[{"data":1,"prerenderedAt":1311},["ShallowReactive",2],{"tag-818":3,"tag-publications-818-1":6,"tag-events-818-1":850,"tag-news-818-1":900,"tag-stories-818-1":1308},{"id":4,"name":5},818,"Anti-money laundering",{"items":7,"total":849},[8,242,366,613,737],{"id":9,"status":10,"sort":11,"date_created":12,"date_updated":13,"nid":14,"slug":15,"title":16,"body":17,"citation":18,"language":11,"year":19,"publisher":20,"date_published":21,"external":22,"topic":11,"link_internal":23,"link_external":30,"featured":22,"topics":37,"languages":39,"type":41,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":43,"short_version":11,"subtitle":44,"image":45,"countries":57,"tags":90,"pdf":179,"authors":204},2441,"published",null,"2026-06-01T22:10:26.000Z","2026-06-02T14:22:13.000Z",2937,"cs-13","Case Study 13: The Beauty Queen case: non-conviction based forfeiture across borders","This Case Study analyses how Colombian authorities recovered assets linked to drug trafficking and held in a trust in Guernsey. It sets out the legal tools and procedures in Colombia and in Guernsey that enabled Colombia’s first international recovery under its non-conviction based forfeiture model _Extinción de dominio_. The Case Study highlights lessons for international cooperation between jurisdictions with different forfeiture systems or even legal traditions.\n\nThe International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance provided technical assistance as part of a Memorandum of Understanding with the General Prosecutor’s Office of Colombia.\n\n[**Download Case Study here**](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-05\u002FCase-Study-13_Beauty-Queen.pdf)\n\nOn 30 November 2023, the Fourth Court of the Specialised Extinción de Dominio Circuit of Colombia ordered the non-conviction based forfeiture of a Guernsey trust account issued by Northern Trust Fiduciary Services (Guernsey) Limited. The beneficiary was María Marcela Serrano Camacho, a Colombian model and former beauty queen.\n\nThe Colombian forfeiture order extinguished property rights over the account – amounting to GBP 361,146 – on the grounds that the funds were the proceeds of drug trafficking offences committed by Efraín Antonio Hernández Ramírez (“Don Efra”), a well-known Colombian drug trafficker, and his former spouse María Serrano in the 1990s.\n\nOn 30 January 2025, following successful mutual legal assistance proceedings between Colombia and the Bailiwick of Guernsey, the two jurisdictions concluded an asset sharing agreement for the repatriation of the confiscated assets.\n\nThis marked Colombia’s first successful international recovery through non-conviction based forfeiture.\n\nThis Case Study examines how early and effective coordination between Colombia and Guernsey enabled the identification, freezing, forfeiture and repatriation of the assets. It analyses the legal framework underpinning Colombia's Extinción de dominio regime and how it was applied, leading to the forfeiture of the Guernsey acccount. It also describes the procedural mechanisms used in Guernsey to execute foreign non-conviction based forfeiture orders.\n\nThe interaction between the authorities in both jurisdictions offers valuable lessons and examples of good practices.\n\n**Main takeaways of the case:**\n\n- Early and trust-based international cooperation is decisive\n- Non-conviction based forfeiture is indispensable when criminal routes are closed\n- Identifying beneficial ownership is central to effective asset recovery\n- Direct enforcement of foreign forfeiture orders increases efficiency and legal certainty\n- Asset sharing agreements strengthen cooperation incentives\n\nThe Case Study can be read alongside [Policy Brief 16](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-16): \"Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres\".\n\n### About this Case Study\n\nThis publication is part of the Basel Institute on Governance Case Study series, [ISSN 2813-3900](https:\u002F\u002Fbaselgovernance.org\u002Fcase-studies). It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License ([CC BYNC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F)).\n\nThe Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery.\n\nThis is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.\n\n**Disclaimer**: This Case Study is intended for general informational purposes and does not constitute and\u002For substitute legal or other professional advice. The contents are the sole responsibility of the authors and do not necessarily reflect the views or the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n","Solórzano, Oscar, and Diana Cordero. 2026. ‘The Beauty Queen case: non-conviction based forfeiture of criminal assets across borders. Lessons learned from Colombia–Guernsey cooperation.’ Case Study 13, Basel Institute on Governance. Available at: [baselgovernance.org\u002Fpublications\u002Fcs-13](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-13).",2026,"Basel Institute on Governance","2026-03-31",false,[24,27],{"url":25,"caption":26},"\u002Fresources\u002Fnews\u002Fcolombiaguernsey-cooperation-leads-to-successful-non-conviction-based-forfeiture-of-illicit-assets-2716","Read related blog",{"url":28,"caption":29},"\u002Fresources\u002Fpublications","Read related Policy Brief 16",[31,34],{"url":32,"caption":33},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=368","View online on Basel LEARN",{"url":35,"caption":36},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=72","eLearning course: International Cooperation and Mutual Legal Assistance in Criminal Matters",[38],"Asset Recovery and Enforcement",[40],"English",[42],"Case Study","- Early and trust-based international cooperation is decisive\n- Non-conviction based forfeiture is indispensable when 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Solorzano","bb78436c-969e-40ca-9f3e-5e37ec0a95f9",{"id":83,"publications_id":225,"authors_id":239},{"id":9,"status":10,"sort":11,"user_created":61,"date_created":12,"user_updated":62,"date_updated":13,"nid":14,"slug":15,"image":46,"title":16,"body":17,"citation":18,"language":11,"year":19,"publisher":20,"date_published":21,"external":22,"topic":11,"link_internal":226,"link_external":229,"featured":22,"topics":232,"languages":233,"type":234,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":43,"short_version":11,"subtitle":44,"countries":235,"tags":236,"pdf":237,"authors":238},[227,228],{"url":25,"caption":26},{"url":28,"caption":29},[230,231],{"url":32,"caption":33},{"url":35,"caption":36},[38],[40],[42],[59],[74,75,76,77,78],[80],[82,83],{"id":240,"name":241,"position":11,"image":11},591,"Diana Cordero",{"id":243,"status":10,"sort":11,"date_created":12,"date_updated":244,"nid":245,"slug":246,"title":247,"body":248,"citation":11,"language":11,"year":19,"publisher":20,"date_published":21,"external":22,"topic":11,"link_internal":249,"link_external":252,"featured":22,"topics":254,"languages":255,"type":256,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":11,"short_version":11,"subtitle":258,"image":259,"countries":267,"tags":268,"pdf":331,"authors":351},2442,"2026-06-02T14:16:22.000Z",2947,"pb-16","Policy Brief 16: Enforcing foreign non-conviction based forfeiture orders","This Policy Brief analyses emerging international standards aimed at addressing recurring challenges in judicial practice with regard to the enforcement of non-conviction based forfeiture orders issued by foreign states. It focuses in particular on the historical absence of a binding obligation on requested states to cooperate in such cases and, where cooperation is available, on the structural tension between direct and indirect enforcement models.\n\n[**Download Policy Brief here**](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-03\u002FPolicy-Brief-16_Enforcing-foreign-NCBF-orders.pdf)\n\nRevisions in 2023 to the Financial Action Task Force (FATF) Recommendations 4 and 38 seek to clarify and strengthen states’ cooperation in the enforcement of foreign forfeiture orders. In this context, the recognition and execution of foreign non-conviction based forfeiture orders are central components of the evolving international asset recovery framework.\n\nThrough analysis and case studies involving Latin American states and international financial centres, this Policy Brief demonstrates that the choice of procedural model for enforcing foreign forfeiture orders – direct or indirect – has significant implications, while acknowledging the competing legal and institutional interests involved.\n\nIn line with FATF Recommendation 38, the Policy Brief argues in favour of direct enforcement in the requested state, based on the facts established by the foreign authority. This promotes efficiency, legal certainty and mutual trust. Indirect enforcement models that may require domestic investigations by the requested state, on the other hand, often lead to delays, duplication and increased costs, which hinders international asset recovery efforts.\n\nThe analysis provides empirical insight into how the revised FATF standards address practical deficiencies and the implications for judicial practice in requested states. For the Latin American context, the Policy Brief suggests to go beyond technical compliance of domestic non-conviction based forfeiture regimes with the FATF standards to strengthen the effectiveness of cross-border enforcement in practice.\n\nThis Policy Brief can be read alongside [Case Study 13](http:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-13): “The Beauty Queen case: non-conviction based forfeiture across borders. Lessons learned from Colombia–Guernsey cooperation.”\n\n### About this Policy Brief\n\nThis publication is part of the Basel Institute on Governance Policy Brief series [ISSN 2624-9669](https:\u002F\u002Fbaselgovernance.org\u002Fpublications?type\\[]=257). You may freely share or republish it under a Creative Commons [BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F) licence.\n\nIt is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.\n\n**Disclaimer**: This Policy Brief is intended for general informational purposes and does not constitute and\u002For substitute legal or other professional advice. The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n\n**Suggested citation**: Solórzano, Oscar. 2026. \"Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres.\" Policy Brief 16, Basel Institute on Governance. Available at: [baselgovernance.org\u002Fpublications\u002Fpb-16](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-16).",[250],{"url":28,"caption":251},"Read related Case Study 13",[253],{"url":35,"caption":36},[38],[40],[257],"Policy Brief","FATF standards and asset recovery practice in Latin America and financial centres",{"id":260,"storage":47,"filename_disk":261,"filename_download":262,"title":263,"type":51,"created_on":264,"modified_on":264,"charset":11,"filesize":265,"width":54,"height":55,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":266,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":264},"f866220c-dddd-41b3-a45e-c2d7992d39e1","f866220c-dddd-41b3-a45e-c2d7992d39e1.jpg","Policy-Brief-16_Enforcing-foreign-NCBF-orders_Cover.jpg","Policy Brief 16_Enforcing foreign non-conviction based confiscation 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conflicts of interest and corruption in Indonesia’s energy transition","This U4 Issue analyses Indonesia's ambitious energy transition and highlights how political finance, weak regulations and a \"revolving door\" of personnel between public office and the private sector create vulnerabilities. The publication was produced by U4 and the Basel Institute on Governance through its Green Corruption programme.\n\n\u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2026-02\u002FAddressing-conflicts-of-interest-and-corruption-in-indonesia-s-energy-transition_U4-Issue.pdf\">Download publication here\u003C\u002Fa>.\n\n### About the paper\n\nConflicts of interest and corruption in Indonesia's political economy pose significant risks to its energy transition, including the Just Energy Transition Partnership. Existing legal and institutional frameworks are fragmented, inconsistently applied, and often fail to address the risk of state capture by powerful political and economic actors, especially in the extractive and energy sectors.\n\nThe reliance on fossil fuel industries for political financing and the monopolistic nature of state-owned entities further complicate the shift to a low- or no-carbon system, despite the country's ambitious renewable energy targets.\n\nPotential pathways to greater anti-corruption resilience lie in improvements to beneficial ownership transparency and strengthening regulation, monitoring and sanctioning of conflict of interest violations.\n","","U4 Anti-Corruption Resource Centre","2026-02-24",[378],"Green Corruption",[],[381,384],{"url":382,"caption":383},"https:\u002F\u002Fwww.u4.no\u002Fpublications\u002Faddressing-conflicts-of-interest-and-corruption-in-indonesia-s-energy-transition"," View on U4 website",{"url":385,"caption":386},"https:\u002F\u002Fwww.u4.no\u002Fblog\u002Fimproving-anti-corruption-resilience-in-indonesia-s-energy-transition"," Read related U4 blog",[378],[389],"Report","- Corruption and conflicts of interest are embedded in the energy transition process due to the strong links between political power, private wealth (especially from extractive industries) and public office holders.\n- Existing anti-corruption regulations are often vague, fragmented across different legal instruments, and suffer from inconsistent enforcement, which creates loopholes susceptible to manipulation.\n- Progress in renewable energy uptake is slowed by the enduring influence and interests of fossil fuel incumbents who benefit from subsidies that keep coal an artificially cheap and viable energy source.\n- The Just Energy Transition Partnership is vulnerable to misallocations due to concentrated decision-making power, limited transparency in project selection and insufficient involvement of national anti-corruption bodies and civil society in its planning.\n- Improving transparency of beneficial ownership and strengthening the monitoring and sanctioning of conflict of interest violations are possible pathways to build greater anti-corruption resilience, though these institutional efforts alone are insufficient to fully address state capture dynamics.",{"id":392,"storage":47,"filename_disk":393,"filename_download":394,"title":395,"type":51,"created_on":368,"modified_on":368,"charset":11,"filesize":396,"width":397,"height":398,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":399,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":368},"d97f2ca5-300d-45c9-9de9-33152b72f96c","d97f2ca5-300d-45c9-9de9-33152b72f96c.jpg?itok=yzE-1mVj","Addressing-CoI-and-corruption-in-indonesias-energy-transition-U4-Issue-cover.jpg?itok=yzE-1mVj","U4 Issue cover: Addressing conflicts of interest and corruption in Indonesia's energy 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Williams",{"id":425,"publications_id":582,"authors_id":594},{"id":367,"status":10,"sort":11,"user_created":404,"date_created":368,"user_updated":61,"date_updated":369,"nid":370,"slug":371,"image":392,"title":372,"body":373,"citation":374,"language":40,"year":19,"publisher":375,"date_published":376,"external":22,"topic":583,"link_internal":584,"link_external":585,"featured":22,"topics":588,"languages":11,"type":589,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":390,"short_version":11,"subtitle":11,"countries":590,"tags":591,"pdf":592,"authors":593},[378],[],[586,587],{"url":382,"caption":383},{"url":385,"caption":386},[378],[389],[402],[414,415,416,417,418,419],[421],[423,424,425,426],{"id":595,"name":596,"position":11,"image":11},523,"Lakso Anindito",{"id":426,"publications_id":598,"authors_id":610},{"id":367,"status":10,"sort":11,"user_created":404,"date_created":368,"user_updated":61,"date_updated":369,"nid":370,"slug":371,"image":392,"title":372,"body":373,"citation":374,"language":40,"year":19,"publisher":375,"date_published":376,"external":22,"topic":599,"link_internal":600,"link_external":601,"featured":22,"topics":604,"languages":11,"type":605,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":390,"short_version":11,"subtitle":11,"countries":606,"tags":607,"pdf":608,"authors":609},[378],[],[602,603],{"url":382,"caption":383},{"url":385,"caption":386},[378],[389],[402],[414,415,416,417,418,419],[421],[423,424,425,426],{"id":611,"name":612,"position":11,"image":11},579,"Dr Amanda Cabrejo le Roux",{"id":614,"status":10,"sort":11,"date_created":615,"date_updated":616,"nid":617,"slug":618,"title":619,"body":620,"citation":621,"language":40,"year":622,"publisher":20,"date_published":623,"external":22,"topic":624,"link_internal":625,"link_external":629,"featured":22,"topics":630,"languages":11,"type":631,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":632,"main_points":633,"short_version":11,"subtitle":11,"image":634,"countries":641,"tags":661,"pdf":705,"authors":723},2428,"2025-11-25T17:05:34.000Z","2026-06-02T14:08:56.000Z",2874,"cs-12","Case Study 12: Indonesia: a landmark money laundering conviction in a forestry crime case","This Case Study highlights how investigators of Indonesia’s Ministry of Environment and Forestry achieved their first conviction for money laundering linked to forestry offences, leveraging institutional and legal changes in financial investigation procedures.\n\n### About this Case Study\n\nThis publication is part of the Basel Institute on Governance Case Study series, \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fcase-studies\">ISSN 2813-3900\u003C\u002Fa>. It is licensed for sharing 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>).\n\nThe development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.\n\nThe contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.","Anindito, Lakso. 2025. “Indonesia: a landmark money laundering conviction in a forestry crime case.” Case Study 12, Basel Institute on Governance. Available at: \u003Ca href=\"https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-12\">baselgovernance.org\u002Fpublications\u002Fcs-12\u003C\u002Fa>.",2025,"2025-11-25",[378],[626],{"url":627,"caption":628},"\u002Fresources\u002Fpublications?type=Case%20Study"," View all Case Studies",[],[378],[42],"\u003C!-- image -->\n\n## Case Study 12\n\n## November 2025\n\n## Indonesia: a landmark money laundering conviction in a forestry crime case\n\nHow investigators of Indonesia's Ministry of Environment and Forestry achieved their first conviction for money laundering linked to forestry offences, leveraging institutional and legal changes in financial investigation procedures.\n\nLakso Anindito , Team Leader Indonesia, Green Corruption programme, Basel Institute on Governance\n\n\u003C!-- image -->\n\n## Key points\n\n- → In a case of illegal logging in Alas Purwo National Park, investigators of Indonesia's Ministry of Environment and Forestry 1  obtained their first money laundering conviction.\n- → This achievement was made possible through a 2021 Constitutional Court decision extending the power to pursue  money laundering offences  to  investigators in  charge of predicate offences, in this case timber trafficking.  This  power  was  previously  limited  to investigators of traditional law enforcement agencies, including the police and the Corruption Eradication Commission.\n- → Training  and  technical  assistance  by  the  Green Corruption  programme  of  the  Basel  Institute  on Governance contributed to strengthening law\n\n- enforcement capacities to effectively handle money laundering cases and track illicit financial flows tied to environmental crimes.\n- → Sustained coordination and collaboration among the Ministry, Indonesia's Financial Intelligence Unit and the Attorney General's Office were pivotal in applying the follow-the-money approach to the illegal logging case.\n- → Businessman  Supono  was  convicted  initially  of illegally trading rosewood and later of laundering approximately USD 127,000 he had obtained through log  trading.  In  both  cases,  he  was  sentenced  to prison and ordered to pay a fine.\n- → Although the amount of money laundered in this case and the imposed fines were relatively modest, the case set a precedent for integrating financial crime investigations into environmental enforcement. This paves the way for future, larger-scale prosecutions by investigators of environmental agencies.\n\n## The case\n\n- 1. In 2021, investigators at the Ministry of Environment and Forestry started investigating indications of illegal logging in Alas Purwo National Park in Banyuwangi, East Java. National Park staff had caught a transporter carrying illegally logged rosewood (sonokeling) .\n- 2 . The  investigation  began  with  an  effort  to  identify who  was  benefiting  from  the  illegal  activities.  A businessman named Supono was later identified as the beneficiary. He was the person who orchestrated the transport of the rosewood logs.\n- 3. In 2022, the Banyuwangi District Court convicted Supono of intentionally transporting and owning forest products (logs of 31 rosewood trees sourced from Alas Purwo National Park) without permit. 2 The Court sentenced Supono to two years in prison and a fine of IDR 500 million (approx. USD 29,900). This first case was pursued purely on the basis of forestry crime charges.\n- 4. The Ministry's investigators continued to pursue the case using a follow-the-money approach to trace the proceeds of the crime. They applied this approach in close collaboration with the Financial Intelligent Unit (PPATK), which contributed key information, and in coordination with the Attorney General's Office. The financial investigation revealed:\n- a. Supono carried out suspicious financial transactions with two sawmill companies, PT Aji Sono and PT Amruu. His later statement during the court  proceedings  disclosed  that  the  logs  he was  trading  with  these  two  companies  were sourced not only from Alas Purwo National Park, but also from other locations, including Lampung, Sulawesi and Sumbawa.\n- b. Between 2020 and 2022, Supono gained approximately USD 127,000 from trading logs with PT Aji Sono (IDR 1,454,440,000) and PT Amruu (IDR 670,980,800).\n\n- c. To conceal the origins of the illegal proceeds, the  two  companies  transferred  the  money for their log purchases to the bank account of Supono's son, which was effectively controlled by Supono himself.\n- d. Supono then moved the money from his son's bank  account  to  his  own  account  in  smaller transactions, both via direct transfer and via cash withdrawal and manual deposits.\n- e. Supono integrated the proceeds of crime with money  he  had  loaned  from  the  bank  in  2020 (when he had no specific need for a bank loan). He then used the illicit funds to pay back the loan. He used this 'loan-back' method to disguise the proceeds of crime as legitimate money from the bank and other unrelated business activities.\n- f. Among other things, Supono used the money from the logging business to buy land.\n- 5. In 2024,  the  Banyuwangi  District  Court  issued its decision No. 11\u002FPid.Sus\u002F2024\u002FPN Byw 3  declaring Supono  guilty  of  money  laundering.  The  Court sentenced  Supono  to  one  year  and  three  months in  prison  and  a  fine  of  IDR  50  million  (approx. USD 3,000). The proceeds of the crime as such were not recovered.\n\nThe illegal logging and money laundering scheme uncovered by investigators of Indonesia's Ministry of Environment and Forestry.\n\n\u003C!-- image -->\n\n## Legal background\n\n- · In  2010,  Indonesia  enacted  the  new  AntiMoney Laundering Law No. 8\u002F2010. 4 It provides  a legal  framework  for  tracing  and prosecuting illicit financial flows, including those  linked  to  environmental  crimes .  This marked a major step towards integrating  financial investigation tools into law enforcement efforts against  money  laundering.  However,  initially, only investigators of traditional law enforcement authorities  were  authorised  to  use  this  law, including from police, the Attorney General's Office, the Corruption Eradication Commission, the National Narcotics Agency, the tax authority and customs.\n- · A  landmark  decision  came  in  2021  when the  Constitutional  Court  issued  its  Decision\n\nNo. 15\u002FPUU-XIX\u002F2021. 5 This authorised investigators in charge of predicate offences, including from natural resources and environmental  authorities,  to  investigate not only environmental  crimes  such  as timber trafficking but also the related money laundering offences .\n\n- · The  Ministry  of  Environment  and  Forestry initiated  several strategic  actions  to  utilise its expanded powers . For example, it reached an  agreement  with  the  Indonesian  Financial Intelligence Unit to develop a joint investigation team. The Ministry also set its investigators the target of handling environmental cases using a  follow-the-money  approach,  and  started collaborating with the Attorney General's Office.\n\n## What can we learn from this case?\n\n## Laws and their interpretation are important….\n\nThe Constitutional Court's 2021 Decision is an important example of how a legal framework can be interpreted to  maximise its effectiveness in practice. In this case, the decision granted investigators from environmental agencies - in addition to investigators from traditional law enforcement agencies - the legal authority to pursue money laundering offences linked to environmental crimes.\n\nIt  empowered investigators to expand their scope and approach, laying the groundwork for more comprehensive enforcement in the future.\n\n## … but using laws in practice requires training and 'learning by doing'\n\nDespite their new powers, the investigators still faced difficulties in tracing illicit financial flows and understanding complex financial transactions linked to environmental crimes. They lacked knowledge and practice in gathering financial intelligence, using investigative technology and cooperating with other agencies domestically or abroad.\n\nOngoing training in financial analysis and intelligence gathering can equip investigators with the necessary skills, tools and networks to tackle money laundering activities, including those linked to environmental crimes.\n\nA  'learning  by  doing'  approach  helps  -  i.e.  applying new skills in realistic case investigations, together with counterparts from other agencies.\n\n## The value of hands-on, inter-agency training\n\nAs part of an Illegal Wildlife Trade (IWT) Challenge  Fund  project, 6   the  Green  Corruption team of  the  Basel  Institute  on  Governance  has trained Indonesian law enforcement agencies to effectively  handle  money  laundering  cases  and track illicit financial flows tied to illegal logging and wildlife-related crimes with the follow-themoney approach.\n\nThe training brought together investigators and prosecutors  from  key  government  agencies, including from the Ministry of Environment and Forestry, Ministry of Marine Affairs and Fisheries, Attorney General's Office and Financial Intelligence Unit. Participants formed inter-agency groups and collaborated on a realistic case scenario, with each person contributing based on their respective role. The training used practical tools and exercises to explain how criminals conceal money and other assets through shell companies, business fronts, real estate investments and tax havens.\n\nBesides training, the Basel Institute also supported the Ministry of Environment and Forestry in developing  guidelines  to  handle  money  laundering cases,  providing  technical  knowledge  on  the investigation process.\n\nIt  was  just  a  few  months  after  the  training  that the Ministry's investigators, in collaboration with the  Attorney  General's  Office  and  the  Financial Intelligence Unit, achieved their first successful convictions for money laundering related to forest crimes.\n\n## Real cases - even when modest - can have a big impact\n\nThis case set a precedent for integrating financial crime investigations into environmental crime cases.\n\nEven  though  the  amount  of  money  laundered  in  this particular case was relatively low - and the fines Supono was sentenced to pay were a small fraction of that amount - the case has opened the door to tackling more complex, high-value cases in the future.\n\nThis first case also played an important role in helping the Ministry of Environment and Forestry's investigators to:\n\n- · shift their perspective from investigating illegal logging crimes only to handling money laundering offences; and\n- · move  from  a  general  understanding  of  money laundering in theory to handling real-life cases in practice.\n\nWhile training and guidelines were necessary to support the process, the real case itself served as a critical opportunity to identify both obstacles and solutions in applying the follow-the-money approach.\n\n## Both leaders and frontline investigators need to take action\n\nEvery natural resource trafficking case has a potential for exploring money laundering due to the amount of money involved in this type of crime.\n\nA  successful  investigation  requires  initiative from investigators and support from decision-makers. In this case of illegal logging in Alas Purwo National Park:\n\n- · The Ministry of Environment and Forestry's Director General and Director of Investigation encouraged investigators to adopt the follow-the-money approach.\n- · At the technical level, investigators put this encouragement  into  action,  demonstrating  their commitment  to  following  the  money  in  existing predicate crime cases.\n\n## Inter-agency collaboration is vital\n\nCoordination between the relevant agencies from the outset of the investigation has been pivotal to concluding the case successfully. The mutual understanding between counterparts from the Ministry of Environment and Forestry, Attorney General's Office and Financial Intelligence Unit provided a strong foundation for the enforcement process.\n\n## Keywords\n\n\u003C!-- image -->\n\nIndonesia\n\nEnvironmental crimes\n\nIllegal logging\n\nMoney laundering\n\nFinancial investigation\n\n## About this Case Study\n\nThis publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives  4.0  International  Licence (CC BY-NC-ND 4.0).\n\nSuggested citation: Anindito, Lakso. 2025. 'Indonesia: a  landmark  money  laundering  conviction  in  a  forestry crime case.' Case Study 12, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002F cs-12.\n\n## Acknowledgment and disclaimer\n\n\u003C!-- image -->\n\nThe  development  of  this  publication  was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.\n\nThe contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->\n\n\u003C!-- image -->","- In a case of illegal logging in Alas Purwo National Park, investigators of Indonesia’s Ministry of Environment and Forestry obtained their first money laundering conviction.\n- This achievement was made possible through a 2021 Constitutional Court decision extending the power to pursue money laundering offences to investigators in charge of predicate offences, in this case timber trafficking. This power was previously limited to investigators of traditional law enforcement agencies, including the police and the Corruption Eradication Commission.\n- Training and technical assistance by the Green Corruption programme of the Basel Institute on Governance contributed to strengthening law enforcement capacities to effectively handle money laundering cases and track illicit financial flows tied to environmental crimes.\n- Sustained coordination and collaboration among the Ministry, Indonesia’s Financial Intelligence Unit and the Attorney General’s Office were pivotal in applying the follow-the-money approach to the illegal logging case.\n- Businessman Supono was convicted initially of illegally trading rosewood and later of laundering approximately USD 127,000 he had obtained through log trading. In both cases, he was sentenced to prison and ordered to pay a fine.\n- Although the amount of money laundered in this case and the imposed fines were relatively modest, the case set a precedent for integrating financial crime investigations into environmental enforcement. This paves the way for future, larger-scale prosecutions by investigators of environmental agencies.",{"id":635,"storage":47,"filename_disk":636,"filename_download":637,"title":638,"type":51,"created_on":615,"modified_on":615,"charset":11,"filesize":639,"width":397,"height":398,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":640,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":615},"cb6cbdfc-7348-43d5-bfc0-2d3fc41157cd","cb6cbdfc-7348-43d5-bfc0-2d3fc41157cd.jpg?itok=8YTVf-7o","Case-Study-12-Indonesia-ML-conviction-cover.jpg?itok=8YTVf-7o","Case Study 12 Indonesia cover page",52429,{},[642],{"id":643,"publications_id":644,"countries_id":660},1147,{"id":614,"status":10,"sort":11,"user_created":404,"date_created":615,"user_updated":61,"date_updated":616,"nid":617,"slug":618,"image":635,"title":619,"body":620,"citation":621,"language":40,"year":622,"publisher":20,"date_published":623,"external":22,"topic":645,"link_internal":646,"link_external":648,"featured":22,"topics":649,"languages":11,"type":650,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":632,"main_points":633,"short_version":11,"subtitle":11,"countries":651,"tags":652,"pdf":656,"authors":658},[378],[647],{"url":627,"caption":628},[],[378],[42],[643],[653,654,655],4670,4706,4707,[657],2483,[659],2616,{"id":428,"name":429,"code":430,"latitude":431,"longitude":432},[662,675,690],{"id":653,"publications_id":663,"tags_id":674},{"id":614,"status":10,"sort":11,"user_created":404,"date_created":615,"user_updated":61,"date_updated":616,"nid":617,"slug":618,"image":635,"title":619,"body":620,"citation":621,"language":40,"year":622,"publisher":20,"date_published":623,"external":22,"topic":664,"link_internal":665,"link_external":667,"featured":22,"topics":668,"languages":11,"type":669,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":632,"main_points":633,"short_version":11,"subtitle":11,"countries":670,"tags":671,"pdf":672,"authors":673},[378],[666],{"url":627,"caption":628},[],[378],[42],[643],[653,654,655],[657],[659],{"id":4,"name":5},{"id":654,"publications_id":676,"tags_id":687},{"id":614,"status":10,"sort":11,"user_created":404,"date_created":615,"user_updated":61,"date_updated":616,"nid":617,"slug":618,"image":635,"title":619,"body":620,"citation":621,"language":40,"year":622,"publisher":20,"date_published":623,"external":22,"topic":677,"link_internal":678,"link_external":680,"featured":22,"topics":681,"languages":11,"type":682,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":632,"main_points":633,"short_version":11,"subtitle":11,"countries":683,"tags":684,"pdf":685,"authors":686},[378],[679],{"url":627,"caption":628},[],[378],[42],[643],[653,654,655],[657],[659],{"id":688,"name":689},1303,"Environment",{"id":655,"publications_id":691,"tags_id":702},{"id":614,"status":10,"sort":11,"user_created":404,"date_created":615,"user_updated":61,"date_updated":616,"nid":617,"slug":618,"image":635,"title":619,"body":620,"citation":621,"language":40,"year":622,"publisher":20,"date_published":623,"external":22,"topic":692,"link_internal":693,"link_external":695,"featured":22,"topics":696,"languages":11,"type":697,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":632,"main_points":633,"short_version":11,"subtitle":11,"countries":698,"tags":699,"pdf":700,"authors":701},[378],[694],{"url":627,"caption":628},[],[378],[42],[643],[653,654,655],[657],[659],{"id":703,"name":704},1193,"Financial investigations",[706],{"id":657,"publications_id":707,"directus_files_id":718},{"id":614,"status":10,"sort":11,"user_created":404,"date_created":615,"user_updated":61,"date_updated":616,"nid":617,"slug":618,"image":635,"title":619,"body":620,"citation":621,"language":40,"year":622,"publisher":20,"date_published":623,"external":22,"topic":708,"link_internal":709,"link_external":711,"featured":22,"topics":712,"languages":11,"type":713,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":632,"main_points":633,"short_version":11,"subtitle":11,"countries":714,"tags":715,"pdf":716,"authors":717},[378],[710],{"url":627,"caption":628},[],[378],[42],[643],[653,654,655],[657],[659],{"id":719,"storage":47,"filename_disk":720,"filename_download":721,"title":721,"type":200,"folder":201,"uploaded_by":404,"created_on":615,"modified_by":11,"modified_on":615,"charset":11,"filesize":722,"width":11,"height":11,"duration":11,"embed":11,"description":199,"location":11,"tags":11,"metadata":11,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":615},"0a13876e-31fd-4a52-8dc6-5b8700a9a731","0a13876e-31fd-4a52-8dc6-5b8700a9a731.pdf","Case-Study-12-Indonesia-ML-conviction.pdf",929965,[724],{"id":659,"publications_id":725,"authors_id":736},{"id":614,"status":10,"sort":11,"user_created":404,"date_created":615,"user_updated":61,"date_updated":616,"nid":617,"slug":618,"image":635,"title":619,"body":620,"citation":621,"language":40,"year":622,"publisher":20,"date_published":623,"external":22,"topic":726,"link_internal":727,"link_external":729,"featured":22,"topics":730,"languages":11,"type":731,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":632,"main_points":633,"short_version":11,"subtitle":11,"countries":732,"tags":733,"pdf":734,"authors":735},[378],[728],{"url":627,"caption":628},[],[378],[42],[643],[653,654,655],[657],[659],{"id":595,"name":596,"position":11,"image":11},{"id":738,"status":10,"sort":11,"date_created":739,"date_updated":740,"nid":741,"slug":742,"title":743,"body":744,"citation":374,"language":40,"year":622,"publisher":745,"date_published":746,"external":22,"topic":747,"link_internal":749,"link_external":750,"featured":22,"topics":754,"languages":11,"type":755,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":11,"short_version":11,"subtitle":11,"image":757,"countries":765,"tags":789,"pdf":831,"authors":832},2424,"2025-11-03T11:05:50.000Z","2026-05-29T22:23:01.000Z",2864,"back-action-how-uk-reviving-unexplained-wealth-orders-academy-bulletin","Back in Action: How the UK is reviving unexplained wealth orders (The Academy Bulletin)","In an article published in the Fall 2025 issue of the Bulletin of the \u003Ca href=\"https:\u002F\u002Ffinancialcrimelitigators.org\u002F\">International Academy of Financial Crime Litigators\u003C\u002Fa>, Andrew Dornbierer explores the revival of unexplained wealth orders (UWOs) in the United Kingdom.\n\nIntroduced in 2017 as a tool to combat the abuse of UK's markets to launder criminal proceeds, the UWO mechanism suffered a severe setback in 2020. After only a handful of attempts to use it, a decision by the High Court effectively left it sprawled on the canvas.\n\nIn the last year or so, however, the mechanism has slowly started to prove itself. Most recently, the UK's Serious Fraud Office – in its first use of the UK's UWO mechanism – secured GBP 1.1 million from the sale of a property belonging to the ex-wife of a convicted fraudster.\n\nThis article offers a short history of UWOs in the UK. It examines how, after a turbulent start and subsequent amendments to the mechanism, UWOs are now back to being used by UK authorities to tackle illicit financial flows. If applied responsibly, proportionately and in harmony with established legal rights, unexplained wealth orders promise to be a powerful tool in the UK’s fight to recover criminal assets.\n\nThis is the fifth issue of The Academy's Bulletin. It has been established to transmit the work of Academy Fellows, draw attention to matters of importance to the legal community and provide high-level analysis of cutting-edge issues in global financial crime investigations and litigation. The Basel Institute on Governance acts as Secretariat to the Academy.","International Academy of Financial Crime Litigators","2025-11-03",[748],"Asset Recovery",[],[751],{"url":752,"caption":753},"https:\u002F\u002Fedit.financialcrimelitigators.org\u002Fapi\u002Fassets\u002Fb401d6c9-b0e4-4ab9-ad1f-948c567c6ab3.pdf","Fall 2025 Bulletin of the International Academy of Financial Crime Litigators",[38],[756],"Article",{"id":758,"storage":47,"filename_disk":759,"filename_download":760,"title":761,"type":51,"created_on":739,"modified_on":739,"charset":11,"filesize":762,"width":397,"height":763,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":764,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":739},"c313d2fa-3e1c-43ab-b40e-3e418d819df1","c313d2fa-3e1c-43ab-b40e-3e418d819df1.jpg?itok=Bq0TEWSf","Back-in-Action-UWOs-article-cover.jpg?itok=Bq0TEWSf","Back in Action_UWOs in the UK_Academy Bulletin article cover ",21006,655,{},[766],{"id":767,"publications_id":768,"countries_id":783},1143,{"id":738,"status":10,"sort":11,"user_created":404,"date_created":739,"user_updated":61,"date_updated":740,"nid":741,"slug":742,"image":758,"title":743,"body":744,"citation":374,"language":40,"year":622,"publisher":745,"date_published":746,"external":22,"topic":769,"link_internal":770,"link_external":771,"featured":22,"topics":773,"languages":11,"type":774,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":11,"short_version":11,"subtitle":11,"countries":775,"tags":776,"pdf":780,"authors":781},[748],[],[772],{"url":752,"caption":753},[38],[756],[767],[777,778,779],4660,4661,4711,[],[782],2613,{"id":784,"name":785,"code":786,"latitude":787,"longitude":788},225,"Ukraine","UA",48.37943,31.16558,[790,803,816],{"id":777,"publications_id":791,"tags_id":802},{"id":738,"status":10,"sort":11,"user_created":404,"date_created":739,"user_updated":61,"date_updated":740,"nid":741,"slug":742,"image":758,"title":743,"body":744,"citation":374,"language":40,"year":622,"publisher":745,"date_published":746,"external":22,"topic":792,"link_internal":793,"link_external":794,"featured":22,"topics":796,"languages":11,"type":797,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":11,"short_version":11,"subtitle":11,"countries":798,"tags":799,"pdf":800,"authors":801},[748],[],[795],{"url":752,"caption":753},[38],[756],[767],[777,778,779],[],[782],{"id":177,"name":178},{"id":778,"publications_id":804,"tags_id":815},{"id":738,"status":10,"sort":11,"user_created":404,"date_created":739,"user_updated":61,"date_updated":740,"nid":741,"slug":742,"image":758,"title":743,"body":744,"citation":374,"language":40,"year":622,"publisher":745,"date_published":746,"external":22,"topic":805,"link_internal":806,"link_external":807,"featured":22,"topics":809,"languages":11,"type":810,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":11,"short_version":11,"subtitle":11,"countries":811,"tags":812,"pdf":813,"authors":814},[748],[],[808],{"url":752,"caption":753},[38],[756],[767],[777,778,779],[],[782],{"id":4,"name":5},{"id":779,"publications_id":817,"tags_id":828},{"id":738,"status":10,"sort":11,"user_created":404,"date_created":739,"user_updated":61,"date_updated":740,"nid":741,"slug":742,"image":758,"title":743,"body":744,"citation":374,"language":40,"year":622,"publisher":745,"date_published":746,"external":22,"topic":818,"link_internal":819,"link_external":820,"featured":22,"topics":822,"languages":11,"type":823,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":11,"short_version":11,"subtitle":11,"countries":824,"tags":825,"pdf":826,"authors":827},[748],[],[821],{"url":752,"caption":753},[38],[756],[767],[777,778,779],[],[782],{"id":829,"name":830},821,"Unexplained wealth",[],[833],{"id":782,"publications_id":834,"authors_id":845},{"id":738,"status":10,"sort":11,"user_created":404,"date_created":739,"user_updated":61,"date_updated":740,"nid":741,"slug":742,"image":758,"title":743,"body":744,"citation":374,"language":40,"year":622,"publisher":745,"date_published":746,"external":22,"topic":835,"link_internal":836,"link_external":837,"featured":22,"topics":839,"languages":11,"type":840,"area":11,"programme":11,"websites":11,"summary":11,"pdf_text":11,"main_points":11,"short_version":11,"subtitle":11,"countries":841,"tags":842,"pdf":843,"authors":844},[748],[],[838],{"url":752,"caption":753},[38],[756],[767],[777,778,779],[],[782],{"id":846,"name":847,"position":11,"image":848},306,"Andrew Dornbierer","89aae58b-3e50-4375-9b9b-5b31370dab64",39,{"items":851,"total":880},[852],{"id":853,"title":854,"body":855,"date_start":856,"date_end":856,"organiser":20,"type":857,"topics":858,"nid":860,"links":861,"slug":867,"summary":11,"image":868,"tags":878,"countries":899},176,"Basel AML Index 2024 launch","This webinar served to launch the 2024 Public Edition of the Basel AML Index – an independent, data-based ranking and risk assessment tool for money laundering and related financial crime risks around the world.\n\nKateryna Boguslavska, Senior Specialist, AML\u002FCFT and lead of the Basel AML Index, presented the methodology and 2024 report findings.\n\nIker Lekuona, Director of the Basel Institute’s International Centre for Asset Recovery, then moderated a panel discussion covering the following topics:\n\n\n- Helena Wood: Growing fraud threats, issues around definitions and measurement, existing frameworks and the need for global standards.\n- John Cusack: Effectiveness in the fight against financial crime.\n- Atuweni-tupochile Agbermodji: Positive lessons from countries that were on the FATF grey list.\n- Alan Ketley: The purpose of country risk assessments and how to improve their use.\n\n\nLightning round for all speakers: Looking at Basel AML Index findings and other recent developments in the AML space, what gives you hope that we’re going to tip the balance in the fight against financial crime?","2024-12-04","Event",[859],"Anti-Money Laundering",2714,[862,865],{"url":863,"caption":864},"https:\u002F\u002Fblockchaintelligence.com\u002Fevents-blockchain-intelligence-forum-2025\u002F","Watch recording",{"url":866},"https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002F6th-basel-arbitration-crime-conference-updating-toolkit","basel-aml-index-2024-launch-2714",{"id":869,"storage":47,"filename_disk":870,"filename_download":871,"title":854,"type":872,"created_on":873,"modified_on":873,"charset":11,"filesize":874,"width":875,"height":876,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":877,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":873},"7e028438-5a86-44e2-a8d7-28028e3c246b","7e028438-5a86-44e2-a8d7-28028e3c246b.webp","tmp.webp","image\u002Fwebp","2025-02-17T20:28:24.000Z",71630,800,556,{},[879,890],{"id":880,"events_id":881,"tags_id":889},1,{"id":853,"title":854,"image":869,"body":855,"date_start":856,"date_end":856,"organiser":20,"type":857,"topics":882,"nid":860,"links":883,"slug":867,"summary":11,"tags":886,"countries":888},[859],[884,885],{"url":863,"caption":864},{"url":866},[880,887],2,[],{"id":4,"name":5},{"id":887,"events_id":891,"tags_id":898},{"id":853,"title":854,"image":869,"body":855,"date_start":856,"date_end":856,"organiser":20,"type":857,"topics":892,"nid":860,"links":893,"slug":867,"summary":11,"tags":896,"countries":897},[859],[894,895],{"url":863,"caption":864},{"url":866},[880,887],[],{"id":177,"name":178},[],{"items":901,"total":1307},[902,959,1031,1090,1243],{"id":903,"status":10,"date_created":904,"date_updated":905,"title":906,"type":907,"body":908,"date":909,"topic":910,"slug":911,"activity":912,"nid":914,"topics":915,"activities":916,"programme":11,"area":11,"websites":11,"language":40,"image":917,"translation_of":11,"countries":923,"tags":924,"authors":955,"images":956,"translations":957,"content":958},10602,"2026-02-27T15:07:18.000Z","2026-05-29T22:22:39.000Z","Advancing trust and standards between banks and virtual asset service providers – lessons from Wolfsberg Group events at the 9th Global Conference","Blog","_By J. Edward (Ned) Conway, Executive Secretary, The Wolfsberg Group_\n\nAs virtual assets move into the mainstream of traditional finance, tricky questions arise. What does a reasonable, risk-based control framework look like for banks that provide services to virtual asset service providers (VASPs)? And how can compliance teams strengthen private-to-private information sharing to better detect suspicious activity?\n\nThese were some of the questions tackled by the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) at the 9th Global Conference on Criminal Finances and Cryptoassets, organised by the Basel Institute on Governance, Europol and UNODC and held in Vienna on 28–29 October 2025.\n\nThe Wolfsberg Group is an association of 12 global banks that develops frameworks and guidance for the management of financial crime risks. Housed at the Basel Institute on Governance, this long-standing initiative brings together senior financial crime compliance leaders through various working groups, including one dedicated to virtual assets.\n\nThis flagship event provided a valuable platform for the Group to explain its [Stablecoin Guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources\u002F204\u002F), gauge interest in a specific Due Diligence Questionnaire focused on VASPs, and further advance efforts to break down silos in private-to-private information sharing.\n\nThis blog summarises some of the key discussions – dialogues that are continuing in dedicated meetings and consultations of the Wolfsberg Group with members, regulators and institutional partners.\n\n### Regulatory clarity as a catalyst for TradFi–VASP relationships?\n\nDay 1 of the conference saw Ned Conway, Executive Secretary of the Wolfsberg Group, moderate a high-level panel discussion featuring representatives from Circle, Bullish and Société Générale on the theme _“Bridging the TradFi–DeFi Gap.”_\n\nThe panel discussed the barriers to relationship building between traditional finance (TradFi) institutions such as banks and VASPs such as cryptocurrency exchanges and stablecoin issuers. The speakers noted that a lack of trust and understanding persists, particularly around risks specific to virtual assets.\n\nThat is one reason that TradFi is slow to onboard VASPs as clients and provide them with the banking services they need in order to operate. However, stablecoins are helping bridge this gap by bringing parts of the crypto universe under regulatory frameworks.\n\nTradFi institutions underlined that they would benefit from clearer scenarios from regulators on where collaboration and information sharing would be permissible between regulated entities and VASPs. Recent [guidance issued by regulators on stablecoins and virtual assets in Asia](https:\u002F\u002Fwww.hkma.gov.hk\u002Fmedia\u002Feng\u002Fdoc\u002Fkey-functions\u002Fifc\u002Fstablecoin-issuers\u002FGuideline_on_supervision_of_licensed_stablecoin_issuers_eng.pdf), in particular, could help improve confidence both ways in the TradFi-VASP relationship.\n\n### Aligning risk appetite, due diligence and monitoring for suspicious activity\n\nOn Day 2, a dedicated Wolfsberg side event brought together VASPs, FinTech firms and traditional banks for in-depth discussions. Representatives from several Wolfsberg member banks – Deutsche Bank, Citi, UBS, Société Générale, and Bank of America – joined the sessions.\n\nThe agenda focused on frameworks for information sharing, but the discussions touched upon a range of hot topics including:\n\n*   risk appetite and the risk-based approach;\n*   payment transparency (i.e. the [travel rule](https:\u002F\u002Fwww.eba.europa.eu\u002Fpublications-and-media\u002Fpress-releases\u002Feba-issues-travel-rule-guidance-tackle-money-laundering-and-terrorist-financing-transfers-funds-and)); and\n*   approaches to monitoring for suspicious activity.\n\nDuring the discussions, participants highlighted that one of the main barriers to effective collaboration between traditional financial institutions and VASPs is a lack of mutual trust. Both sectors face difficulties in interacting with each other.\n\nThe [Wolfsberg Correspondent Banking Due Diligence Questionnaire](https:\u002F\u002Fwolfsberg-group.org\u002Fresources?type=cbddq-fccq&category=questionnaires) (CBDDQ) is useful for setting standards, but onboarding challenges could be overcome by framing risk in common language. Many viewed the current onboarding approaches as fragmented, and expressed strong support for the Wolfsberg Group to develop standardised guidance and a due diligence questionnaire for VASPs.\n\nQuestions remain about what is “reasonable” and “risk-based” for VASPs, especially for smaller institutions, and whether banks should monitor blockchain transactions themselves. VASPs need to be able to articulate their risk appetite, and how this changes as they continue to develop innovative products and services.\n\nVASP participants viewed the Wolfsberg Group’s [Stablecoin Guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources\u002F204\u002F) as applicable beyond stablecoin issuers to the wider VASP ecosystem. This is particularly true for the tailored questions on the underlying control environment, and the linking of risk appetite directly to monitoring approaches.\n\n### Improving private-private information sharing on suspicious activity\n\nDiscussion on information sharing between TradFi and VASPs highlighted that this can rely heavily on personal relationships across entities, limiting scalability.\n\nVASPs showed concern around sharing wallet addresses under private-to-private information sharing frameworks, given geopolitical trends and concerns around the EU’s General Data Protection Regulation (GDPR). However, consensus emerged that better data sharing both increases the quality of suspicious activity reports (SARs) and reduces SAR volumes.\n\nParticularly on this latter point, activities often thought to be suspicious in a silo are better understood when viewed from multiple perspectives, confirming the importance of information exchange.\n\n### Continuing to build bridges as the financial system evolves\n\nBridging the gap between TradFi and DeFi remains a central theme in the Wolfsberg Group’s strategy. The Vienna events offered a unique opportunity to engage key stakeholders across the sector and advance this important dialogue.\n\nThe side event was opened by Elizabeth Andersen, Executive Director of the Basel Institute on Governance. The Wolfsberg Group extends its sincere thanks to the Basel Institute for the opportunity to co-host this side event and to participate in the 9th Global Conference on Criminal Finances and Cryptoassets.\n\n### Learn more\n\n*   Learn more about the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) and explores its guidance and [resources](https:\u002F\u002Fwolfsberg-group.org\u002Fresources) on managing financial crime risk, including its [Stablecoin Guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources\u002F204\u002F).\n*   Learn more about the [9th Global Conference](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fglobal-experts-advance-joint-fight-against-crypto-enabled-crime) and see selected recordings.\n*   Find out about the [10th Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002F10crc) on 15–16 September 2026 in Luxembourg.","2026-02-11",[859,748],"advancing-trust-and-standards-between-banks-and-virtual-asset-service-providers-lessons-from-wolfsberg-group-events-at-the-9th-global-conference-2929",[913],"Events",2929,[859,38],[913],{"id":918,"storage":47,"filename_disk":919,"filename_download":871,"title":906,"type":872,"created_on":904,"modified_on":904,"charset":11,"filesize":920,"width":875,"height":921,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":922,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":904},"c0f797c0-3af2-47b9-92aa-20efc3f95cce","c0f797c0-3af2-47b9-92aa-20efc3f95cce.webp",39348,533,{},[],[925,942],{"id":926,"news_id":927,"tags_id":939},5605,{"id":903,"status":10,"user_created":404,"date_created":904,"user_updated":61,"date_updated":905,"title":906,"type":907,"body":908,"image":918,"date":909,"topic":928,"slug":911,"activity":929,"nid":914,"topics":930,"activities":931,"programme":11,"area":11,"websites":11,"translation_of":11,"language":40,"countries":932,"tags":933,"authors":935,"images":936,"translations":937,"content":938},[859,748],[913],[859,38],[913],[],[926,934],5620,[],[],[],[],{"id":940,"name":941},854,"Virtual assets",{"id":934,"news_id":943,"tags_id":954},{"id":903,"status":10,"user_created":404,"date_created":904,"user_updated":61,"date_updated":905,"title":906,"type":907,"body":908,"image":918,"date":909,"topic":944,"slug":911,"activity":945,"nid":914,"topics":946,"activities":947,"programme":11,"area":11,"websites":11,"translation_of":11,"language":40,"countries":948,"tags":949,"authors":950,"images":951,"translations":952,"content":953},[859,748],[913],[859,38],[913],[],[926,934],[],[],[],[],{"id":4,"name":5},[],[],[],[],{"id":960,"status":10,"date_created":961,"date_updated":905,"title":962,"type":907,"body":963,"date":964,"topic":965,"slug":966,"activity":967,"nid":972,"topics":973,"activities":974,"programme":11,"area":11,"websites":11,"language":40,"image":975,"translation_of":11,"countries":980,"tags":981,"authors":1012,"images":1028,"translations":1029,"content":1030},10587,"2025-12-04T11:01:47.000Z","Anti-money laundering: what is success?","_This article is adapted from the_ [_2024 Basel AML Index public report_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024)_._\n\nPrivate companies and governments invest significant resources in efforts to combat money laundering and related financial crimes. Financial institutions alone spent an [estimated USD 206 billion globally](https:\u002F\u002Frisk.lexisnexis.com\u002Fglobal\u002Fen\u002Finsights-resources\u002Fresearch\u002Ftrue-cost-of-financial-crime-compliance-study-global-report) on anti-money laundering (AML) compliance in 2023 – and that figure is rising. Yet illicit assets continue to flow through and outside of regulated financial systems. Confiscation rates are still very low, with a long way to go before asset recovery becomes an effective deterrence to financially motivated crimes.\n\nThis is a disaster for countries deprived of [desperately needed funds for development](https:\u002F\u002Functad.org\u002Fsystem\u002Ffiles\u002Fofficial-document\u002Faldcafrica2020_en.pdf), while also negatively impacting on [economies](https:\u002F\u002Fwww.imf.org\u002Fen\u002FBlogs\u002FArticles\u002F2023\u002F12\u002F07\u002Ffinancial-crimes-hurt-economies-and-must-be-better-understood-and-curbed), [security](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fframing-financial-crime-security-threat) and the health of our [planet](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-50).\n\nIt is right to question whether we are on the path to success, and indeed what we mean by success in the fight against money laundering and related financial crimes. This article looks at what data we have and what else we should consider in answering this question.\n\n### 1 Are we making progress in terms of international standards?\n\nA very basic question is whether countries and regions are at least in line with minimum international standards for AML set by the FATF.\n\nWhile it is important to [question](https:\u002F\u002Fwww.rusi.org\u002Fexplore-our-research\u002Fpublications\u002Fcommentary\u002Fwhats-point-financial-action-task-force-standards) FATF data and standards, and to identify [abuses](https:\u002F\u002Fwww.rusi.org\u002Fexplore-our-research\u002Fprojects\u002Fcharting-authoritarian-abuses-fatf-standards) and [unintended consequences](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFinancialinclusionandnpoissues\u002FUnintended-consequences-project.html), ultimately they are the foundation of a harmonised global framework aimed at reducing opportunities for criminals to hide and launder illicit funds.\n\n#### _Technical compliance: fewer black holes on the map_\n\nFirst, the good news. Technical compliance with the FATF’s 40 Recommendations has, on average, increased by 12 percentage points globally since the start of the fourth round of evaluations in 2013. Much of that improvement comes from lower-performing countries catching up with the others. This indicates that more countries are at least meeting basic standards of an AML legal and institutional infrastructure. There are fewer black holes on the map.\n\nTo reach the 12 percentage point figure, we analysed data on 113 countries and jurisdictions that had both mutual evaluation reports (MERs) and subsequent follow-up reports (FURs) from the FATF.\n\nThe greatest progress has taken place in the area of preventive measures and targeted financial sanctions. The following table indicates the highest level of progress in technical compliance with FATF Recommendations across all 113 jurisdictions assessed with MERs and FURs:\n\nRecommendation\n\nAverage technical compliance\n\nR.7: Targeted financial sanctions – proliferation of weapons of mass destruction\n\n57% (up from 31%)\n\nR.19: Higher-risk countries\n\n74% (up from 51%)\n\nR.12: Politically exposed persons\n\n73% (up from 51%)\n\nR.16: Wire transfers\n\n71% (up from 50%)\n\nR.22: DNFBPs – Customer due diligence\n\n59% (up from 40%)\n\nR.6: Targeted financial sanctions – terrorism and terrorist financing\n\n62% (up from 43%)\n\nIt is good to see progress in R.22 on designated non-financial businesses and professions (DNFBPs), since this has traditionally been an area of low performance globally and a frequently criticised weakness in AML systems.\n\nThe progress brings hope that more countries have now imposed stricter customer due diligence requirements for gambling businesses, improved record-keeping standards on customer information and transactions, increased the coverage of customer due diligence requirements to relevant professionals such as property developers and precious metal dealers, and increased the responsibilities and obligations for legal professionals.\n\nWhile improvements in most Recommendations may show real progress across countries, the dynamics in R.16 on wire transfers are complicated by the increase in new payment systems and methods that are not captured by this Recommendation.\n\nIn early 2024, the FATF conducted [public consultations](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002FR16-public-consultation-Feb24.html) on possible amendments to R.16 to reflect this evolution in payment systems and to increase the transparency of cross-border payments. It may be that stricter requirements under R.16 will lead to a rapid deterioration in compliance in the next period.\n\n#### _Regional picture: closing the gap_\n\nIn general, countries and regions with low scores in technical compliance with the FATF Recommendations are catching up, including as a result of being [grey listed](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Ffatf-grey-list-truth-and-myths). The top 20 countries and jurisdictions in terms of progress are mostly in Sub-Saharan Africa and Latin America and the Caribbean, followed by East Asia and Pacific, regions with low average performance previously.\n\nThe following table shows countries with the highest level of progress in technical compliance with FATF Recommendations, out of all those assessed with MERs and FURs. Countries with an asterisk (\\*) are those that are or have been on the FATF grey list.\n\nProgress between mutual evaluation report and latest follow-up report\n\nCountries and jurisdictions (progress in percentage points)\n\n40–52 percentage points\n\nMauritius\\* (52), Botswana\\* (50), Vanuatu\\* (49), Mauritania (48), Uganda\\* (40)\n\n25–39 percentage points\n\nPakistan\\* (33), Iceland\\* (33), Saint Lucia (29), Bahamas\\* (28), Sri Lanka\\* (27), Zimbabwe\\* (26)\n\n20–25 percentage points\n\nMongolia\\* (24), Kenya\\* (24), Norway (24), Costa Rica (23), Morocco\\* (23), Fiji (22), Jamaica\\* (22), Bhutan (21), Trinidad and Tobago\\* (21), Tunisia\\* (20)\n\nThese leaps in performance are not the norm, however: more than half of the assessed countries made progress of less than 10 percentage points.\n\n#### _Effectiveness is falling_\n\nMore challenging, and more depressing, is to assess changes in effectiveness according to the FATF’s 11 Immediate Outcomes (IOs). FATF follow-up reports do not currently reassess countries against these effectiveness criteria. At the global level, however, we can see that effectiveness is decreasing. And that decrease is happening from an already very low base.\n\nWe analysed the difference in global effectiveness scores as the FATF increased its coverage of fourth-round evaluation reports from 115 countries and jurisdictions in 2021 to 178 in 2024.\n\nAverage effectiveness dropped from 30 percent in 2021 to 28 percent in 2023 and remained at that low level in 2024. That means newly assessed countries have similarly low levels of effectiveness as those assessed in earlier years.\n\nWhat’s falling the most? The following table displays the IOs with the lowest effectiveness scores on average across all jurisdictions assessed with mutual evaluation reports. All of them dropped still further between 2021 and 2024:\n\nImmediate Outcome (paraphrased)\n\nAverage effectiveness\n\nIO7: Money laundering investigations, prosecutions and effective, proportionate and dissuasive sanctions\n\n20% (down from 21% in 2021)\n\nIO5: Legal persons and arrangements prevented from misuse for money laundering and terrorist financing (ML\u002FTF); beneficial ownership information available to competent authorities\n\n21% (down from 22%)\n\nIO4: Financial institutions and DNFBPs apply AML\u002FCFT preventive measures commensurate with their risks and report suspicious transactions\n\n22% (down from 24%)\n\nIO11: Prevention of financing of proliferation of weapons of mass destruction\n\n22% (down from 24%)\n\nIO3: Appropriate supervision according to a risk-based approach\n\n23% (down from 26%)\n\nIO10: Prevention of terrorist financing \u002F abuse of non-profit sector\n\n24% (down from 27%)\n\nEven in the IOs with the highest average performance globally across all jurisdictions assessed with MERs, we see decreasing effectiveness as more countries are assessed:\n\nImmediate Outcome (paraphrased)\n\nAverage effectiveness\n\nIO2: International cooperation on information, financial intelligence and evidence against criminals and assets\n\n44% (down from 49% in 2021)\n\nIO1: Risks understood and domestic coordination to combat ML\u002FTF and proliferation financing\n\n36% (down from 38%)\n\nIO6: Financial intelligence and other information used investigations\n\n34% (down from 37%)\n\nIO9: Terrorist financing investigations, prosecutions and effective, proportionate and dissuasive sanctions\n\n33% (down from 37%)\n\nIO8: Proceeds and instrumentalities of crime confiscated\n\n27% (down from 29%)\n\nIO8 on proceeds and instrumentalities of crime confiscated dropped despite hopes for a rise, as [asset recovery was an FATF priority](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Ftopics\u002Fasset-recovery.html) in 2022–2023.\n\nThe big picture? Overall, countries’ AML frameworks are gradually becoming more technical compliant with the global standards but less effective in practice.\n\n### Effectiveness along the asset recovery chain\n\nData from the Basel AML Index Expert Edition Plus, which includes the full FATF dataset, can help to identify weak links in what we call the asset recovery “chain” – all the steps from preventing and detecting illicit financial flows through to their confiscation and restitution.\n\nApplying this concept to FATF data on effectiveness can give us a simplified picture of what might be weak links in the chain. The following figure shows FATF average effectiveness ratings applied to key links in the asset recovery “chain”:\n\n> The concept of the asset recovery chain is at the heart of the support provided by our International Centre for Asset Recovery (ICAR) to partner countries, including Basel AML Index-based technical assistance in strengthening understanding of and resilience to money laundering risks.\n\n### 2 What other data and metrics can we use to better measure success in practice?\n\nFATF data is the best that is available for comparing money laundering vulnerabilities in different countries and jurisdictions, as the same assessment methodology is applied globally.\n\nYet alone it is clearly not enough to give an accurate picture of success. Critics point out that many countries with high performance in both technical compliance and effectiveness are favoured destinations for those seeking to stash, spend and launder money.\n\nThis is why the Basel AML Index methodology takes into account a variety of indicators beyond the quality of a country’s AML framework as assessed by the FATF. They make it easier to evaluate financial crime risk exposure more widely as well as the functioning of the system as a whole. They also make it possible to see where data is missing or could be misleading.\n\nMany of these metrics are useful in evaluating whether systems are working in practice not only to address illicit financial flows as an end in itself but considering wider implications for people and societies.\n\nThe following figure offers some illustrative examples. See the [methodology](https:\u002F\u002Findex.baselgovernance.org\u002Fmethodology) online for more information and subscribe to the Expert Edition (free for most users outside the private sector) to view and filter the full data.\n\n### 3 Clearer goals, better evidence\n\nIt may seem obvious to readers, but it still needs to be stressed: the fight against financial crime is not a narrow technical issue but a multi-dimensional challenge that is interlinked with many aspects of our lives at both the national and global level. A single metric alone will never be sufficient to measure success.\n\nMeasuring success depends on defining the ultimate objective. The FATF’s purpose has always been to “protect financial systems and the broader economy”. This may be a useful intermediate goal. But we support rising calls to position the fight against money laundering and related financial crimes as ultimately key to achieving a more peaceful, just and sustainable world.\n\nAchieving this ambition requires a nuanced understanding of the broader factors driving money laundering risk and their far-reaching consequences, as illustrated above. It also demands robust evidence of the effectiveness and tangible benefits of AML measures, to counter scepticism and bolster the case for sustained investment in these efforts\n\nCrucially, building an effective AML system is not merely a technical task for a single government department or a compliance team. It is a collective mission that requires collaboration across sectors, industries and borders. Only through a shared commitment and clear vision of our end goal can we create a world where financial systems are resilient to exploitation for criminal purposes and where AML measures support broader societal goals.\n\n### Learn more\n\n*   Read the [13th annual Public Edition report of the Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024).\n*   Explore the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F).","2025-02-20",[859,748],"anti-money-laundering-what-is-success-2768",[968,969,970,971],"Basel AML Index","Research","Reports","Insights",2768,[859,38],[968,969,970,971],{"id":976,"storage":47,"filename_disk":977,"filename_download":871,"title":962,"type":872,"created_on":961,"modified_on":961,"charset":11,"filesize":978,"width":875,"height":921,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":979,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":961},"947bee1f-add9-40fb-9346-e20626e7c915","947bee1f-add9-40fb-9346-e20626e7c915.webp",13936,{},[],[982,999],{"id":983,"news_id":984,"tags_id":997},5585,{"id":960,"status":10,"user_created":404,"date_created":961,"user_updated":61,"date_updated":905,"title":962,"type":907,"body":963,"image":976,"date":964,"topic":985,"slug":966,"activity":986,"nid":972,"topics":987,"activities":988,"programme":11,"area":11,"websites":11,"translation_of":11,"language":40,"countries":989,"tags":990,"authors":992,"images":994,"translations":995,"content":996},[859,748],[968,969,970,971],[859,38],[968,969,970,971],[],[983,991],5663,[993],1362,[],[],[],{"id":998,"name":968},1346,{"id":991,"news_id":1000,"tags_id":1011},{"id":960,"status":10,"user_created":404,"date_created":961,"user_updated":61,"date_updated":905,"title":962,"type":907,"body":963,"image":976,"date":964,"topic":1001,"slug":966,"activity":1002,"nid":972,"topics":1003,"activities":1004,"programme":11,"area":11,"websites":11,"translation_of":11,"language":40,"countries":1005,"tags":1006,"authors":1007,"images":1008,"translations":1009,"content":1010},[859,748],[968,969,970,971],[859,38],[968,969,970,971],[],[983,991],[993],[],[],[],{"id":4,"name":5},[1013],{"id":993,"news_id":1014,"authors_id":1025},{"id":960,"status":10,"user_created":404,"date_created":961,"user_updated":61,"date_updated":905,"title":962,"type":907,"body":963,"image":976,"date":964,"topic":1015,"slug":966,"activity":1016,"nid":972,"topics":1017,"activities":1018,"programme":11,"area":11,"websites":11,"translation_of":11,"language":40,"countries":1019,"tags":1020,"authors":1021,"images":1022,"translations":1023,"content":1024},[859,748],[968,969,970,971],[859,38],[968,969,970,971],[],[983,991],[993],[],[],[],{"id":876,"name":1026,"position":11,"image":1027},"Dr Kateryna Boguslavska","24433c58-4115-4c6c-b220-142b5a1b135b",[],[],[],{"id":1032,"status":10,"date_created":1033,"date_updated":1034,"title":1035,"type":907,"body":1036,"date":1037,"topic":1038,"slug":1039,"activity":1040,"nid":1041,"topics":1042,"activities":1043,"programme":11,"area":11,"websites":1044,"language":11,"image":1046,"translation_of":11,"countries":1054,"tags":1055,"authors":1072,"images":1087,"translations":1088,"content":1089},10532,"2025-02-06T11:01:49.000Z","2026-05-29T22:22:34.000Z","FATF grey list: truth and myths","_This article is adapted from the_ [_2024 Basel AML Index public report_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024)_._\n\nFinancial crime has far-reaching impacts on people’s lives. Yet often the only time it draws serious attention in the media is when a country is added to the [FATF’s grey list](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fcountries\u002Fblack-and-grey-lists.html). This designation of “jurisdictions under increased monitoring” frequently sparks debate and concern, and is clouded by misconceptions. This section looks at five common myths that we come across in our work to support partner countries seeking to avoid or leave the grey list.\n\n### Myth 1: The grey list = high-risk countries\n\nA common misconception about the FATF grey list is that it represents (the only) countries and jurisdictions that pose high risks for money laundering, terrorist financing and proliferation financing.\n\nIn fact, in the FATF’s own words, the grey list is the public list of jurisdictions that are “actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.” It is the FATF’s black list that specifically identifies high-risk countries and calls for enhanced due diligence and\u002For countermeasures when dealing with these.\n\nThe distinction is important because not all grey-listed countries pose the same level or type of risk. Many are on a rapid path to improvement. Not all will require enhanced due diligence. And some countries that are not and never have been on the grey list may still present significant risks.\n\nInclusion on the grey list is based on the FATF's [International Co-operation Review Group](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FHigh-risk-and-other-monitored-jurisdictions\u002FMore-on-high-risk-and-non-cooperative-jurisdictions.html) (ICRG) process and on the criteria summarised under Myth 2, rather than merely on its own criteria for identifying a higher-risk country (see box below).\n\nA complicating factor for financial institutions seeking to identify clear criteria for applying enhanced due diligence is the use of both the black and grey lists by the EU and UK for their own lists of high-risk third countries.\n\n> What is a higher-risk country?\n> \n> The Interpretative Note to the FATF’s [Recommendation 10](https:\u002F\u002Fcfatf-gafic.org\u002Fdocuments\u002Ffatf-40r\u002F376-fatf-recommendation-10-customer-due-diligence) on customer due diligence sets out guidelines on country or geographic risk factors that might trigger the application of enhanced due diligence according to a risk-based approach. The criteria (note 15b) refer to countries that are “identified by credible sources” as having inadequate AML\u002FCFT systems, high levels of corruption and crime or high levels of terrorist activity and financing, or that are subject to sanctions or similar measures. It does not specifically refer to either the grey list or the black list, though this may be one factor that organisations take into account.\n> \n> Similarly, [Recommendation 19](https:\u002F\u002Fwww.cfatf-gafic.org\u002Fdocuments\u002Ffatf-40r\u002F385-fatf-recommendation-19-higher-risk-countries) on higher-risk countries and its Interpretative Note require enhanced due diligence by financial institutions to be applied only to countries “for which this is called for by the FATF”, indicating the black list of jurisdictions subject to a call for action.\n\n### Myth 2: Grey listing is a surprise\n\nEach time the FATF holds a plenary session, commentators appear to “bet” which countries will be added or removed. This leads some to believe that grey listing comes as a surprise – even to a country’s authorities.\n\nIn fact, grey listing is based mainly on a country’s poor performance in its mutual evaluation report, specifically in one of four criteria:\n\n*   Fifteen or more non-compliant or partially compliant ratings for technical compliance in any Recommendation.\n*   A non-compliant or partially compliant rating for three or more of the following Recommendations: R.3 (money laundering offences), R.5 (terrorist financing offences), R.6 (targeted financial sanctions related to terrorist financing), R.10 (customer due diligence), R.11 (record keeping) and R.20 (reporting of suspicious transactions).\n*   A low or moderate level of effectiveness for nine or more of the 11 Immediate Outcomes, with a minimum of 2 low ratings.\n*   A low level of effectiveness for six or more of the 11 Immediate Outcomes.\n\nThe authorities typically have a year or more to work on their specific weaknesses without being publicly listed, under the FATF’s International Co-operation process.\n\nThe FATF also prioritises countries and jurisdictions with significant financial centres. For the fifth round of evaluations, the threshold has been increased from USD 5 billion to USD 10 billion, measured in [broad money terms](https:\u002F\u002Fwww.oecd.org\u002Fen\u002Fdata\u002Findicators\u002Fbroad-money-m3.html).\n\nSo grey listing is rarely a surprise to the authorities. It is however less easy for third parties like financial institutions and foreign donors to predict whether a jurisdiction will end up on the grey list.\n\nOur [Expert Edition Plus](https:\u002F\u002Findex.baselgovernance.org\u002Fexpert-edition) now offers subscribers an assessment of the risks that a particular country will end up on the grey list. This makes it possible to better anticipate this and prepare accordingly – including, we would recommend, by using the Basel AML Index to assess the broad range of factors contributing to a higher level of money laundering risk.\n\n### Myth 3: Grey listing has only negative impacts\n\nBeing added to the FATF grey list can trigger severe economic consequences for countries, especially low-income countries dependent on foreign investment and assistance. Investors and financial institutions may reduce their business in the country. A 2021 [IMF paper](https:\u002F\u002Fpapers.ssrn.com\u002Fsol3\u002Fpapers.cfm?abstract_id=4026331) found that capital inflows decline on average by 7.6 percent of GDP following grey listing, for example.\n\nFinancial institutions may also “de-risk” completely – cutting off all business to avoid the extra compliance and risk management costs. Individuals and businesses may have challenges accessing financial services as a result, leading to lower financial inclusion. Other [unintended consequences](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fpb-12) may include an increase in the use of less regulated channels to move money.\n\nNegative economic consequences are not inevitable, however, especially for more developed economies. [Croatia’s economy and its financial sector](https:\u002F\u002Fwww.imf.org\u002Fen\u002FPublications\u002FCR\u002FIssues\u002F2024\u002F07\u002F26\u002FRepublic-of-Croatia-2024-Article-IV-Consultation-Press-Release-and-Staff-Report-552561), for example, both appear to be relatively unscathed by its placement on the grey list in 2023. S&P Global even [upgraded](https:\u002F\u002Fdisclosure.spglobal.com\u002Fratings\u002Fen\u002Fregulatory\u002Farticle\u002F-\u002Fview\u002Ftype\u002FHTML\u002Fid\u002F3250133) its long-term sovereign credit rating from BBB+ to A- in September 2023.\n\nWould it have done even better if it hadn’t been grey listed? It is hard to know – but in some cases perhaps being grey listed could even help a country’s performance in the long run, by motivating it to conduct necessary reforms quickly. For example, Iceland and Malta both managed to leave the grey list after just a year, having speedily fulfilled the requirements of their action plans.\n\nFor countries receiving development aid, grey listing can bring the benefit of increased targeted assistance to implement reforms and eventually exit the grey list. However, since authorities are typically aware of the risk of grey listing in advance (see Myth 2), it would be more effective if this assistance were provided earlier to help prevent the country from being listed in the first place.\n\n### Myth 4: The grey-listing system is inherently unfair\n\nCritics of the grey-listing system point out that it unfairly penalises low-income jurisdictions with less capacity for AML\u002FCFT but also lower significance due to their small financial centres.\n\nIt is true that low-income countries are disproportionately represented on the grey list, but this is changing. More than half of grey-listed countries at the time of writing are in [Sub-Saharan Africa](https:\u002F\u002Findex.baselgovernance.org\u002Fapi\u002Fassets\u002Ff2c74bc1-2760-4bea-a118-aaa96b9cdf09), for example. Yet the addition of European countries in 2023 and 2024 – Bulgaria, Croatia and Monaco – shows that the geography is shifting.\n\nThe following figure shows the percentage of jurisdictions in each region on the grey list as of October 2024:\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2025-02\u002FGraphic%20regional%20percentage%20FATF%20grey%20list.png)\n\n[New prioritisation criteria](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfgeneral\u002FFATF-grey-listing-criteria.html) announced in October 2024 in effect apply a risk-based approach to grey listing. High-income countries and jurisdictions with financial centres over USD 10 billion will be prioritised. Least developed countries as defined by the UN will not be prioritised except in rare cases of high risk, in which case they will have a longer time period to work on their deficiencies before being grey listed.\n\nAs these changes take effect, we should see the grey-listing geography shift towards higher-income countries that are deeply integrated in financial markets.\n\nAnd there are some simple things that a country can do to avoid grey listing – namely, prepare well for the mutual evaluation process, which is always announced well in advance. Quite basic actions can help, like preparing an up-to-date [national risk assessment](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-26-national-money-laundering-and-terrorist-financing-risk-assessments) (and specific sectoral assessments where relevant), gathering statistical data and developing strategies to mitigate identified risks.\n\nThe Basel AML Index methodology does not penalise countries for being on the grey list, since the deficiencies that led to them being grey listed are already apparent in the mutual evaluation report data. In 2023, we also [updated our methodology](https:\u002F\u002Findex.baselgovernance.org\u002Fnews\u002Fbasel-aml-index-2023-reflecting-the-progress-of-grey-listed-jurisdictions-2513) to better capture improvements in the effectiveness of jurisdictions that exit the grey list, even if the FATF does not release new effectiveness data.\n\n### Myth 5: Leaving the grey list is the end of the story\n\nGrey listing is just one period in a country’s anti-money laundering journey. Being delisted is naturally a cause for celebration and hope, but it’s not the end of the story. Many jurisdictions have been grey listed more than once, including Cambodia, Nicaragua, Panama and Pakistan.\n\nFATF standards continue to evolve and to strengthen, so jurisdictions need to constantly improve in order to keep up.\n\nA prominent example highlighted in several Basel AML Index reports over the years is Recommendation 15 on virtual assets. After it was updated in 2018, almost all subsequently assessed jurisdictions [achieved lower levels of compliance](https:\u002F\u002Findex.baselgovernance.org\u002Fnews\u002Fvirtual-currencies-are-we-missing-a-trick-insights-from-the-basel-aml-index-2023-2541) than previously. We can expect a similar effect with the [updated Recommendations 4 and 38](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Ffatf-seeks-change-landscape-international-asset-recovery-what-means-latin-america) on asset recovery, where there are still some countries that do not meet basic criteria such as having a non-conviction based forfeiture law or enforcing international judgements based on these laws.\n\nThe FATF’s fifth round of evaluations will [emphasise effectiveness](https:\u002F\u002Fwww.fatf-gafi.org\u002Fcontent\u002Ffatf-gafi\u002Fen\u002Fpublications\u002FMutualevaluations\u002FFatf-methodology.html) over technical compliance. Countries will need to put in more effort to improve their effectiveness ratings, which are, on average, less than half as strong as their ratings for technical compliance.\n\nAs financial systems continue to evolve, criminals will find ever more ingenious ways to steal, launder and hide money or to use it for illicit purposes such as the financing of terrorism and weapons of mass destruction. Avoiding or graduating from the grey list is one step along a never-ending journey to a resilient system that successfully wards of money laundering and related threats while not limiting financial inclusion and innovation.\n\n### Learn more\n\n*   Read the [13th annual Public Edition report of the Basel AML Index](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fbasel-aml-index-2024).\n*   Explore the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F).","2025-02-06",[859,748],"fatf-grey-list-truth-and-myths-2760",[971],2760,[859,38],[971],[1045],"Main page",{"id":1047,"storage":47,"filename_disk":1048,"filename_download":871,"title":1035,"type":872,"created_on":1049,"modified_on":1049,"charset":11,"filesize":1050,"width":1051,"height":1052,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":1053,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":1049},"2397c564-394a-4f1e-8448-ec230a14810c","2397c564-394a-4f1e-8448-ec230a14810c.webp","2025-05-12T21:09:46.000Z",36158,1400,933,{},[],[1056],{"id":1057,"news_id":1058,"tags_id":1071},5666,{"id":1032,"status":10,"user_created":404,"date_created":1033,"user_updated":61,"date_updated":1034,"title":1035,"type":907,"body":1036,"image":1047,"date":1037,"topic":1059,"slug":1039,"activity":1060,"nid":1041,"topics":1061,"activities":1062,"programme":11,"area":11,"websites":1063,"translation_of":11,"language":11,"countries":1064,"tags":1065,"authors":1066,"images":1068,"translations":1069,"content":1070},[859,748],[971],[859,38],[971],[1045],[],[1057],[1067],1090,[],[],[],{"id":4,"name":5},[1073],{"id":1067,"news_id":1074,"authors_id":1086},{"id":1032,"status":10,"user_created":404,"date_created":1033,"user_updated":61,"date_updated":1034,"title":1035,"type":907,"body":1036,"image":1047,"date":1037,"topic":1075,"slug":1039,"activity":1076,"nid":1041,"topics":1077,"activities":1078,"programme":11,"area":11,"websites":1079,"translation_of":11,"language":11,"countries":1080,"tags":1081,"authors":1082,"images":1083,"translations":1084,"content":1085},[859,748],[971],[859,38],[971],[1045],[],[1057],[1067],[],[],[],{"id":876,"name":1026,"position":11,"image":1027},[],[],[],{"id":1091,"status":10,"date_created":1092,"date_updated":1093,"title":1094,"type":1095,"body":1096,"date":1097,"topic":1098,"slug":1101,"activity":1102,"nid":1103,"topics":1104,"activities":1106,"programme":11,"area":11,"websites":1107,"language":11,"image":1108,"translation_of":11,"countries":1115,"tags":1161,"authors":1222,"images":1240,"translations":1241,"content":1242},10509,"2024-11-27T11:01:43.000Z","2026-05-07T21:29:56.000Z","Money dirtying: shining a light on how clean money turns into bribes","News","There’s a lot of attention to the laundering of “dirty money” – but very little about how clean money can be turned into bribes, kickbacks or payments to terrorists.\n\nTogether with David Jancsics, I examined the money-dirtying strategies at the heart of one of the world’s most dramatic corruption scandals: the _Lava Jato_ or Car Wash case. How did the multinational company Odebrecht manage to secretly channel millions in legitimately earned funds to bribe politicians and bureaucrats across the continent? Our article [_Turning Legally Obtained Resources into Illegal Payments: A Money Dirtying Scheme_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fturning-legally-obtained-resources-illegal-payments-money-dirtying-scheme) attempts to answer this question and to explore the networks of individuals and entities that made the schemes possible.\n\nExploring the concept and practice of money dirtying could help practitioners get a more holistic view of major financial crime cases. It could also potentially lead to new ways to prevent, detect and intercept illicit financial flows.\n\n### What is “money dirtying”?\n\nWe use the term “money dirtying” to refer to the process by which clean, legitimate resources are turned into illicit payments used for corruption, the financing of terrorism and other illegal activities.\n\nThe term was originally coined to describe the mechanisms of terrorism financing in the late 1990s and early 2000s. Following the terrorist attacks of 9\u002F11, researchers worked to understand the financial structures that allowed Al-Qaeda to finance the attacks. We have repurposed the term to fit the field of corruption, but the underlying idea is the same.\n\n### What are the typical characteristics?\n\nOn the face of it, money dirtying has similar characteristics to money laundering:\n\n*   Complex, multi-layered schemes using redundant payments and fake contracts to make funds difficult to trace.\n*   The use of specialised professionals who can create sophisticated financial infrastructures and know all the tricks to evade detection.\n*   The use of informal actors such as _halawadars_ or _doleiros_ to escape regulatory radars.\n*   Often transnational, with money, resources and information shared along a cross-border network of individuals and entities.\n\n### What makes it different to money laundering?\n\nThe key differences lie in the purpose and the direction of the flow.\n\n*   Money laundering seeks to clean dirty money by reintegrating it into the legal financial system. It is a circular system, where the funds return to their point of origin.\n*   Money dirtying serves to transfer money undetected from the bribe giver to the bribe taker. It is linear.\n\nFor example, in our case study, the money took the following route:\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-11\u002FUntitled.jpg)\n\nIn reality, it looked more like this:\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-11\u002FUntitled%20design.png)\n\n### The Lava Jato case\n\nThe _Lava Jato_ case (Operation Car Wash) was a major judicial investigation launched in Brazil in 2009. Initially focused on money laundering and illegal activities linked to a car wash company, it quickly expanded into one of the largest corruption investigations in history. By the early 2010s, investigations and plea deals had exposed the intricate financial structures and corrupt management systems of the Odebrecht Group at the heart of a web of illicit payments in countries across the region.\n\nUnlike other cases, there is significant public information available about Lava Jato thanks to judicial investigations, journalistic work, academic studies and other reports. This allowed us to map and analyse the “money dirtying” network in detail.\n\nThe case is also an ideal case study in advanced corruption schemes. It was large, long-running and used complex, multi-layered networks that spread across the world. \n\n### Skeleton and muscles\n\nTo map the complex networks of the Odebrecht Group’s money dirtying networks we looked at the data in two ways:\n\n*   We analysed the transactions, performing a [social network analysis](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-4-social-network-analysis-combating-organised-crime-and-trafficking) and looking at the “skeleton” of the network – how it was shaped, where transactions centred and how they moved.\n*   At the same time, we tried to understand the _substance_ of the network. If you like, the muscles surrounding the skeleton. We read interviews and wiretaps, and looked at personal histories to understand the relationships between people in the network and how they operated together.\n\nWe then created a coherent framework of both the “skeleton” and “muscles”. This includes a description of each role and its function within the network.\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-11\u002Fnew%20version.png)\n\n### So what?\n\nPaying more attention to how legitimate funds are channelled towards illegal activities can help anti-corruption practitioners to gain a more holistic view of major corruption schemes.\n\nWith the increase in internal controls and regulatory scrutiny, those that engage in corruption are forced to use more sophisticated methods than just declaring bribes as “consultancy fees”, for example. A better understanding of these methods could help inform stronger internal controls and compliance systems.\n\nThis focus also helps practitioners to see how some of the same methods – legal structures in offshore financial centres, shell companies, professional enablers, informal value transfer service providers for example – can be misused not only for money laundering but for other parts of a corruption scheme.\n\nThe research also showcases the power of social network analysis in mapping the key individuals and entities involved in transforming clean money into illicit payments. Combined with evidence of their relations and interactions, this can create a valuable source of information for both law enforcement and the development of evidence-based strategies for targeting corrupt networks.\n\n### Learn more\n\n[Organisational forms of corruption networks: the Odebrecht-Toledo case](http:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Forganisational-forms-corruption-networks-odebrecht-toledo-case)\n\n[Quick Guide 4: Social network analysis in combating organised crime and trafficking](http:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-4-social-network-analysis-combating-organised-crime-and-trafficking)\n\n[Research Case Study 3: Exposing the networks behind transnational corruption and money laundering schemes](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fresearch-case-3)","2024-11-25",[1099,1100],"Prevention"," Research and Innovation","money-dirtying-shining-a-light-on-how-clean-money-turns-into-bribes-2723",[969,971],2723,[1105],"Prevention Research and Innovation",[969,971],[1045],{"id":1109,"storage":47,"filename_disk":1110,"filename_download":871,"title":1094,"type":872,"created_on":1111,"modified_on":1111,"charset":11,"filesize":1112,"width":1051,"height":1113,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":1114,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":1111},"04afeb59-9775-4b6c-b487-de86baa29a94","04afeb59-9775-4b6c-b487-de86baa29a94.webp","2025-05-12T21:10:07.000Z",43618,878,{},[1116,1142],{"id":1117,"news_id":1118,"countries_id":1136},7080,{"id":1091,"status":10,"user_created":404,"date_created":1092,"user_updated":61,"date_updated":1093,"title":1094,"type":1095,"body":1096,"image":1109,"date":1097,"topic":1119,"slug":1101,"activity":1120,"nid":1103,"topics":1121,"activities":1122,"programme":11,"area":11,"websites":1123,"translation_of":11,"language":11,"countries":1124,"tags":1126,"authors":1131,"images":1133,"translations":1134,"content":1135},[1099,1100],[969,971],[1105],[969,971],[1045],[1117,1125],7081,[1127,1128,1129,1130],4862,5685,5686,5687,[1132],1099,[],[],[],{"id":1137,"name":1138,"code":1139,"latitude":1140,"longitude":1141},29,"Brazil","BR",-14.235,-51.92528,{"id":1125,"news_id":1143,"countries_id":1155},{"id":1091,"status":10,"user_created":404,"date_created":1092,"user_updated":61,"date_updated":1093,"title":1094,"type":1095,"body":1096,"image":1109,"date":1097,"topic":1144,"slug":1101,"activity":1145,"nid":1103,"topics":1146,"activities":1147,"programme":11,"area":11,"websites":1148,"translation_of":11,"language":11,"countries":1149,"tags":1150,"authors":1151,"images":1152,"translations":1153,"content":1154},[1099,1100],[969,971],[1105],[969,971],[1045],[1117,1125],[1127,1128,1129,1130],[1132],[],[],[],{"id":1156,"name":1157,"code":1158,"latitude":1159,"longitude":1160},171,"Peru","PE",-9.18997,-75.01515,[1162,1178,1194,1208],{"id":1127,"news_id":1163,"tags_id":1175},{"id":1091,"status":10,"user_created":404,"date_created":1092,"user_updated":61,"date_updated":1093,"title":1094,"type":1095,"body":1096,"image":1109,"date":1097,"topic":1164,"slug":1101,"activity":1165,"nid":1103,"topics":1166,"activities":1167,"programme":11,"area":11,"websites":1168,"translation_of":11,"language":11,"countries":1169,"tags":1170,"authors":1171,"images":1172,"translations":1173,"content":1174},[1099,1100],[969,971],[1105],[969,971],[1045],[1117,1125],[1127,1128,1129,1130],[1132],[],[],[],{"id":1176,"name":1177},879,"Money laundering",{"id":1128,"news_id":1179,"tags_id":1191},{"id":1091,"status":10,"user_created":404,"date_created":1092,"user_updated":61,"date_updated":1093,"title":1094,"type":1095,"body":1096,"image":1109,"date":1097,"topic":1180,"slug":1101,"activity":1181,"nid":1103,"topics":1182,"activities":1183,"programme":11,"area":11,"websites":1184,"translation_of":11,"language":11,"countries":1185,"tags":1186,"authors":1187,"images":1188,"translations":1189,"content":1190},[1099,1100],[969,971],[1105],[969,971],[1045],[1117,1125],[1127,1128,1129,1130],[1132],[],[],[],{"id":1192,"name":1193},1373,"Corruption prevention",{"id":1129,"news_id":1195,"tags_id":1207},{"id":1091,"status":10,"user_created":404,"date_created":1092,"user_updated":61,"date_updated":1093,"title":1094,"type":1095,"body":1096,"image":1109,"date":1097,"topic":1196,"slug":1101,"activity":1197,"nid":1103,"topics":1198,"activities":1199,"programme":11,"area":11,"websites":1200,"translation_of":11,"language":11,"countries":1201,"tags":1202,"authors":1203,"images":1204,"translations":1205,"content":1206},[1099,1100],[969,971],[1105],[969,971],[1045],[1117,1125],[1127,1128,1129,1130],[1132],[],[],[],{"id":4,"name":5},{"id":1130,"news_id":1209,"tags_id":1221},{"id":1091,"status":10,"user_created":404,"date_created":1092,"user_updated":61,"date_updated":1093,"title":1094,"type":1095,"body":1096,"image":1109,"date":1097,"topic":1210,"slug":1101,"activity":1211,"nid":1103,"topics":1212,"activities":1213,"programme":11,"area":11,"websites":1214,"translation_of":11,"language":11,"countries":1215,"tags":1216,"authors":1217,"images":1218,"translations":1219,"content":1220},[1099,1100],[969,971],[1105],[969,971],[1045],[1117,1125],[1127,1128,1129,1130],[1132],[],[],[],{"id":526,"name":527},[1223],{"id":1132,"news_id":1224,"authors_id":1236},{"id":1091,"status":10,"user_created":404,"date_created":1092,"user_updated":61,"date_updated":1093,"title":1094,"type":1095,"body":1096,"image":1109,"date":1097,"topic":1225,"slug":1101,"activity":1226,"nid":1103,"topics":1227,"activities":1228,"programme":11,"area":11,"websites":1229,"translation_of":11,"language":11,"countries":1230,"tags":1231,"authors":1232,"images":1233,"translations":1234,"content":1235},[1099,1100],[969,971],[1105],[969,971],[1045],[1117,1125],[1127,1128,1129,1130],[1132],[],[],[],{"id":1237,"name":1238,"position":11,"image":1239},550,"Dr Jacopo Costa","90469998-3598-471d-9499-48b19f557c7d",[],[],[],{"id":1244,"status":10,"date_created":1245,"date_updated":1246,"title":1247,"type":907,"body":1248,"date":1249,"topic":1250,"slug":1251,"activity":1252,"nid":285,"topics":1253,"activities":1254,"programme":11,"area":11,"websites":1255,"language":11,"image":1256,"translation_of":11,"countries":1266,"tags":1288,"authors":1303,"images":1304,"translations":1305,"content":1306},10384,"2023-08-07T16:01:34.000Z","2025-08-31T23:14:40.000Z","The Crown Resorts anti-money laundering fine: a wake-up call for the gambling industry","_A blog by Zisheng Xing, a law student at the Arizona State University who is undertaking a legal research internship at the Basel Institute on Governance._\n\nA monumental anti-money laundering fine recently dropped in Australia, sending shockwaves throughout the gambling industry – a sector well-known for flying under the radar of anti-money laundering and counter financing of terrorism (AML\u002FCFT) regulations.\n\nOn 11 July 2023, the Federal Court of Australia ordered the Australian gambling giant Crown Resorts (“Crown”) to pay an AUD 450 million (USD 300 million) fine for repeatedly violating the _Anti-Money Laundering and Counter-Terrorism Financing Act 2006_ (“AML\u002FCFT Act”) between 2015–2022. \n\nThe fine resulted from an agreement between Crown and Australia’s financial intelligence unit, AUSTRAC. This significant penalty is one of the largest in the gambling industry and serves as a severe reminder to casinos to implement and maintain effective AML\u002FCFT systems.\n\n### How did Crown breach Australia’s AML\u002FCFT Act?\n\nThe Australian Federal Court [found](https:\u002F\u002Fwww.judgments.fedcourt.gov.au\u002Fjudgments\u002FJudgments\u002Ffca\u002Fsingle\u002F2023\u002F2023fca0782) that Crown’s Melbourne and Perth casinos:\n\n*   failed to implement transaction monitoring programmes that were “appropriate to the nature, size and complexity of their business”;\n*   lacked “appropriate procedures to ensure higher risk customers were subjected to extra scrutiny” in their “enhanced customer due diligence” programmes;\n*   failed to conduct “appropriate ongoing customer due diligence on a range of specific customers who presented higher money laundering risks”;\n*   failed to maintain effective “risk-based systems and controls in their AML\u002FCFT programs”;\n*   failed to appropriately identify, timely assess and respond to ML\u002FTF risks they faced; and\n*   failed to establish appropriate frameworks for management oversight.\n\nWhen assessing the propriety of the penalty, the Federal Court concluded that Crown’s violations were “systemic, longstanding and egregious” and that they permeated “every designated service” that the enterprise provided its customers.\n\n### Risks posed by junkets\n\nA key finding of proceedings was that Crown had shown “a fundamental lack of regard” for the risk posed by junket operators. Junket operators are third parties who enter into agreements with casinos to facilitate gambling for high rollers. Junket operations often involve heightened AML risk, on the basis that they enable transfers of large amounts of money between jurisdictions. These transfers are administered in such a way that the source and ownership of funds involved can be easily obscured.\n\nMany of Crown’s contraventions were based on their relationship with such operations – even when the risks they presented were obvious. For example, AUSTRAC stated that Crown continued a “business relationship with a major casino junket operator” while “aware of allegations the operator was connected to organised crime.\"\n\nAdditionally, AUSTRAC noted at least 75 “suspicious incidents” involving approximately AUD 23 million in cash found in a private gaming room to which Crown Melbourne had given a junket operator exclusive access.\n\n### Why is this decision significant for AML\u002FCFT?\n\nAs [outlined](https:\u002F\u002Fwww.austrac.gov.au\u002Fnews-and-media\u002Fmedia-release\u002Ffederal-court-makes-ruling-crown-matter) by AUSTRAC, “the casino industry by its very nature, faces serious risks of exploitation by criminals seeking to launder the profits of their illicit enterprises.”\n\nConsequently, it is crucial that enterprises involved in this industry strictly implement and maintain strong AML measures and comply with relevant state laws. The penalty imposed on Crown is a clear warning to the entire gambling industry that its AML\u002FCFT compliance systems must be strong enough to meet obligations and “protect the… community and their businesses from serious financial crime.”\n\nThe decision also shows the importance of significant civil or administrative sanctions to enforcing compliance. As highlighted in our [quick guide to money laundering through the gambling industry](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-28-money-laundering-through-gambling-industry), proportionate penalties such as these both deter future breaches and encourage casinos to invest in robust AML\u002FCFT programmes.\n\n### Learn more\n\n*   View our [quick guide](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2022-09\u002FQG28%20gambling.pdf) to money laundering through the gambling industry by Isys Lam and Andrew Dornbierer.\n*   For more on money laundering risk assessment more generally, see the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F) – the Basel Institute’s flagship index of money laundering and terrorist financing risks around the world.","2023-08-07",[859],"the-crown-resorts-anti-money-laundering-fine-a-wake-up-call-for-the-gambling-industry-2496",[374],[859],[],[1045],{"id":1257,"storage":47,"filename_disk":1258,"filename_download":1259,"title":1247,"type":872,"created_on":1260,"modified_on":1261,"charset":11,"filesize":1262,"width":1263,"height":1264,"duration":11,"embed":11,"description":11,"location":11,"tags":11,"metadata":1265,"focal_point_x":11,"focal_point_y":11,"tus_id":11,"tus_data":11,"uploaded_on":1261},"4ba38771-e903-4845-9203-549526518d27","4ba38771-e903-4845-9203-549526518d27.webp","Alex Proimos from Sydney, Australia, via Wikimedia Commons.webp","2025-05-12T21:11:43.000Z","2026-05-06T07:35:09.000Z",238556,1600,1067,{},[1267],{"id":1268,"news_id":1269,"countries_id":1282},7170,{"id":1244,"status":10,"user_created":404,"date_created":1245,"user_updated":62,"date_updated":1246,"title":1247,"type":907,"body":1248,"image":1257,"date":1249,"topic":1270,"slug":1251,"activity":1271,"nid":285,"topics":1272,"activities":1273,"programme":11,"area":11,"websites":1274,"translation_of":11,"language":11,"countries":1275,"tags":1276,"authors":1278,"images":1279,"translations":1280,"content":1281},[859],[374],[859],[],[1045],[1268],[1277],5706,[],[],[],[],{"id":1283,"name":1284,"code":1285,"latitude":1286,"longitude":1287},14,"Australia","AU",-25.2744,133.77515,[1289],{"id":1277,"news_id":1290,"tags_id":1302},{"id":1244,"status":10,"user_created":404,"date_created":1245,"user_updated":62,"date_updated":1246,"title":1247,"type":907,"body":1248,"image":1257,"date":1249,"topic":1291,"slug":1251,"activity":1292,"nid":285,"topics":1293,"activities":1294,"programme":11,"area":11,"websites":1295,"translation_of":11,"language":11,"countries":1296,"tags":1297,"authors":1298,"images":1299,"translations":1300,"content":1301},[859],[374],[859],[],[1045],[1268],[1277],[],[],[],[],{"id":4,"name":5},[],[],[],[],36,{"items":1309,"total":1310},[],0,1780676624492]