Asset recovery
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Asset recovery postgraduate programme: Celebrating our first graduating cohort
How and where can a professional acquire specialised knowledge in asset recovery? A year ago, that question didn’t have an easy answer. Today, it does: with the postgraduate programme "CAS Combating Financial Crime Through Asset Recovery", offered by the Basel Institute on Governance and the University of Basel. This July, we were delighted to welcome the first cohort to our headquarters in Basel and host the 1.5-day hybrid closing event. Here are a few highlights from the programme, and what participants themselves had to say about their experience. A programme unique in its class This Certificate of Advanced Studies CAS was developed to address a longstanding gap in postgraduate education. While aspects of asset recovery are covered in some university courses, there has until now been no similar qualification combining academic learning with practical skills. The programme draws on more than two decades of experience from our International Centre for Asset Recovery ICAR , which has worked with authorities around the world to strengthen financial investigations, asset recovery and international cooperation. Graduates receive a CAS degree from the University of Basel, one of Switzerland's leading universities. A global classroom The first cohort brought together prosecutors, investigators, lawyers, anti-money laundering specialists, development practitioners, bankers and policy professionals from 10 countries across Africa, South America, Asia and Europe. The online format with live sessions helped make that possible. It gave participants the flexibility to join from anywhere in the world and balance the course with their day-to-day work – and, just as importantly, to connect with peers working under completely different legal systems. That’s exactly the kind of contact that matters for international cooperation. As one participant from Europe explained: The exchange with other participants working in different jurisdictions was extremely valuable. That was crucial for seeing how asset recovery is approached differently elsewhere, and what options other jurisdictions have. Asset recovery is a global issue now – money moves across the world, so you can't just sit in your office thinking everything stops at the border. The cohort also spanned different levels of expertise, from prosecutors to lawyers working in cybercrime to people just entering the field. As another participant, who works in development cooperation, explains: After having worked for two decades in development cooperation, I realised that if less money was lost to financial crime, countries could decide more autonomously where to invest in their own development. So I got interested in the topic of money laundering, and how we could get better at fighting it. Learning by doing When we asked participants what they found most valuable or unique about the programme, the answer was always the same: its practical approach. Asset recovery is a complex discipline that spans financial investigations, international cooperation, prosecution and the management and return of confiscated assets. Professionals working in this field need not only legal knowledge, but the practical skills that can be applied across different jurisdictions and institutional settings. Over six months, the cohort engaged in interactive online sessions built around real cases and realistic simulated investigation exercises, guided by practitioners who have investigated and prosecuted financial crime themselves. A participant from Uruguay explains: In most certifications, the focus tends to stay on theory and definitions, spending a lot of time discussing ethical and regulatory issues. But in this case, it was so case-specific and applied that by the end, you know what you have to do, you know how to investigate and you know the steps for asset recovery. The final project: a professional opportunity That practical focus culminates in the personal project each participant is now completing in order to graduate: a chance to advance a project from their own work, a side interest or simply an area they want to explore in more depth. One participant is taking the programme to build up a specialised Asset Recovery Office within the Ministry of Justice. It tackles the problem that currently, competence is split between the prosecutor's office and the police, and neither magistrates nor police officers have the same view of the data. Another participant is working on a proposal to bring public-private collaboration to her country's asset recovery efforts. She noticed a clear gap: information that should flow between the two sectors simply wasn't being exchanged. Throughout the programme, she tested her model with instructors, refining it with their feedback. Her final project now sets out how that collaboration could actually work in practice. Discussing future career steps The closing event was also a chance to look ahead to the careers and opportunities this certificate can open. An exclusive panel discussion showcased the breadth of career paths in combating financial crime, bringing together experts from international organisations, the public sector and private industry. The panel featured Kodjo Attisso Coordinator of the Illicit Finance Fusion Center – Africa at UNODC , Federica Maschera Group Financial Crime Engagement Manager at HSBC Holdings plc , Pedro Gomes Pereira Advisor on Anti-Corruption and Asset Recovery and Maria Schnebli Federal Prosecutor at the Office of the Attorney General of Switzerland . The panellists shared their career paths and challenges in the various sectors, and the steps they took to get to their current affiliations. Maria Schnebli also gave a keynote speech on international collaboration and the challenges of combating financial crime from a Swiss prosecutor's perspective. This tied in perfectly with the work the students had done throughout the course. The Gretta Fenner Scholarship Fund Some students in this cohort could only take the course thanks to financial support. We launched the Gretta Fenner Scholarship Fund to help cover tuition costs for talented professionals from low-income backgrounds. We have received, and continue to receive, generous donations from organisations and individuals alike. Julio Petrucci, a prosecutor at the Attorney General's Office of the Province of Buenos Aires, Argentina, was one of the participants who benefited. As he puts it: To donors and benefactors, I would say that your contribution isn't just individual support for one student – it's a direct investment in justice across our countries. Thanks to your contribution, I now have the tools to investigate complex crimes and recover assets that belong to society. We are deeply grateful to our donors for making these opportunities possible, especially the International Academy of Financial Crime Litigators, Bonifassi Avocats, Bennett Jones, ECO Strategic Communications and Kellerhals Carrard. Another way to build capacity As the first cohort prepares to graduate, the programme marks another step in the Basel Institute's efforts to strengthen global capacity to investigate financial crime, recover stolen assets, and build a new generation of practitioners connected through a worldwide community of practice. Along with our second postgraduate programme, “CAS Mastering Today’s Anti-Corruption Challenges”, it marks our current portfolio of practice related academic programmes to support careers, knowledge and skills development of talented international professionals and practitioners. Congratulations to all the participants of this first cohort. Learn more ::: links - Discover “Combating Financial Crime Through Asset Recovery” - Postgraduate programme delivered online in partnership with the University of Basel. - Contribute to the Gretta Fenner Scholarship Fund - Help train the next generation of anti-corruption professionals. - Discover our offer of short online training courses - Practitioner-led training focused on real-world financial crime challenges. :::
Six new certified trainers will scale financial investigation and asset recovery capacity in Romania
As part of a wider Swiss-Romanian Cooperation Programme, our International Centre for Asset Recovery ICAR has concluded a successful nine-month train-the-trainer TTT programme in Bucharest. Alongside delivering foundational money laundering and asset recovery training to 125 practitioners in total, the programme has certified six new local trainers. Equipped with ICAR’s unique training methodology, they are now ready to independently train their peers and help strengthen financial investigation and asset recovery capacity across Romania. Building sustainable national capacity The six trainers certified through the programme include one judge, four prosecutors and one representative of the National Agency for the Management of Seized Assets ANABI . Fully independently, they will now deliver a further 15 workshops across the country. This effort will effectively bring the total number of practitioners trained to around 500, including judges, prosecutors, specialists, ANABI inspectors and other relevant practitioners. This is a clear example of how train-the-trainer programmes are a proven approach to building sustainable national capacity. On one side, certified local trainers help ensure that knowledge and skills continue to be transferred even after a programme concludes. On the other side, participants benefit far more from learning from peers who understand their specific challenges and possibilities. Two critical legal tools in focus This time, the programme placed particular emphasis on two areas where practitioners can strengthen their response to financial crime: treating money laundering as a standalone offence and launching financial investigations from the earliest stages of a case. 1. The standalone money laundering offence A persistent challenge in money laundering investigations is the assumption that prosecutors must first prove or secure a conviction before pursuing money laundering charges. Under the Council of Europe's Warsaw Convention CETS No. 198, Art. 9 and EU Directive EU 2018/1673 on combating money laundering by criminal law, a conviction for money laundering actually requires neither a prior nor a simultaneous conviction for the predicate offence, nor that the predicate offence be established or identified with precision: prosecutors need only show that the property derives from criminal activity, not which specific crime generated it. As one of the newly certified trainers reflected: I highly valued the new perspective of setting aside the old view of placement, layering and integrating the proceeds of a crime in order to prove money laundering. … It was very useful the approach of covering as many areas as possible impacted by money laundering, like crypto assets, which I did not know almost anything about before, and asset recovery, which is not a topic very much considered in our practice. I was also very impressed how the concept of multi-stakeholder approach in fighting ML was reflected in setting up the groups for the practical exercise. 2. Systematic use of parallel financial investigations Another important approach is the systematic use of parallel financial investigations to identify and trace criminal assets from the outset of a case. This approach is now required under Directive EU 2024/1260 on asset recovery and confiscation, which obliges Member States to launch asset-tracing investigations alongside criminal investigations into high-revenue-generating crime, rather than waiting for a conviction before tracing assets. This shift is already visible in practice. One trainer wrote: I started talking to my colleagues about financial investigations and money laundering. I managed to send to court my first money laundering case, though not standalone, and I also started asking the police to start financial investigations from the beginning of the file. From training to real cases The effect of our training has also reached institutional level. One trainer reported: The management has started disseminating theoretical and practical materials on these topics, organising meetings and training sessions with practitioners and academics, and actively encouraging prosecutors to consider money laundering and asset recovery aspects in their cases. These initiatives have facilitated increased awareness and engagement within the institution. This is exactly the dual impact we seek through the Train-the-Trainer model: a sustainable, independently delivered training capacity, paired with a genuine shift in how practitioners approach financial investigations in their daily work and how their institutions prioritise it. With the first independently delivered workshops planned for September 2026, our ICAR training team looks forward to following the six newly certified trainers and seeing their work generate further impact across Romania. About the programme This TTT was part of the Component 3 of a larger Swiss-Romanian Cooperation Programme Strengthening the institutional capacity in the area of financial investigations and asset recovery FIARS . This component is implemented by the Prosecutor’s Office attached to the High Court of Cassation and Justice PICCJ as component operator, in partnership with the National Institute of Magistracy INM and the Basel Institute on Governance as the Swiss partner.
Q&A: Why civil society and journalists need asset recovery skills – and how they can gain them
Investigative journalists and civil society organisations are often the first to uncover corruption, suspicious financial flows and hidden assets. But turning those discoveries into successful financial investigations and recovered assets requires specialised knowledge that many practitioners have never had the opportunity to acquire. To help bridge this gap, the Basel Institute's International Centre for Asset Recovery ICAR has developed a new training course on Asset Recovery for Civil Society and Journalists. Combining practical exercises, open-source intelligence techniques and a realistic corruption case simulation, the course equips participants with a deeper understanding of how assets are traced, investigated and ultimately recovered. In this Q&A, ICAR trainers Tom Walugembe and Emmanuel Mringo explain why the training was developed, what makes its approach distinctive, who it is designed for and the impact they hope participants will have after completing it. What specific gap or need led to the development of this course for civil society and investigative journalists? In the past two decades we have seen major financial crime scandals, such as the Panama and Pandora Papers leaks, in which efforts by organisations like the International Consortium for Investigative Journalists ICIJ and the Organised Crime and Corruption Reporting Project OCCRP have led to financial crime investigations and prosecutions. Yet in many parts of the world, journalists and other non-state actors like civil society organisations CSOs are under-equipped with the knowledge of asset recovery processes needed to carry out their core work effectively. For CSOs, that often includes advocacy for policy reform. For journalists, it means evidence-based investigative reporting, as well as the skills to trace illicit financial flows, understand money laundering typologies and gather actionable information whose exposure can trigger financial investigations and lead to the recovery of stolen assets. There is international recognition of their importance in the fight against corruption – e.g., Article 13 of the UN Convention Against Corruption, which requires state parties to take measures to promote the participation of CSOs and individuals in the fight against corruption. But when it comes to investigating and recovering proceeds of corruption, there is little or no targeted training to enable CSOs and journalists to play this role effectively. We developed the course to address these capacity gaps. How does this course fit within and complement ICAR’s wider training and learning offer? This course complements ICAR’s broader training portfolio by broadening its traditional audience. ICAR training programmes focus heavily on law enforcement agencies, prosecutors, financial intelligence units and judicial authorities. This new module extends ICAR’s reach to non-state actors while aligning with ICAR’s uniquely effective methodology and offerings. It also integrates with Basel LEARN, the Basel Institute’s online learning platform, which enables blended learning and pre-course preparation. The course emphasises core ICAR themes, including parallel financial investigations, international cooperation, and asset tracing, freezing and confiscation. And ICAR’s postgraduate programmes on asset recovery? Unlike the ICAR-led Certificate of Advanced Studies CAS programme on Combating Financial Crime Through Asset Recovery, this is a short professional training course rather than a university-accredited academic programme. The CAS programmes, delivered in partnership with the University of Basel, run over six months and require around 300 hours of study. By contrast, this course provides a focused, accessible introduction to asset recovery concepts and practical skills. The aim is to enable individuals to strengthen their contribution to transparency, accountability and anti-corruption efforts without the substantial time commitment of a postgraduate programme. What makes the course’s approach – especially the use of a simulated case and OSINT –distinctive for this audience? Like other ICAR training modules, the course focuses on developing practical skills through the “learn by doing” methodology. Participants do not simply learn theoretical concepts in a classroom setting. Working in teams, they conduct a simulated corruption and money laundering investigation. They learn to follow financial trails wherever they lead, through layers of international banking transactions and the misuse of offshore shell companies. As this audience of CSOs and investigative journalists lacks investigative powers such as accessing bank accounts or searching premises , the course emphasises alternative methods for securing information that could trigger or support financial investigations. These include using access to public information laws and open-source intelligence OSINT . What kind of real-world impact do you realistically hope participants will have after completing the training? First, better investigations. Individuals who complete the course will gain stronger OSINT skills to effectively gather information on financial crime and illicit assets. They will have broader knowledge to detect modern bribery and money laundering schemes. They will understand anti-money laundering frameworks and the meticulous process of conducting financial investigations. They will have greater capacity to analyse financial records, such as bank statements, company documents and procurement records. Second, more objective reporting. The course will expose participants to the practical challenges of financial investigations and asset recovery, including capacity gaps, asset management and slow international cooperation. This will lead to, among other things, more objective press reporting on financial crimes and asset recovery cases. Third, a stronger accountability role. Upon completing the course, participants will also have the broader knowledge needed to report on and follow up on the reuse of recovered assets, ensuring they are used effectively. Fourth, a stronger network. The course will provide a platform to foster better cooperation among CSOs, investigative journalists and law enforcement agencies. It will also foster regional and international cooperation among CSOs and Investigative Journalists. Our dream? That CSOs and journalists go from being external observers and reporters to complementary actors who ensure that financial investigations are effective and transparent, and that stolen assets are quickly detected, traced, seized, well-managed, confiscated, repatriated and deployed to achieve sustainable development. Ambitious, but essential to making a dent in the corruption and financial crime that hinder development and prosperity worldwide. Interested in bringing this training to your organisation or network? The Asset Recovery for Civil Society and Journalists course can be delivered either onsite or online for booked groups of approximately 25–30 participants. It is suitable for national, regional or international audiences and can be tailored to specific contexts and learning needs. For individuals, the course is also offered online as an open enrolment programme, allowing participants from anywhere in the world to join. To learn more or discuss delivery options, contact training@baselgovernance.org.
How will the EU Anti-Corruption Directive affect enforcement against corruption?
What does the EU's new Anti-Corruption Directive actually change, and where does it fall short? This article by Rita Simões of the Basel Institute’s International Centre for Asset Recovery takes a closer look at the final text. She looks at what was adopted, what was left out during negotiations, and what the final text is likely to mean for enforcement across the EU. For a broader reflection on what the directive reveals about changing corruption risks and the future direction of EU anti-corruption policy, see a companion analysis by Dr Jacopo Costa. The European Union EU has adopted and published its Anti-Corruption Directive, concluding a process that began with the Commission’s proposal in May 2023. Its adoption comes amid a broader recalibration of global anti-corruption enforcement, marked by decreased U.S. leadership through the scaling back of Foreign Corrupt Practices Act enforcement and increased expectations for the EU to assume a more central role in global anti-corruption efforts. Following a lengthy negotiation period, the final directive is a compromise between the widely differing levels of ambition reflected in the proposals put forth by the European Parliament and European Commission. It establishes a common baseline of corruption offences, corporate liability rules and jurisdiction, but leaves member states significant discretion to limit the scope of new measures. The final version also omits key provisions relating to political financing, non-trial resolutions and victims’ rights. Therefore, the directive's central achievement is the harmonisation of anti-corruption offences and sanctions. Its central limitation is that it leaves key aspects of enforcement practice largely in the hands of member states. Important changes in criminal law, liability and jurisdiction The directive establishes a detailed enforcement and prevention framework. It requires member states to, among others: - create independent anti-corruption bodies; - adopt national strategies; - conduct sector-specific risk assessments; - provide training for officials; and - use Europol’s SIENA system for information exchange. These measures are complemented by harmonised statistical reporting obligations on investigations, prosecutions and sanctions. On substantive criminal law, the directive introduces a harmonised baseline of corruption offences across member states including domestic and foreign bribery, trading in influence, misappropriation, abuse of functions and obstruction of justice. The directive also requires member states to establish a broad criminal liability regime for legal persons . Under this framework, companies can be held accountable for corruption offences, including those resulting from lapses in senior management supervision. Notably, the directive reinforces this regime through obligating the use of dissuasive measures, such as fines based on global turnover and exclusion from public procurement. The directive also strengthens jurisdictional rules. Member states must assert jurisdiction over offences committed on their territory or by their nationals. Furthermore, a member state can prosecute offences committed abroad without needing the state where the crime occurred to report it first. . How these could help enhance anti-corruption enforcement These measures aim to strengthen the EU’s enforcement capacity by expanding the legal tools available to investigate and prosecute corruption, particularly in cross-border cases. Measures on corporate liability, for instance, will strengthen the ability of member states to address complex bribery schemes involving multinational structures. Similarly, the enhanced jurisdictional rules will enable member states to pursue corruption cases that occurred outside their territory, even where the state in which the corruption took place is unwilling or unable to act. In addition, the institutional and procedural framework – particularly coordination, risk assessments and dedicated enforcement bodies – should strengthen the EU’s ability to prevent, detect, investigate and prosecute corruption. However, enforcement effectiveness will still depend heavily on national implementation capacity and political will. Three missed opportunities: political financing, non-trial resolutions and victim participation Previously identified as areas of significant potential, several key measures proposed by the European Parliament that could have further enhanced enforcement were excluded or significantly watered down in the final directive. Political financing The European Parliament had proposed stronger measures to tackle illicit political financing, including enhanced transparency requirements and potential criminalisation of certain violations. However, member states are only encouraged – not required – to address risks linked to political funding, with no binding obligation to implement transparency measures or criminalise political financing. This leaves the EU without a harmonised framework in this area. This is a critical gap given growing concerns about how illicit funding can distort electoral processes and enable undue influence over public decision-making, both globally and at the European level653631 EN.pdf . Non-trial resolutions Proposed mandatory frameworks for non-trial resolutions in cases involving legal persons, reflecting established practice in jurisdictions such as the United Kingdom, were not retained as binding obligations in the final directive. As a result, this instrument does not establish a level playing field across the EU. This is likely to lead to divergent enforcement approaches, with some jurisdictions relying on negotiated resolutions while others depending on full criminal proceedings. Such fragmentation may weaken the effective imposition of financial sanctions on companies, as well as the recovery of proceeds and their use for compensating victims of corruption or enhance anti-corruption efforts. Victim and public participation in corruption cases The final version of the directive requires member states to grant procedural rights to victims and members of the public affected by corruption offences. But it largely relies on existing EU frameworks and national law, providing participation rights only where they already exist domestically. By contrast, the European Parliament’s proposal was more ambitious: it sought to define these categories explicitly, regulate their procedural rights and grant victims a clear right to compensation. As a result, recognition of victims in corruption cases remains uneven across member states. This approach also may limit victim and civil society participation, despite growing international support for more participatory approaches. Anti-corruption ambition is now up to member states The directive adopts an anti-corruption approach that strengthens enforcement powers while maintaining deference to national legal systems. Its effectiveness will depend heavily on implementation, particularly where it sets only minimum standards or leaves room for national discretion. In practice, this is likely to produce uneven legal frameworks across the EU, shaped more by domestic political will than by EU-led harmonisation. Member states implementing the directive will face a choice: - Should they adhere to the minimum requirements only? - Or take the opportunity to pursue more ambitious anti-corruption reforms, including some of the broader measures originally proposed by the European Parliament? Choosing a more ambitious approach presents an opportunity to lead by example and influence future EU reform.
Basel Institute joins regional effort to strengthen security, justice and development in Latin America
Reducing the economic power of organised crime is essential to improving security, strengthening justice systems and supporting sustainable development across Latin America and the Caribbean. And doing that requires strong and dependable partnerships. Building on more than a decade of support to authorities across the region, the Basel Institute on Governance has formally joined the Alliance for Security, Justice and Development, a regional initiative led by the Inter-American Development Bank IDB . The Alliance seeks to strengthen coordinated responses to organised crime in Latin America and the Caribbean through dialogue, cooperation, knowledge exchange and resource mobilisation. Supporting the fight against illicit financial flows For the Basel Institute and its International Centre for Asset Recovery ICAR , participation in the Alliance represents a further opportunity to contribute its expertise in financial investigations, asset recovery, international cooperation and public financial management while working alongside governments, international organisations and other partners committed to strengthening security, justice and development across the region. Executive Director Elizabeth Andersen signed the declaration formalising the Basel Institute’s participation in the Alliance in Washington, D.C. The signing followed close engagement between senior IDB and Alliance representatives and Oscar Solórzano, Head of ICAR Latin America. Strengthening regional cooperation The Alliance for Security, Justice and Development is a regional platform for dialogue, cooperation, knowledge exchange and resource mobilisation aimed at preventing and responding to organised crime in Latin America and the Caribbean. Coordinated by the IDB through its Citizen Security Division, the Alliance currently brings together 23 member states and multiple strategic partners from the international, development and security sectors. Its work is structured around three strategic pillars: protecting vulnerable communities from organised crime and violence; strengthening institutional resilience within security and justice systems; and reducing illicit financial flows and illicit markets to weaken the operational capacity and influence of criminal organisations. Bringing expertise in asset recovery and financial investigations The Basel Institute will contribute particularly to the third pillar, leaning on the expertise and two decades of experience of its specialised International Centre for Asset Recovery ICAR . Elizabeth Andersen stated that the Basel Institute is honoured to participate in such a high-level initiative focused on issues of critical importance for Latin America and the Caribbean, as well as for the broader international community. Oscar Solórzano highlighted that the Alliance represents an important opportunity to support countries in strengthening asset recovery systems, international cooperation and institutional capacities against increasingly sophisticated forms of organised crime and illicit economies. Building on a decade of support in Latin America Our participation builds on more than a decade of operational and technical support to authorities across Latin America in areas including financial investigations, asset recovery, international cooperation and – through a dedicated programme – public financial management. Activities under the Alliance framework are expected to begin in the region in the coming months, with our teams supporting key initiatives and technical workstreams developed through the Alliance in the years ahead. Our participation reflects our longstanding commitment to helping countries tackle corruption, illicit financial flows and organised crime, and our belief that sustainable impact is achieved through strong partnerships that bring together public authorities, international organisations and practitioners around shared goals.
Publications
La extinción de dominio en el marco de los estándares e instrumentos internacionales
Case Study 13: The Beauty Queen case: non-conviction based forfeiture across borders
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 International Academy of Financial Crime Litigators, Andrew Dornbierer explores the revival of unexplained wealth orders (UWOs) in the United Kingdom.
Introduced 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.
In 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.
This 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.
This 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.
Quick Guide 41: Managing seized and confiscated assets
This Quick Guide explains why effective, transparent and fair management of seized and confiscated assets – including assets linked to sanctions violations – is essential to successful asset recovery. It introduces key principles, standards and practical steps based on international good practice. These include legal, institutional and technical arrangements, that help countries manage seized assets in a way that preserves value, ensures accountability and supports justice.
The Guide is primarily intended for government officials working in law enforcement, justice and asset recovery. It may also be useful to policymakers and development partners seeking a better understanding of how countries can improve their asset management systems.
About this Quick Guide
You are free to share and republish this work under a Creative Commons BY-NC-ND 4.0 Licence. It is part of the Basel Institute on Governance Quick Guide series, ISSN 2673-5229.
Working Paper 55: Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms
The UK is a global leader in its efforts to target foreign bribery. It is one of the only countries worldwide to use negotiated settlements such as deferred prosecution agreements (DPAs) to resolve cases and extract penalties from corporations that commit corruption abroad. The UK has also laudably committed to using the proceeds of DPAs in foreign bribery cases to compensate the victims of corruption, particularly in countries that suffer its worst effects.
This paper explores why the UK’s policy of compensating the victims of foreign bribery is not achieving its intended results in practice, and proposes realistic suggestions for improvement to the extant DPA regime.
It examines the conceptual, practical and political difficulties inherent in this undertaking, shining a light on how victim compensation operates in the UK and analysing judicial decisions on this issue. Finally, the paper proposes reform recommendations to strengthen the DPA regime to ensure appropriate compensation is made in foreign bribery settlements.
About this report
The paper is published as part of the Basel Institute on Governance Working Paper series, ISSN: 2624-9650. You may share or republish it under a Creative Commons BY-NC-ND 4.0 International Licence.
The paper is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
Suggested citation: Hickey, Sam. 2025. ‘Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms.’ Working Paper 55, Basel Institute on Governance. Available at: baselgovernance.org/publications/wp-55.
A version of this paper is also published by the Transnational Criminal Law Review.