logistics firms, freight organisation) are committed to addressing the issue of wildlife trafficking. The private sector is also involved in initiatives such as the Global Platform for Sustainable Natural Rubber, the Forest Stewardship Council, the Extractive Industries Transparency Initiatives, the Fisheries Transparency Initiatives, the Maritime Anti-Corruption Network and the Urban Cleaning, Solid Waste and Effluents Anti-Corruption Collective Action.\n\nIn 2024, WWF and Themis, with support from the Climate Solutions Partnership (a collaboration between HSBC, World Resources Institute and WWF), launched a toolkit to equip financial institutions with knowledge on environmental crime, focusing on deforestation and land conversion, illegal mining and the illegal wildlife trade. 43\n\nPrivate sector awareness of the role, importance and impact of corruption and money laundering associated with crimes that have an impact on the environment remains nevertheless limited. Additional efforts are needed so that the private sector does not facilitate corruption and money laundering linked to the environment.\n\n## 4�4 Initiating litigation for lasting change\n\nCivil society organisations around the world have used strategic litigation to defend human rights, tackle corruption, raise awareness on a specific issue or open new legal avenues (Lemaître 2023a).\n\nFor example, Sherpa, the Center for Climate Crime Analysis, Repórter Brasil and Transparency International filed a complaint in November 2023 with the French Financial Prosecutor's Office against four French banks (BNP Paribas, Crédit Agricole, BPCE and Axa) for money laundering and concealment. The case revolves around their alleged financial support for Brazil's leading beef companies, which are suspected of contributing to illegal deforestation in the Amazon (Sherpa 2023). An investigation was opened by the Financial Prosecutor's Office.\n\nIn Italy, NGOs have made use of environmental liability provisions to secure compensation for harm caused to the environment . For example, Associazione per la Biodiversità e la sua Conservazione, supported by Conservation-Litigation. org, joined the criminal prosecution of two cactus smugglers as a civil party. In January 2025, the court convicted the smugglers and awarded EUR 20,000 in remedies to Associazione per la Biodiversità e la sua Conservazione (ConservationLitigation.org 2025). 44  The awarded funds will be invested into cacti conservation.\n\nIn Jamaica, Freedom Imagineries uses human rights laws to address corruption and crimes that have an impact on the environment . Together with 10 individuals from communities in St. Ann, it launched a case against the government for granting a bauxite mining licence located in the Cockpit Country, a protected ecological area. Freedom Imagineries argues that the mining operations have led to health issues, dust and air pollution for the communities living near the mine. It is also alleged that the award process was not followed; mining activities started before the approval was granted. The case is ongoing.\n\nIn parallel, Freedom Imagineries submitted an application in June 2022 to the InterAmerican Commission on Human Rights asking that the Jamaican government be required to adopt the necessary measures to protect the rights to health, personal integrity and life of the communities. The Commission issued precautionary measures in November 2022, requesting the country to protect the rights to life, personal integrity and health of the communities affected by the mine. 45  For defending their rights, Freedom Imagineries and affected communities have been facing threats and reprisals (Box 12).\n\nBox 12: Anti-corruption and environmental defenders under attack (Lawlor 2025,\n\nHuman rights defenders working on corruption and\u002For the environment are targeted by state and non-state actors Forst 2025). Their repression is on the rise.\n\nSince 2012, 2,253 land and environmental defenders have been killed worldwide (Global Witness 2025a). 46  In 2024 alone, 144 were murdered for defending the planet, with Latin America accounting for the vast majority of these killings (Global Witness 2025a). The most frequently reported violations include arrest and arbitrary detention, legal action, threats, surveillance and death threats (Front Line Defenders 2025). Moreover, 92 percent of defenders surveyed by Global Witness responded that they have experienced some form of online abuse or harassment as a result of their work (Global Witness 2025b).\n\nBeyond physical, verbal and online attacks, anti-corruption and environmental defenders also have to face the misuse of the legal and judicial system . They are investigated and prosecuted under national security, disinformation and anti-terrorism laws, anti-money laundering legislation and defamation provisions, among others. This practice, known as lawfare , is found on every continent  (Lemaître 2025).\n\n## 5 A paradigm shift for corruption and the environment\n\nResolution 8\u002F12 and subsequent UN Resolutions have set a precedent to address\n\ncorruption as it relates to crimes that have an impact on the environment. Nevertheless, a paradigm shift is necessary because corruption can harm the environment without being linked to a crime that has an impact on the environment .\n\nFor example, a bribe to obtain a land conversion permit for agricultural purposes may result in deforestation and biodiversity loss while no crime is committed. Similarly, embezzlement 47  of funds allocated for climate adaptation or mitigation projects such as afforestation or carbon capture impedes efforts to address climate change, without an environmental crime being committed.\n\nTherefore, 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.\n\nAs our collective understanding of the connection between corruption and the environment expands, so should our definition to encompass corruption linked to activities damaging the environment. A holistic approach, 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' is crucial for protecting the environment and people.\n\nThis section 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 (see also Box 14).\n\n## 5�1 Corruption linked to climate finance and renewable energy\n\nWhen Resolution 8\u002F12 was adopted in 2019, the connection between corruption and climate finance and renewable energy was not yet at the forefront of international debates and negotiations.\n\nOver the past six years, however, research conducted by civil society organisations and academia has highlighted how corruption hampers efforts to adapt to and mitigate climate change, jeopardises the energy transition, weakens countries' resilience to climate disasters and leads to the misuse of climate funds (e.g.\n\nNest et al. 2020; Transparency International 2022; Chan et al. 2023; Nest and Mullard 2025).\n\nIn its Climate and Corruption Case Atlas 48 , Transparency International has identified 89 cases around the globe, and its 2024 report provides an analysis of these cases (Nest 2024). Moreover, international organisations such as UNODC and the World Bank have recognised and documented the links between corruption and climate finance (World Bank 2025; UNODC and World Bank 2024).\n\nResearch has also examined the various forms corruption can take, such as conflicts of interest, undue influence and disproportionate lobbying, which can hinder the adoption and implementation of ambitious climate policies (e.g. Resimić 2022; Nest and Mullard 2021). For example, Transparency International published several reports in 2024 and 2025, analysing the influence of fossil fuel interests before and during UN climate talks and how it undermines trust and legitimacy in multilateral processes as well as obstructs efforts to reduce emissions (Gverdtsiteli 2025a; Goddard et al. 2024; Gverdtsiteli 2025b).\n\nEvidence provided by the Extractive Industries Transparency Initiatives (EITI), U4 Anti-Corruption Resource Centre and the Basel Institute on Governance have also underscored the various governance and corruption risks in the renewable energy sector (Zinnbauer and Trapnell 2023; de Vibe and Robinson 2024; Nest and Mullard 2025). This is an area requiring additional focus.\n\nBillions of dollars are mobilised and invested for climate mitigation and adaptation. 49  Recognising and integrating corruption risks linked to climate finance and renewable energy at the international, regional and national levels is crucial to effectively address all forms of corruption jeopardising initiatives that aim to address the climate crisis.\n\nBox 13: Collaborative educational tools for raising awareness on corruption linked to climate\n\nGamification is a powerful tool for raising awareness and engaging a broad audience on anti-corruption issues through interactive discussions, creative exercises and reflection.\n\nInspired by the success of the Climate Fresk 50  - a collaborative workshop designed to share climate knowledge with the general public - UNODC, together with its youth programme, developed a variation of this format\n\nto explore and deepen understanding of how corruption can exacerbate climate change and undermine climate action.\n\nThe methodology was tested in October 2025 with a group of students at the University of Mostar in Bosnia and Herzegovina as well as officials from the country's Agency for the Prevention of Corruption and Coordination of the Fight against Corruption. It received positive feedback and is currently finalised, with public release expected in 2026.\n\nThe UNODC's 'corruption and climate fresk' will support the dissemination of knowledge and raise public awareness of corruption linked to climate issues.\n\n## 5�2 Corruption and critical minerals\n\nCritical or strategic minerals - such as copper, lithium, cobalt, nickel and rare earths - are essential to our daily lives . They are key components in mobile phones, computers, semiconductors, etc. These minerals also play an important role in reducing greenhouse gas emission and enabling the energy transition .\n\nThe International Energy Agency projects that demand for minerals used in solar panels, wind turbines, electric vehicles and related technologies will quadruple by 2040. 51 Demand is further driven by the rapid development of artificial intelligence infrastructures as well as military and defence systems, making these minerals the centre of geopolitical tensions.\n\nHowever, the growing demand, the race to secure mineral supplies, the urgency to address climate change and the immense profits at stake come with significant challenges and vulnerabilities . These range from environmental and social harms to human rights violations, corruption, financing conflicts and organised crime infiltration.\n\nResearch by Natural Resource Governance Institute (NRGI), Transparency International, EITI and UNODC underscores the risks of corruption associated with the exploitation of critical minerals (Sturman et al. 2022; Sayne et al. 2024; Carballo et al. 2025; UNODC 2025; Fitzgerald et al. 2025). For instance, 91 percent of rare earths, 74 percent of cobalt and 67 percent of nickel are located in countries with high perceived levels of corruption (Carballo et al. 2025).\n\nThese organisations have also documented how corruption undermines progress towards a low carbon economy , with corrupt practices taking place at every stage of the supply and value chains, ranging from bribery and collusion to undue influence and misappropriation of funds. NRGI identified 53 cases of corruption in 30 countries across five continents (Sayne et al. 2024).\n\nTo address these challenges, NRGI developed a diagnostic tool 52  which aims at identifying the forms of corruption and creating an action plan to prevent corruption in the oil, gas and mining sectors. NRGI's diagnostic tool has already been used in Mongolia, Philippines, Guinea and Chile to diagnose corruptions risks associated with the exploitation of critical minerals such as bauxite, lithium and nickel. 53  In the DRC, the Anti-Corruption Agency ( Agence de Prévention et de Lutte contre la Corruption - APLC) is applying the tool to assess corruption risks associated with cobalt exploitation.\n\nTransparency International Australia designed the Mining Awards Corruption Risk Assessment (MACRA) Tool to assess the underlying causes of corruption in mining sector awards. 54  It has been used in 23 countries. The OECD and EITI have also been developing guidance to support companies in conducting due diligence in mineral supply chains, taking an anti-corruption perspective. 55\n\nLastly, the UN established a panel on critical energy transition minerals, bringing together governments, intergovernmental and international organisations, industry and civil society to develop a set of common and voluntary principles to guide the transition. It published a report in 2024 laying down seven guiding principles, including principle 6 on transparency, accountability and anti-corruption measures to ensure good governance. 56\n\nWhile Resolution 8\u002F12 does not explicitly address corruption linked to critical minerals governance, States should urgently integrate anti-corruption measures and safeguards in this sector to protect efforts towards a just and equitable energy transition.\n\n## Box 14: Cross-cutting issues requiring attention: the digital challenge\n\nSeveral cross-cutting issues are not addressed by Resolution 8\u002F12, but merit close attention, as they significantly influence efforts to combat corruption that has an impact on the environment. Two examples are highlighted in this box.\n\nGovernments are increasingly relying on digital technologies and artificial intelligence (AI) tools to prevent, detect and investigate corruption and\u002For crimes that have an impact on the environment.\n\n- 52 See: https:\u002F\u002Fresourcegovernance.org\u002Fpublications\u002Fdiagnosing-corruption-extractive-sector-tool\n- 53 Briefs on lessons learned for each country are available at https:\u002F\u002Fanticorruptiontool.resourcegovernance.org\u002F\n- 54 See: https:\u002F\u002Ftransparency.org.au\u002Fpublications\u002Fmacra-tool\n- 55 See for example: https:\u002F\u002Fwww.oecd.org\u002Fcontent\u002Fdam\u002Foecd\u002Fen\u002Ftopics\u002Fpolicy-sub-issues\u002Fdue-diligence-guidance-forresponsible-business-conduct\u002Fminerals\u002Ffaq-how-to-address-bribery-and-corruption-risks-in-mineral-supply-chains.pdf\n- 56 See: https:\u002F\u002Fwww.un.org\u002Fsites\u002Fun2.un.org\u002Ffiles\u002Freport\\_sg\\_panel\\_on\\_critical\\_energy\\_transition\\_minerals\\_11\\_sept\\_2024.pdf\n\nWhile digital and AI technologies offer significant opportunities and benefits, recent studies have underscored the challenges associated with these tools, including data quality issues, opaque and discriminatory algorithms, biases, regulatory gaps or risks to privacy and fundamental rights (Resimić 2025, Izdebski 2023).\n\nFurthermore, digital and AI technologies can be 'corrupted' and abused for private gain (Köbis et al. 2022a, Köbis et al. 2022b, Transparency International 2025). It can also be used to increase the surveillance of journalists and civil society organisations and further repress civic space.\n\nAddressing and mitigating these risks is essential to ensure digital and AI technologies are an effective approach to tackle corruption that has an impact on the environment.\n\nCryptocurrencies are now well established in the global financial system. They are also increasingly used to facilitate illicit activities - not only cybercrime, but any type of crime involving the transfer of monetary value. Cryptocurrencies can enable corruption and money laundering (Elsayed 2023, UNODC 2025) and are intersecting with crimes that have an impact on the environment. They can add a layer of opacity and complexity that helps conceal and launder the proceeds from crimes that have an impact on the environment.\n\nFor example, in Brazil, law enforcement dismantled a criminal network which had created its own cryptocurrency to launder profits from illegal gold mining (Sayki 2022, Ministério da Justiça e Segurança Pública 2022).\n\nDespite its prominent role, research on - and our understanding of how cryptocurrencies are used in corruption cases linked to crimes that have an impact on the environment remains limited. Preventing and combating the misuse of cryptocurrencies, for example by equipping law enforcement authorities to navigate financial investigations related to cryptocurrencies, is therefore vital to effectively address corruption that has an impact on the environment.\n\n## 6 Conclusion\n\nSince the adoption of Resolution 8\u002F12 in December 2019, various activities have been taking place to tackle corruption as it relates to crimes that have an impact on the environment.\n\nIn terms of prevention , the journey towards fostering a culture of integrity and anti-corruption is progressing, although it takes time for behaviours and practices to evolve. The report highlights a diverse range of actions that are beginning to generate concrete improvement in key systems, processes or norms within environmental authorities - not only to safeguard them from corruption, but also to encourage integrity champions and promote a broader shift in mindset. These initiatives can already be replicated and scaled up.\n\nThe international community can also play a key role by sharing these examples and encouraging States to go further in building robust systems capable of resisting corruption and enabling staff and citizens to safely report wrongdoing and misconduct.\n\nFrom an enforcement perspective, as the first generation of money laundering cases against environmental criminals concludes, it is vital to ensure that lessons learned are shared, replicated or adapted by relevant institutions within the same jurisdiction and in other countries. The 'follow-the-money' approach is beginning to show concrete results.\n\nIt is equally essential to address the root drivers of crimes that have an impact on the environment. Corruption remains an under-addressed dimension of efforts to combat these crimes. Thus, enforcement actions must receive adequate support and resources so they can prioritise the investigation and prosecution of corruption linked to crimes that have an impact on the environment.\n\nThis is no easy task. It requires a systemic approach with committed leadership to equip law enforcement authorities with the right resources and skills, remove obstacles and potential undue influence within the enforcement chain and build strong inter-institutional cooperation. Such collaboration is necessary for specialised anti-corruption actors to broaden their focus and investigate and prosecute crimes that have an impact on the environment.\n\nThe contributions of non-state actors discussed in this report include the research and reporting from journalists, civil society organisations and academia which have enhanced our understanding of corruption as it relates to crimes that have an impact on the environment. The various fora established to facilitate exchanges among officials and professionals engaged in fighting corruption and\u002For crimes that have an impact on the environment have provided specialised networks and knowledge to accelerate peer learning, expertise and thus impact.\n\nOver the last six years, most initiatives tested or implemented have primarily focused on wildlife and forest crimes , with fewer initiatives related to other crimes that have an impact on the environment. It is worth noting, however, that this report has identified several actions targeting illegal gold mining , an increase compared to the 2023 report.\n\nEven though it is still early to draw definitive conclusions on the results and impacts of these activities, they are promising in many aspects.\n\n## What make initiatives promising?\n\nThe authors looked at a combination of the following characteristics to determine the promising initiatives identified in this report:\n\n- · Tried and tested approaches in other spaces that appear to have the right preconditions to function well in the environmental space.\n- · New approaches that are low cost and low risk.\n- · Spaces where very limited work is done to date, meaning that investments might make an outsized difference.\n- · Engagements where environmental and integrity considerations align and thus make adoption more likely.\n- · Activities that align with broader national, regional or global trends, where efforts are likely to bear fruit over time.\n\nPromising initiatives relating to corruption prevention include:\n\n- · Conducting regular corruption perception and experience surveys among staff 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.\n- · Involving high-level management and leadership at each stage of the corruption prevention approach 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.\n\n- · Stipulating a mandatory budget for corruption prevention across ministries, agencies and departments 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.\n- · Launching awareness-raising campaigns to promote knowledge of anti-corruption measures is an important first step to their effective implementation.\n- · Developing whistleblowing mechanisms 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.\n- · Peer-to-peer learning for government representatives from different countries and institutions to exchange on corruption prevention actions 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.\n\nPromising initiatives relating to enforcement include:\n\n- · 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.\n- · 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.\n- · Exploring legal avenues outside the anti-corruption field can help strengthen enforcement. These include legislation on money laundering and tax offences as well as social re-use of seized and confiscation assets, sanctions and visa bans.\n\n## Further promising initiatives\n\nUNCAC States Parties, civil society, academia, the media and the private sector have also engaged in initiatives in areas that were not laid out in Resolution 8\u002F12 which show promising signals and should be highlighted:\n\n- · The increase of transparency and accountability through initiatives such as the Extractive Industries Transparency Initiative 57 , the Fisheries Transparency Initiative 58 , the Open Government Partnership 59  and the Open Contracting Partnership 60 .\n- · The adoption of beneficial ownership legislation , the disclosure of beneficial ownership information, including politically exposed persons, and the creation of beneficial ownership registers. 61\n- · The establishment of traceability systems, electronic information systems and electronic permitting systems in the forestry, wildlife and fisheries sector. 62\n- · The monitoring and reviewing of court proceedings and decisions . 63\n\n## Looking ahead\n\nOverall, 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. Sustaining efforts and maintaining momentum over time are necessary for long-lasting change. UNCAC States Parties need to adapt and scale up initiatives that are effective or look promising, by:\n\n- · Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources.\n- · Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment.\n\n- 60 See: https:\u002F\u002Fwww.open-contracting.org\u002F\n- 61 For an overview of actions worldwide on beneficial ownership transparency, see the work by Open Ownership: https:\u002F\u002Fwww. openownership.org\u002Fen\u002Fmap\u002F\n- 62 For example, in 2021-2022, WWF Peru piloted an electronic permitting app to reduce opportunities for corruption in the fisheries sector. See: https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-peru-pilot-summary. In addition, around 30 countries are developing or planning electronic CITES permit systems.\n- 63 For more information, see the TNRC publication reviewing the monitoring of wildlife crime cases in Africa, Asia and South America: https:\u002F\u002Fwww.worldwildlife.org\u002Fpages\u002Ftnrc-practice-note-monitoring-wildlife-crime-cases-a-possible-approach-toreduce-corruption-in-the-justice-system\n\n- · Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms.\n- · Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment.\n- · Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment.\n- · 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.\n- · 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.\n- · Sharing knowledge , case law, success stories, etc.\n- · Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity.\n- · Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related issues.\n\nAs 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.\n\nFinally, a paradigm shift is now more than ever necessary. We need to move 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 ' .\n\nAdopting a holistic approach is crucial to address all forms of corruption that affect the environment, including pressing issues such as corruption linked to climate finance, renewable energy and the exploitation of critical minerals.\n\n## References\n\nAbdelilah, Alexander. 2025. Ghana: Illegal gold poisons land and global supply chains. Forbidden Stories . 24 October 2025. https:\u002F\u002Fforbiddenstories.org\u002Fghanaillegal-gold-environment-multinationals\u002F\n\nAbdelilah, Alexander. 2025. In Ghana, the environment and journalists are the first casualties of the illegal gold rush. 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Global Analysis 2024\u002F25 . Front Line Defenders.\n\nGlobal Witness. 2025a. Roots of resistance - Documenting the global struggles of defenders protecting land and environmental rights . Global Witness.\n\nGlobal Witness. 2025b. Toxic platforms, broken planet - How online abuse of land and environmental defenders harms climate action . Global Witness.\n\nGoddard, Louis, et al. 2024. COP Co-opted? - How Corruption and Undue Influence Threaten Multilateral Climate Action . Transparency International.\n\nGverdtsiteli, Gvantsa. 2025a. Fuelling Delay - How fossil fuel interests shape global climate negotiations . Transparency International.\n\nGverdtsiteli, Gvantsa. 2025b. Behind the Badge - Understanding the roles, reach, and risks of fossil fuel industry participation in UN climate talks . Transparency International.\n\nHuerta, Pamela. 2025. When Gold Rules: Politicians and Criminals Fight Over Resources in the Peruvian Amazon. Amazon Underworld . 28 October 2025. https:\u002F\u002F amazonunderworld.org\u002Fwhen-gold-rules-politicians-and-criminals-fight-overresources-in-the-peruvian-amazon\u002F\n\nHsu, Emily, et al. 2025. Dissecting the environmental - financial crime nexus: a spotlight on the illegal wildlife trade . WWF and Themis.\n\nInternational Press Institute. 2024. Climate and environmental journalism under fire: Threats to Free and Independent Coverage of Climate Change and Environmental Degradation . International Press Institute.\n\nInterpol. 2016. Uncovering the risks of corruption in the forestry sector . Interpol.\n\nInterpol, RHIPTO, Global Initiative against Transnational Organized Crime. 2018. World Atlas of Illicit Flows . Global Initiative against Transnational Organized Crime.\n\nIzdebski, Krzysztof, et al. 2023. The Digitalization of Democracy - How Technology is Changing Government Accountability . National Endowment for Democracy.\n\nKleinfeld, James. 2019. Anatomy of a Bribe: A deep dive into an underworld of corruption. Al Jazeera . 1 December 2019. https:\u002F\u002Fwww.aljazeera.com\u002Ffeatures\u002F2019\u002F12\u002F1\u002Fanatomyof-a-bribe-a-deep-dive-into-an-underworld-of-corruption\n\nKöbis, Nils, et al. 2022a. The corruption risks of artificial intelligence . Transparency International.\n\nKöbis, Nils, et al. 2022a. The Promise and Perils of Using Artificial Intelligence to Fight Corruption . Nature Machine Intelligence, 4, 418-424.\n\nLawlor, Mary. 2025. Tipping points: human rights defenders, climate change and a just transition . United Nations General Assembly.\n\nLemaître, Sophie. 2025. Réduire au silence - Comment le droit est perverti pour bâillonner média et ONG . Rue de l'échiquier.\n\nLemaître, Sophie. 2023a. Strategic litigation and its untapped potential for anticorruption. U4 Anti-Corruption Resource Centre . 12 July 2023. https:\u002F\u002Fwww.u4.no\u002Fblog\u002F strategic-litigation-untapped-potential-for-anti-corruption\n\nLemaître, Sophie. 2023b. Seedlings of hope: Addressing corruption linked to crimes that impact the environment in line with UNCAC Resolution 8\u002F12. Working Paper 50, Basel Institute on Governance. https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fwp-50\n\nMinistério da Justiça e Segurança Pública. 2022. PF Desarticula Organizações Criminosas Voltadas à Extração e Comércio Ilegal de Ouro. 7 July 2022. https:\u002F\u002Fwww. gov.br\u002Fpf\u002Fpt-br\u002Fassuntos\u002Fnoticias\u002F2022\u002F07\u002Fpf-desarticula-organizacoes-criminosasvoltadas-a-extracao-e-comercio-ilegal-de-ouro\n\nMusinguzi, Blanshe. 2024. How Congo trees are smuggled through East Africa . Africa Report.\n\nNatural Resource Governance Institute. 2025. Digging into the Problem - How corruption facilitates socioenvironmental, human rights, and Indigenous Peoples' rights harms in the mining sector . Natural Resource Governance Institute.\n\nNest, Michael, et al. 2020. Corruption and climate finance . U4 Anti-Corruption Resource Centre.\n\nNest, Michael and Saul Mullard. 2021. Lobbying, corruption and climate finance: The stakes for international development . U4 Anti-Corruption Resource Centre.\n\nNest, Michael. 2024. Climate and Corruption Atlas: Lessons from Real-World Cases . Transparency International.\n\nNest, Michael and Saul Mullard. 2025. Climate governance in a fast-changing world: Evolving patterns of corruption risks . U4 Issue 2025:2. U4 Anti-Corruption Resource Centre.\n\nNtawurikura, Rosine. 2025. Lives in Ruin: The Trail of Devastation Left by Illegal Miners in Rwanda's Kamonyi. The Forefront Magazine . 28 June 2025. https:\u002F\u002F theforefrontmagazine.com\u002Flives-in-ruin-the-trail-of-devastation-left-by-illegal-minersin-rwandas-kamonyi\u002F\n\nOLAF. 2024. OLAF pivotal in uncovering a criminal network introducing hazardous waste from the UK to the EU. OLAF . 4 July 2024. https:\u002F\u002Fanti-fraud.ec.europa.eu\u002Fmediacorner\u002Fnews\u002Folaf-pivotal-uncovering-criminal-network-introducing-hazardous-wasteuk-eu-2024-07-04\\_en?utm\\_source=chatgpt.com\n\nPope, Henry. 2023. Brazil Launches Investigation into R$80 Million in Illegal Gold. OCCRP . 11 July 2023. https:\u002F\u002Fwww.occrp.org\u002Fen\u002Fnews\u002Fbrazil-launches-investigationinto-r80-million-in-illegal-gold\n\nReid, Alexandria, Rob Parry-Jones and Tom Keatinge. 2020. Targeting corruption and its proceeds: Why we should mainstream an anti-corruption perspective into 'follow the money' approaches to natural resource crime . TNRC.\n\nResimić, Miloš. 2022. Grand corruption and climate change policies . U4 Anti-Corruption Resource Centre.\n\nResimić, Miloš. 2025 . Harnessing artificial intelligence (AI) for anti-corruption - Benefits and challenges in prevention, detection and investigation . U4 Heldesk Answer 2025:24. U4 Anti-Corruption Resource Centre.\n\nRSF. 2025. 30 journalists embody struggle for freely reported environmental coverage. RSF . 27 October 2025. https:\u002F\u002Frsf.org\u002Fen\u002F30-journalists-embody-struggle-freelyreported-environmental-coverage\n\nSAMLIT. 2025. Financial flows and key indicators associated with illegal wildlife trade in South Africa - the 2025 updated perspective . SAMLIT.\n\nSayki, Inci. 2022. Brazil Dismantles Network That Used Crypto to Launder Illegally Extracted Gold. OCCRP . 14 July 2022. https:\u002F\u002Fwww.occrp.org\u002Fen\u002Fnews\u002Fbrazildismantles-network-that-used-crypto-to-launder-illegally-extracted-gold?utm\\_ source=chatgpt.com\n\nSayne, Aaron, et al. 2024. Ten Red Flags for Corruption Risk in Transition Minerals Licensing and Contracting . Natural Resource Governance Institute.\n\nSebastian, Angela. 2025. Tanzania Bleeds Revenue as Illegal Tin Trade Thrives at Mulongo Border. Musoma News Hub. 16 June 2025. https:\u002F\u002Fmusomanewshub.blogspot. com\u002F2025\u002F06\u002Ftanzania-bleeds-revenue-as-illegal-tin.html\n\nSherpa. 2023. Complaint filed against French banks for money laundering and concealment of proceeds from illegal deforestation in the Amazon. Sherpa . 8 November 2023. https:\u002F\u002Fwww.asso-sherpa.org\u002Fcomplaint-filed-against-french-banks-for-moneylaundering-and-concealment-of-proceeds-from-illegal-deforestation-in-the-amazon\n\nSpicer, Jonathan and Juhani Grossmann. 2022. Targeting profit: non-conviction based forfeiture in environmental crime . TNRC.\n\nSturman, Kathryn, et al. 2022. Mission critical - Strengthening governance of mineral value chains for the energy transition . Extractive Industries Transparency Initiative.\n\nTransparency International. 2022. Corruption-free climate finance: Strengthening multilateral funds . Transparency International.\n\nTransparency International. 2025. Addressing Corrupt Uses of Artificial Intelligence . Transparency International.\n\nUmuhoza, Nadine. 2024. Porous border with DR Congo turns Rwanda into a wildlife trafficking hub . The Bridge Magazine.\n\nUNCAC Coalition. 2024. Breaking the silos: combating corruption and environmental crime to advance climate protection goals . UNCAC Coalition.\n\nUNESCO. 2024. Press and planet in danger: safety of environmental journalists; trends, challenges and recommendations . UNESCO.\n\nUNICRI. 2025. The social re-use of seized and confiscated assets: good policies and practices . UNICRI.\n\nUNODC. Date unknown. Crimes that Affect the Environment and Climate Change . UNODC.\n\nUNODC. 2021. Preventing and Combating Corruption as it Relates to Crimes that have an Impact on the Environment . UNODC.\n\nUNODC. 2025. The Nexus Between Cybercrime and Corruption . UNODC.\n\nUNODC and World Bank. 2024. Addressing Corruption Risks to Safeguard the Response to Climate Change - Discussion draft II. UNODC.\n\n- U.S. Department of Justice. 2023. Doc Antle, Owner of Myrtle Beach Safari, Pleads Guilty to Federal Wildlife Trafficking and Money Laundering Charges. U.S. Department of Justice . 6 November 2023. https:\u002F\u002Fwww.justice.gov\u002Farchives\u002Fopa\u002Fpr\u002Fdoc-antle-ownermyrtle-beach-safari-pleads-guilty-federal-wildlife-trafficking-and-money\n- U.S. Department of Justice. 2025. Doc Antle, Owner of Myrtle Beach Safari, Sentenced for Federal Wildlife Trafficking and Money Laundering Charges. U.S. Department of Justice . 8 July 2025. https:\u002F\u002Fwww.justice.gov\u002Fopa\u002Fpr\u002Fdoc-antle-owner-myrtle-beachsafari-sentenced-federal-wildlife-trafficking-and-money\n- U.S. Department of the Treasury. 2024. 2024 National Money Laundering Risk Assessment . Department of the Treasury.\n\nWCP News. 2025. High Court Forfeits $1 Million in Illegal Timber Assets. WCP News . 15 October 2025. https:\u002F\u002Fwww.wildlifecrimeprevention.com\u002F2025\u002F10\u002F15\u002Fhigh-courtforfeits-1-million-in-illegal-timber-assets\u002F\n\nWildlife Justice Commission. 2024. Simon Valoi convicted and sentenced to 27 years in prison: A major blow to rhino horn trafficking in Mozambique and South Africa. Wildlife Justice Commission . 21 August 2024. https:\u002F\u002Fwildlifejustice.org\u002Fsimon-valoi-convictedand-sentenced-to-27-years-in-prison-a-major-blow-to-rhino-horn-trafficking-inmozambique-and-south-africa\u002F\n\nWildlife Justice Commission. 2025a. Disruption and Disarray: An analysis of pangolin scale and ivory trafficking, 2015-2024 . Wildlife Justice Commission.\n\nWildlife Justice Commission. 2025b. Is wildlife trafficking being treated as serious crime? A review of criminal offences, penalties, and implementation of the United Nations Convention against Transnational Organized Crime . Wildlife Justice Commission.\n\nWorld Bank. 2019. Illegal logging, fishing, and wildlife trade: the costs and how to combat it . World Bank.\n\nWorld Bank. 2025. 2nd Symposium on Supranational Responses to Corruption: Integrity in Climate Finance and Action knowledge report . World Bank.\n\nZinnbauer, Dieter and Stephanie Trapnell. 2023. Race to renewables - Tackling corruption and integrity risks in the renewable energy sector . Extractive Industries Transparency Initiative.\n\n## Annex 1 - Relevant resources\n\n## Resource hubs, learning platforms and tools\n\nACAMS self-paced course: https:\u002F\u002Fwww.acams.org\u002Fen\u002Ftraining\u002Fcertificates\u002Fendingillegal-wildlife-trade#learning-points-4fd76b28\n\nBasel Institute on Governance's publications and resources on Green Corruption: https:\u002F\u002F baselgovernance.org\u002Fpublications?topic=6&type=All&country=All&language=All&title\n\nBasel LEARN: https:\u002F\u002Flearn.baselgovernance.org\n\nECOSOLVE's Global Monitoring System on illicit online wildlife markets: https:\u002F\u002Fwww. ecosolve.eco\u002Fdashboard\n\nEnvironmental Investigation Agency's Global Environmental Crime Tracker: https:\u002F\u002Feiainternational.org\u002Fglobal-environmental-crime-tracker\n\nInternational Maritime Organization's self-paced course: https:\u002F\u002Fwww.imo.org\u002Fen\u002F mediacentre\u002Fpressbriefings\u002Fpages\u002Fnew-e-learning-course-tackles-illegal-wildlife-trade. aspx\n\nNature Crime Alliance's knowledge database: https:\u002F\u002Fnaturecrimealliance.org\u002F knowledge-database\n\nNature Crime Alliance's index of tools (a compilation of tools developed by various organisations): https:\u002F\u002Fnaturecrimealliance.org\u002Findex-of-tools\n\nNatural Resource Governance Institute's tool to diagnose corruption in the extractive sector: https:\u002F\u002Fresourcegovernance.org\u002Fpublications\u002Fdiagnosing-corruption-extractivesector-tool\n\nTargeting Natural Resource Corruption knowledge hub: https:\u002F\u002Fwww.worldwildlife.org\u002F pages\u002Ftnrc-knowledge-hub\n\nTransparency International's Climate and corruption atlas: https:\u002F\u002Fwww.transparency. org\u002Fen\u002Fprojects\u002Fclimate-governance-integrity-programme\u002Fclimate-corruption-atlas\n\nTransparency International Australia's Mining Awards Corruption Risk Assessment Tool (MACRA Tool): https:\u002F\u002Fmining.transparency.org.au\u002Fmacra-tool\n\nU4 Anti-Corruption Resource Centre self-paced courses: https:\u002F\u002Fwww.u4.no\u002FU4natural-resources-short-online-courses\n\nUNODC's publications and resources: https:\u002F\u002Fwww.unodc.org\u002Funodc\u002Fen\u002Fenvironmentclimate\u002Fresources.html\n\nUNODC's global analysis on crimes that affect the environment: https:\u002F\u002Fwww.unodc. org\u002Funodc\u002Fen\u002Fdata-and-analysis\u002Fcrimes-that-affect-the-environment.html\n\nUNODC's teaching modules on wildlife crime: https:\u002F\u002Fsherloc.unodc.org\u002Fcld\u002Fen\u002F education\u002Ftertiary\u002Fwildlife-crime.html\n\nWWF and Themis's Environmental Crimes Financial Toolkit: https:\u002F\u002Fwww.wearethemis. com\u002Fuk\u002Fresources\u002Fenvironmental-crimes-financial-toolkit\n\n## Main publications since 2019 providing a global overview of corruption, money laundering and financial crimes linked to crimes that have an impact on the environment\n\nAmerhauser, Kristina and Robin Cartwright. 2023. Hidden in plain sight - counting the cost of environmental crime . Global Initiative against Transnational Organized Crime.\n\nBarber, Victor Charles, et al. 2025. People. Planet. Justice. Understanding and countering nature crime . World Resources Institute.\n\nByrd, Nicole, et al. Forthcoming. Money Talks: Ten Years of Firsthand Corruption Reporting from ELI Investigations . Earth League International.\n\nCarballo, Estefanía Ana, et al. 2025. Global transition, local transformations: Governance Challenges for the Energy Transition at the Sites of Extraction . Transparency International Australia.\n\nCutajar, Chantal, et al. 2025. Livre blanc sur la criminalité environnementale . Dalloz.\n\nde  Vibe  Maja,  and  Mark  Robinson.  2024. Good  governance  and  the  just  transition: Implications  for  renewable  energy  companies . Working  Paper  53.  Basel  Institute  on Governance.\n\nECOFEL. 2021. Financial investigations into wildlife crime . Egmont Group.\n\nEgmont  Group  of  Financial  Intelligence  Units.  2025. The  role  of  FIUs  in  fighting environmental crimes. Egmont Group of Financial Intelligence Units.\n\nEnvironmental Investigation Agency. 2021. Rotten to the Core: How to tackle the corrupt networks facilitating wildlife and forest crime . Environmental Investigation Agency.\n\nEnvironmental Investigation Agency. 2025. Tricks, Traders and Trees - How Illegal Logging Drives Forest Crime in the Brazilian Amazon and Feeds EU and U.S . Markets. Environmental Investigation Agency.\n\nEuropol. 2022. Environmental Crime in the Age of Climate Change .  Threat  assessment, Europol.\n\nFATF. 2020. Money Laundering and the Illegal Wildlife Trade . FATF.\n\nFATF. 2021. Money Laundering from Environmental Crimes . FATF.\n\nFitzgerald, Susannah, et al. 2025. Digging Into the Problem - How corruption facilitates socioenvironmental,  human  rights,  and  Indigenous  Peoples'  rights  harms  in  the  mining sector . Natural Resource Governance Institute.\n\nFitzgerald,  Susannah,  et  al.  2025. Preventing  Corruption  in  Africa's  Transition  Mineral Supply Chains . Natural Resource Governance Institute.\n\nGlantz, Elijahs, et al. 2025. Strengthening Financial Investigation of Wildlife Crime in Central Africa . RUSI.\n\nGonzalez, Sofia, et al. 2023. Dirty Money and the Destruction of the Amazon: Uncovering the U.S. Role in Illicit Financial Flows from Environmental Crimes in Peru and Colombia . FACT Coalition.\n\nHsu, Emily, et al. 2025. Dissecting the environmental - financial crime nexus: a spotlight on the illegal wildlife trade . WWF and Themis.\n\nKassa, Saba, et al. 2019. Corruption and wildlife trafficking: exploring drivers, facilitators and networks behind illegal wildlife trade in East Africa . Working Paper 30. Basel Institute on Governance.\n\nInstituto Igarapé. 2025. Strengthening Anti-Money Laundering Systems Against Environmental Crime: Comparative Legal and Policy Frameworks in Amazonian Countries . Instituto Igarapé.\n\nIsarin, Nancy, et al. 2023. Dirty deals - Case studies on corruption in waste management and trade . Working Paper 49. Basel Institute on Governance.\n\nMarks,  Dan  and  Jennifer  Scotland.  2025. Emerging  Insights  -  Scoping  Corruption  in Voluntary Carbon Markets . RUSI.\n\nNest,  Michael.  2024. Climate  and  Corruption  Atlas:  Lessons  from  Real-World  Cases . Transparency International.\n\nNest,  Michael  and  Saul  Mullard.  2025. Climate  governance  in  a  fast-changing  world: Evolving  patterns  of  corruption  risks . U4  Issue  2025:2.  U4  Anti-Corruption  Resource Centre.\n\nSayne, Aaron, et al. 2024. Ten Red Flags for Corruption Risk in Transition Minerals Licensing and Contracting . Natural Resource Governance Institute.\n\nStassart,  Joachim,  and  Flávia  M.  de  A.  Collaço.  2023. Addressing  land  corruption  for climate justice . Transparency International.\n\nStewart, Davyth, et al. 2023. Wildlife money trails - Building financial investigations from wildlife and timber trafficking cases in the European Union . TRAFFIC.\n\nTRAFFIC.  2020. Case  Digest:  Initial  Analysis  of  the  Financial  Flows  and  Payment Mechanisms behind Wildlife and Forest Crime . TRAFFIC.\n\nUNODC. 2019. Rotten  Fish:  A  Guide  on  Addressing  Corruption  in  the  Fisheries  Sector . United Nations Office on Drugs and Crime.\n\nUNODC. 2021 . Preventing and Combating Corruption as it Relates to Crimes that Have an Impact on the Environment: An Overview . United Nations Office on Drugs and Crime.\n\nUNODC. 2023. Scaling Back Corruption: A Guide on Addressing Corruption for Wildlife Management Authorities . United Nations Office on Drugs and Crime.\n\nUNODC.  2023. Rooting  out  corruption  -  An  introduction  to  addressing  the  corruption fuelling forest loss . United Nations Office on Drugs and Crime.\n\nUNODC. 2024. World Wildlife Crime Report . United Nations Office on Drugs and Crime.\n\nUNODC.  2025. Safeguarding  strategic  resources  in  Latin  America  and  the  Caribbean: countering organized crime, money laundering, and corruption in the mining sector . United Nations Office on Drugs and Crime.\n\nWildlife  Justice  Commission.  2022 . Role  of  corruption  in  illegal  trade .  Wildlife  Justice Corruption.\n\nWildlife Justice Commission. 2023. Dirty Money: The Role of Corruption in Enabling Wildlife Crime . Wildlife Justice Commission.\n\nWildlife  Justice  Commission.  2023. Convergence  of  wildlife  crime  with  other  forms  of organised crime: A 2023 review . Wildlife Justice Commission.\n\nWildlife Justice Commission. 2025. Is wildlife trafficking being treated as serious crime? A review of criminal offences, penalties, and implementation of the United Nations Convention against Transnational Organized Crime . Wildlife Justice Commission.\n\nWorld Bank. 2025. 2nd Symposium on Supranational Responses to Corruption: Integrity in Climate Finance and Action knowledge report . World Bank.\n\nYansura, Julia. 2024. Money Laundering from Environmental Crime: Typologies and Trends in Countries in the Amazon Region . FACT Coalition.\n\n## Annex 2 - Initiatives from the 2023 Seedlings of hope report\n\nBelow are two promising initiatives which were included in the Seedlings of hope report published in 2023.\n\n\u003C!-- image -->\n\nIndonesia: Combining anticorruption and anti-money laundering legislation for nature restoration\n\nPT Duta Palma, a major palm oil conglomerate in Indonesia, and its\n\nsubsidiaries have been under investigation for bribing public officials in Riau Province, illegal land clearing and conversion and land conflicts with local communities, among many allegations. In September 2023, Surya Darmadi, the CEO of PT Duta Palma, saw his initial conviction in February 2023 for corruption and money laundering upheld by the Supreme Court of Indonesia (Jong Hans Nicholas 2023).\n\nThe case has many distinctive features. The conviction is exemplary: Surya Darmadi was sentenced to 16 years in prison. The Attorney General's Office took an innovative approach. Instead of relying on environmental crime legislation, it based its case on the Indonesian anticorruption law that includes a special provision on unlawful enrichment that has an impact on finance and economic state loss. The Supreme Court followed the Attorney General's approach, using the provisions related to economic loss for the State and the removal of the illegal gains for its verdict.\n\nWhile the imposed fine of IDR 2.23 trillion (equivalent to USD 144 million) represents a significant reduction from the initial conviction in February 2023, 64 the case underscores the possibility of assessing economic and social losses resulting from corrupt practices linked to crimes that have an impact on the environment.\n\nWith several corruption cases currently under prosecution that have similar characteristics, one can only hope that the ensuing fines will reflect the gravity of the offences, ensuring that effective restoration actions are taken and sending a clear message that crime does not pay.\n\n\u003C!-- image -->\n\n## Thailand: Using anti-money laundering legislation to confiscate illicit acquired assets\n\nIn Thailand, after a first criminal investigation into the operations of Boonchai Bach, a Vietnamese and Thai citizen suspected of wildlife trafficking, the AntiMoney Laundering Office opened a new case in 2019. It collaborated with the NGO Freeland Foundation to map the entire criminal network. Using the Anti-Money Laundering Act, the Anti-Money Laundering Office seized and froze more than THB 300 million (USD 11 million) worth of assets\n\n(including hotels, land, vehicles and bank accounts) of Boonchai Bach for laundering profits of wildlife trafficking (Freeland 2021).\n\nThe case was a success thanks in part to the collaboration with the Freeland Foundation and government agencies from Australia, Malaysia, South Africa, Thailand and the US (Cabrejo le Roux and Romero 2023). Thailand, Vietnam and Malaysia are examining how they can work together to make it a multi-country case to seize his assets in every jurisdiction (Nuwer 2023).\n\n## References:\n\nCabrejo le Roux, Amanda and Isabella Romero. 2023. 'Following-the-money' in environmental crime cases: Lessons from experience. TNRC . September 2023. https:\u002F\u002F www.worldwildlife.org\u002Fpages\u002Ftnrc-blog-following-the-money-in-environmental-crimecases-lessons-from-experience\n\nFreeland. 2021. Thailand says $11m seized in wildlife trafficking sting. Freeland . 17 March 2021. https:\u002F\u002Fwww.freeland.org\u002Fnewsroom\u002Fthailand-says-11m-seized-in-wildlifetrafficking-sting\n\nJong, Hans Nicholas. 2023. Experts slam massive 'discount' in fines for Indonesian palm oil billionaire. Mongabay . 27 September 2023. https:\u002F\u002Fnews.mongabay.com\u002F2023\u002F09\u002F experts-slam-massive-discount-in-fines-for-indonesian-palm-oil-billionaire\u002F\n\nLlewellyn, Aisyah. 2023. Indonesia's palm oil tycoon Darmadi gets 15 years for corruption. Al Jazeera . 24 February 2023. https:\u002F\u002Fwww.aljazeera.com\u002F economy\u002F2023\u002F2\u002F24\u002Findonesias-palm-oil-tycoon-darmadi-gets-15-years-for-corruption\n\nNuwer, Rachel. 2023. Thai poaching kingpin is on the run after prison sentence. National Geographic . 15 February 2023. https:\u002F\u002Fwww.nationalgeographic.com\u002Fanimals\u002Farticle\u002F manhunt-thai-poaching-kingpin-southeast-asia-traffickingivory\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->","Adopted in 2019, UNCAC Resolution 8\u002F12 – *Preventing and combating corruption as\nit relates to crimes that have an impact on the environment* – urges States Parties to\nprevent, investigate and prosecute corruption offences where they may be linked to\ncrimes that have an impact on the environment.\n\nIn 2023, the Basel Institute on Governance published its Working Paper 50,\n*Seedlings of hope*, providing a panorama of emerging and promising initiatives\nacross the world since the adoption of Resolution 8\u002F12. The purpose of the updated\nreport Saplings of hope is to highlight what progress has been achieved since then.\n\n### Corruption prevention measures\n\nStates have implemented a host of initiatives to strengthen integrity systems.\nMost commonly, this included the revision and adoption of internal control policies, more dedicated risk management efforts, including through the establishment\nof corruption prevention committees, and a range of capacity building efforts to\nstrengthen environmental agencies’ ability to mitigate their own corruption risks,\nsuch as workshops on ethics codes and other integrity measures. Whistleblower\nprotection programmes were increasingly designed, implemented and promoted.\nCorruption risk assessments were conducted in sectors such as wildlife management, forestry and fisheries.\n\nPromising corruption prevention interventions include:\n\n- 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.\n- 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.\n- 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.\n- Launching awareness-raising campaigns to promote knowledge of anti-corruption measures. This is an important first step to their effective implementation.\n- 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.\n- 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.\n\n### Enforcement actions\n\nSeveral countries have investigated and prosecuted corruption cases linked to\ncrimes that have an impact on the environment. Financial investigations and\nmoney laundering legislation are more frequently used to tackle these crimes.\nThe systematic seizure and confiscation of assets is still just beginning, as is\nthe creation of multi-agency and interdisciplinary task forces, nationally and\ninternationally. However, enforcement actions on corruption as it relates to crimes\nthat have an impact on the environment are still limited.\n\nPromising enforcement interventions include:\n\n- 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.\n- 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.\n- 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.\n\n### Essential role of civil society and the media\n\nAlongside States, civil society organisations and the media have played an essential\nrole in increasing our understanding of the relationship between corruption and\ncrimes that have an impact on the environment.\n\nTheir efforts span investigative reporting, publishing evidence-based research,\ncapacity building, creating networks to bridge the gap between anti-corruption\nand environmental practitioners, as well as initiating strategic litigation cases. Their\ninvolvement is all the more commendable given that they are facing an increasingly\nrepressive environment.\n\n### The way forward\n\nAs this Working Paper highlights, various activities are taking place to tackle\ncorruption linked to crimes that have an impact on the environment. The paper\npicks out those that show significant promise. The diversity of engagements is\nlaudable, but it is far from the scale needed to make a systemic difference to both\nsocietal corruption and environmental challenges. States Parties need to adapt and\nscale up initiatives that are effective or look promising, by, among other things:\n\n- Ensuring more robust staffing and prioritisation of corruption prevention systems in government and state-owned enterprises tasked with conserving, managing or trading natural resources.\n- Developing specialised knowledge and expertise of governmental institutions and agencies to better address corruption that impacts the environment.\n- Incorporating anti-corruption measures into environmental and natural resource policies and strengthening environmental governance structures to include anti-corruption internal controls and mechanisms.\n- Dedicating greater resources for specialised law enforcement to pursue complex financial flows linked to corruption and crimes that have an impact on the environment.\n- Increasing inter-agency collaboration and conducting joint operations on corruption that has an impact on the environment.\n- 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.\n- 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.\n- Sharing knowledge, case law, success stories, etc.\n- Ensuring that this issue is integrated in all relevant United Nations processes such as the ones related to climate and biodiversity.\n- Protecting and defending civil society space, press freedom and human rights defenders working on the environment and corruption-related\nissues.\n\nAs these initiatives have now been conducted for six years, there is a sufficient\nbody to scrutinise their effectiveness and efficiency. It is therefore **essential to\nrigorously assess these measures**, especially in an environment of increasingly\nscarce financial resources.\n\n### Addressing corruption that has an impact on the environment\n\nThe Working Paper also makes a case for moving from the concept of “corruption\nas it relates to crimes that have an impact on the environment” to “**corruption that\nhas an impact on the environment**”.\n\nFocusing solely on corruption linked to crimes that have an impact on the\nenvironment overlooks situations where corruption causes environmental harm\nwithout an associated criminal offence. It does not take into consideration pressing\nissues such as corruption linked to climate finance, renewable energy and the\nexploitation of critical minerals.\n\nAdopting a holistic approach is crucial to address all forms of corruption that affect\nthe environment, and thus to protect the environment and people.",{"id":655,"storage":35,"filename_disk":656,"filename_download":657,"title":658,"type":494,"created_on":634,"modified_on":634,"charset":31,"filesize":659,"width":496,"height":660,"duration":31,"embed":31,"description":31,"location":31,"tags":31,"metadata":661,"focal_point_x":31,"focal_point_y":31,"tus_id":31,"tus_data":31,"uploaded_on":634},"85b2c8ec-9f32-46b0-81ec-ea6143ac15b2","85b2c8ec-9f32-46b0-81ec-ea6143ac15b2.jpg?itok=yTD7UR-g","WP61-Saplings-of-hope-cover.jpg?itok=yTD7UR-g","Cover page of Working Paper 61 Saplings of 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View Executive Summary",[796,809],{"id":684,"publications_id":797,"authors_id":808},{"id":633,"status":15,"sort":31,"user_created":48,"date_created":634,"user_updated":186,"date_updated":635,"nid":636,"slug":637,"image":655,"title":638,"body":639,"citation":640,"language":32,"year":641,"publisher":642,"date_published":21,"external":474,"topic":798,"link_internal":799,"link_external":801,"featured":474,"topics":802,"languages":31,"type":803,"area":31,"programme":31,"websites":31,"summary":31,"pdf_text":652,"main_points":31,"short_version":653,"subtitle":31,"countries":804,"tags":805,"pdf":806,"authors":807},[23],[800],{"url":646,"caption":647},[],[23],[651],[],[665,675,676,677,678],[680,681,682],[684,685],{"id":140,"name":141,"position":31,"image":31},{"id":685,"publications_id":810,"authors_id":821},{"id":633,"status":15,"sort":31,"user_created":48,"date_created":634,"user_updated":186,"date_updated":635,"nid":636,"slug":637,"image":655,"title":638,"body":639,"citation":640,"language":32,"year":641,"publisher":642,"date_published":21,"external":474,"topic":811,"link_internal":812,"link_external":814,"featured":474,"topics":815,"languages":31,"type":816,"area":31,"programme":31,"websites":31,"summary":31,"pdf_text":652,"main_points":31,"short_version":653,"subtitle":31,"countries":817,"tags":818,"pdf":819,"authors":820},[23],[813],{"url":646,"caption":647},[],[23],[651],[],[665,675,676,677,678],[680,681,682],[684,685],{"id":822,"name":156,"position":31,"image":31},579,{"id":824,"status":15,"sort":31,"date_created":825,"date_updated":826,"nid":827,"slug":828,"title":829,"body":830,"citation":470,"language":831,"year":832,"publisher":642,"date_published":833,"external":474,"topic":834,"link_internal":836,"link_external":840,"featured":474,"topics":841,"languages":842,"type":844,"area":31,"programme":31,"websites":31,"summary":31,"pdf_text":31,"main_points":31,"short_version":31,"subtitle":31,"image":846,"countries":854,"tags":934,"pdf":963,"authors":1001},2241,"2022-11-15T17:04:01.000Z","2026-06-02T14:09:02.000Z",2309,"pb11","Policy Brief 11: Fighting corruption in West African coastal states: how Collective Action can help","Africa is estimated to lose an unbelievable USD 88.6 billion (3.7% of Africa’s GDP) each year to illicit financial flows, of which corruption is a major component. Rooting out corruption is a collective effort, and the private sector has a major role to play in laying down the foundations for clean business environments and sustainable development.\n\nThat is why anti-corruption Collective Action  has got so much to offer Africa, and in particular West African coastal states keen to maximise their clear economic potential. As the spectrum of Collective Action initiatives is quite large, it allows for innovative measures where governments, companies and civil society organisations (CSOs) can join forces toward a common objective, despite their different perspectives. This collaborative approach therefore provides a fertile ground for constructive dialogue between like-minded stakeholders, as well as an opportunity to understand the private sector’s language and reality. \n\nCSOs have an important part to play in bringing Collective Action to the fight against corruption in West Africa. They must continue to initiate, facilitate and engage in Collective Action initiatives to help raise awareness and build bridges. Their presence can bring credibility, independent oversight and accountability to the initiatives.\n\nThis Policy Brief is based on conversations held with CSOs based in Benin (Social Watch Benin), Ghana (Ghana Integrity Initiative), Ivory Coast (Ivorian Youth Leaders’ Network) and Togo (The Togolese National Agency for Consumers and the Environment). It aims to capture their experiences, challenges and outlook on what the future for Collective Action could hold in the region.\n\nDespite their different backgrounds, they are united on one point: fighting corruption collectively by raising the voice of the private sector is an important step to pave the way for sustainable economic growth.\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 supports the Basel Institute's work on anti-corruption \u003Ca href=\"https:\u002F\u002Fcollective-action.com\u002F\">Collective Action\u003C\u002Fa> with funding from the Siemens Integrity Initiative.\n\nIt is licensed 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: Young, Liza. 2022. “Fighting corruption in West African coastal states: how Collective Action can help.” Policy Brief 11, Basel Institute on Governance. Available at: \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpb-11\">baselgovernance.org\u002Fpb-11\u003C\u002Fa>.","English, French",2022,"2022-11-15",[169,835],"Collective Action",[837],{"url":838,"caption":839},"\u002Fresources\u002Fpublications?type=Policy%20Brief"," View all Policy Briefs",[],[174,835],[32,843],"French",[845],"Policy Brief",{"id":847,"storage":35,"filename_disk":848,"filename_download":849,"title":850,"type":494,"created_on":825,"modified_on":825,"charset":31,"filesize":851,"width":496,"height":852,"duration":31,"embed":31,"description":31,"location":31,"tags":31,"metadata":853,"focal_point_x":31,"focal_point_y":31,"tus_id":31,"tus_data":31,"uploaded_on":825},"6abf2611-ae87-40fa-a2fa-710aecc515b5","6abf2611-ae87-40fa-a2fa-710aecc515b5.jpg?itok=4BNLWqvh","Pages-from-Policy-Brief-11-final.jpg?itok=4BNLWqvh","Policy Brief 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Social accountability, on its part, aims to empower citizens with information and provide effective channels through which to exercise agency. \n\nAuthored by Claudia Baez Camargo, Head of Governance Research, this publication guides practitioners towards localising anti-corruption interventions that invite citizen participation in order to make them more effective.",2018,"U4 Anti-Corruption Research Centre","2018-01-01",[1031],"Public Governance",[],[1034],{"url":1035,"caption":1036},"https:\u002F\u002Fwww.u4.no\u002Fpublications\u002Fharnessing-the-power-of-communities-against-corruption"," View on U4 website",[1038],"Corruption Prevention and Public 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It is meant to be used in conjunction with the \u003Ca href=\"\u002Fnode\u002F667\">handbook on social accountability\u003C\u002Fa> methods, developed by the Basel Institute in support of the same project.\n\nThe material here contained provides implementers and interested parties with a practical guide to the elements and steps necessary in order to develop a citizen monitoring program. The handbook has been tailored based on the experiences of trusted colleagues who are seasoned implementers in the area of citizen monitoring initiatives as well as drawing from resources on the topic that have been made publicly available by some of the world’s most reputed development agencies.\n\nIn addition, for purposes of illustrating the operationalization of some key concepts throughout the handbook, reference is made to the participatory monitoring experiences of G-Watch in Philippines, specifically regarding the implementation of an agricultural subsidies monitoring program in San Miguel, Bohol. \n\nIt was translated into Armenian and published by the \u003Ca href=\"https:\u002F\u002Ftransparency.am\u002Fen\u002Fpublications\u002Fview\u002F125\">Transparency International Anticorruption Center\u003C\u002Fa>.","Baez Camargo, C., Stahl, F. (2016). 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