Asset recovery
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Holding the corrupt to account: the promise and potential of corruption sanctions
When states fail to hold corrupt actors to account, ordinary citizens pay the price. Corruption sanctions were born from the idea that no one should be above the law, no matter where they are in the world. In a new Working Paper, Dr Anton Moiseienko explores how these tools have evolved and offers recommendations for their more effective and legitimate use. Here we share the foreword to his paper by the Basel Institute's Andrew Dornbierer, Head of Policy and Research, International Centre for Asset Recovery. Foreword Every state has an obligation to investigate and prosecute corruption within their jurisdiction. Unfortunately, many states around the world are not willing to fulfil this responsibility. As a result, the very individuals within these states tasked with serving the public interest are instead given free rein to commit acts that not only serve themselves but also corrode the fabric of the state. And ordinary citizens have no alternative but to endure the ensuing economic and social damage. The development of sanctions tools targeting corruption stemmed from the idea that justice should be universal; that no one in any society around the world should be above the law. They are powerful tools, built on powerful principles. States introducing them understand that unchecked corruption will always suffocate a state’s ability to provide security, fairness and prosperity to its citizens. Comparatively though, corruption sanctions are still an underdeveloped concept and are far from perfect. Only a handful of states have introduced them, and those that have are not often using them to their full potential. They also spark valid concerns surrounding due process. These criticisms shouldn’t be ignored: they offer an insight on how these tools could be further developed and enhanced to ensure that they are more credibly and consistently applied. In his paper, Anton Moiseienko provides an excellent and well-researched overview of how corruption sanctions could be designed and employed to better achieve their potential. He explains how these tools have evolved over the last two decades and how they could be further refined to be more effective and achieve a wider range of impact. Critically, his paper is an indispensable resource for those looking to understand exactly how such sanctions can help states deter, disrupt and debilitate the notoriously corrupt that are unreachable through standard criminal justice tools. Learn more Read Dr Anton Moiseienko’s Working Paper “Corruption sanctions: What governments need to know” for a deeper analysis of the topic and key policy recommendations. Get a brief introduction to corruption sanctions from our related Quick Guide. Register for our public webinar "Corruption sanctions – reaching those beyond the law" on 18 June 2026, marking the launch of Dr Moiseienko's Working Paper.
Professor Anne Peters on how anti-corruption organisations can survive in today’s volatile world
Professor Anne Peters, a renowned scholar of international law and governance, stepped down from her role as Vice President of the Basel Institute on Governance at the end of 2025. In this Q&A she looks back at her involvement with the Basel Institute since its inception more than 23 years ago. Her insights emphasise the importance of underpinning anti-corruption and governance efforts with interdisciplinary academic research, and of connecting abstract concepts like governance and asset recovery to real-world challenges like human rights, biodiversity and climate change. She traces the Basel Institute’s path from a small group of friends driven by individual passion to a highly professional, global centre of expertise on anti-corruption and asset recovery. This professionalism, she says, is essential for non-profit organisations to survive and even thrive in today’s unstable new world. Anne is known for her pioneering work on animal rights, human rights and corruption. She holds long-standing academic positions as Director of the Max Planck Institute for Comparative Public Law and International Law MPIL Heidelberg and Professor of International Law at the University of Basel. You were a part of the Basel Institute from the beginning. How did it all start? My engagement with the Institute took root when I joined the University of Basel in 2001 and met Professor Mark Pieth, the Institute’s founder and former President. He was involved in establishing the Wolfsberg Group, an early multi-stakeholder initiative of banks focused on developing anti-money laundering guidelines. This was a time when concepts like banking due diligence and know-your-customer were relatively unknown, and the idea of multi-stakeholder associations didn’t even exist. Because of Mark Pieth’s personal standing as a Professor of Criminal Law at the University of Basel and as Chair of the OECD Working Group on Bribery, he received requests for advisory and consultancy services on problems of corruption and governance. The Basel Institute gradually rose out of those beginnings, helped by individuals like Gemma Aiolfi and Thomas Christ, who continued to play key roles at the Institute for the next two decades. Back then we used to meet in cafés or in Mark’s office, and we just had a letterhead and a flyer describing the Basel Institute on Governance. Things became more formalised when we received seed funding from a foundation, drafted statutes and – this was the game-changer – hired Gretta Fenner in 2005. Gretta was the first paid staff member. We miss her dearly. What excited you about it? What did you bring from the academic world? I was young, I had energy and I liked Mark as a colleague and friend. The concept of governance was also quite new and exciting. I am a public international lawyer, not a criminal lawyer, so I had little technical expertise in corruption or money laundering. But since these crimes have clear transnational dimensions, my background in international law made sense. I was able to bring the academic perspective to the Institute’s work, later reinforced by Lucy Koechlin and Claudia Baez Camargo, who joined to lead research on public and global governance. The association with the University of Basel was crucial. It gave structure to the original idea: providing practical advice and assistance on corruption and governance, grounded in academic research. An important aspect was financing doctoral students who would work at the Basel Institute while completing their PhDs. I supervised three such dissertations. This academic underpinning and insistence on research and evidence is still one of the Basel Institute’s strongest points. What other milestones and innovations do you remember? A major academic milestone was our conference on non-state actors and the resulting book, Non-State Actors as Standard Setters , which was published with Cambridge University Press in 2009. The term “non-state actor” – covering the private sector as well as non-profit organisations, academia, the media and the like – was still novel. I co-edited the book with Gretta Fenner, Lucy Koechlin and our former Board colleague and social anthropologist Till Förster. It was a serious and influential publication that is still cited today. I remember us retreating for a full day to review drafts. At first the mix of different writing styles and perspectives – political science, law, social anthropology and sociology – was a bit of a shock. Then we realised the value of this interdisciplinary nature in helping to gain a holistic perspective of how non-state actors can contribute to setting governance standards in the messy world of real life. Again, this interdisciplinary approach remains central to the Basel Institute’s current work. How did the Basel Institute’s work expand into so many different areas – from asset recovery to conflicts of interest, to money laundering in the art market. What’s the connection? Personal interests, reputations and networks mattered greatly. And new concepts were appearing in the international anti-corruption arena. People and governments needed help working out how to apply them in practice in different contexts. That’s what happened with asset recovery, a concept that appeared in the 2003 UN Convention Against Corruption with the aim of depriving corrupt actors of their criminal gains. We developed a distinct workstream at the Basel Institute that soon became the International Centre for Asset Recovery. The concept and practice of Collective Action – sustained, trust-based multi-stakeholder collaboration with the private sector to address specific corruption challenges – evolved in large part thanks to our colleague Gemma Aiolfi’s tireless efforts. Similarly, it was a personal interest that led myself and fellow board member Lukas Handschin to edit a book on Conflict of Interest in Global, Public and Corporate Governance published by Cambridge University Press. It’s a topic that I was convinced was underappreciated at the time and is now, in these current times, showing its importance. We did early work on money laundering in the art market. Again this was a personal interest of our board member Thomas Christ that is now a key concern for not only money laundering but sanctions evasion. A newer area we have helped to establish internationally is green corruption, i.e. applying anti-corruption and governance tools to address challenges like the mass extinction of species, biodiversity decline, the climate crisis. This is a topic that is dear to me personally and that is evolving fast. Common to this all is how the Basel Institute applies anti-corruption and governance research and tools to different fields that really matter in the world, from business to health to environmental protection. And human rights? How does that connect to corruption? My interest in the intersection between corruption and human rights grew from Gretta’s involvement in several side events at the UN Human Rights Council in Geneva. I began thinking about legal relationships between corruption and human rights and whether, for example, states have a human rights obligation to protect citizens from corruption. I wrote a Working Paper on the topic for the Basel Institute back in 2015 and later published two academic papers. You can get a short overview of the topic in this Quick Guide to corruption and human rights. The Office of the High Commissioner for Human Rights UN Human Rights references my work in a recently published practical guide on corruption and human rights to which I contributed, as well as other work of the Basel Institute on human rights in the context of asset recovery laws. It’s great to see our scholarly work being used to underpin practical international guidance that will ultimately have impact on people’s lives. What does the current global context mean for anti-corruption efforts and organisations like the Basel Institute? We are in a period of profound global change. The political order is fundamentally shifting and the optimism of the 1990s is all but gone. The United States, an early driver of international anti-corruption treaties, efforts and successes, is retreating from its role. In some countries, anti-corruption laws and campaigns are misused for political purposes. Even if concepts like good governance, rule of law, human rights and democracy don’t seem to be en vogue right now, they remain important. Not least because they, and corruption, are key to understanding and tackling today’s toughest challenges, from poverty and inequality to crime and conflict. So non-profit organisations like the Basel Institute are more essential than ever, as are other non-state actors dedicated to tackling corruption and governance challenges. But it’s not easy for small organisations to survive in this rocky world, and many face their own governance challenges. That’s why it’s good that the Basel Institute has professionalised its governance and compliance structures over the years, while keeping the sense of passion and personal conviction that characterised its early years. Any bright side for those who care about anti-corruption and governance? On the positive side, public awareness, opposition and global debate about corruption is far stronger than in the past. And much of international law – on travel, transportation, communication, diplomatic relations etc. – functions quietly and effectively every day. Despite how dire the current situation seems, change for the better has only ever occurred after major catastrophes. For example, the establishment of the International Criminal Court in 1998 was a direct result of the rape camps and the Srebrenica massacre in Bosnia and Herzegovina. The question is how severe crises must become and how much they must affect people directly before meaningful reform occurs. Climate change, biodiversity loss and pollution, for example, are slow-moving crises that still feel abstract to many. What’s coming up for you personally? In my research I remain focused on the big-picture development of the international legal order. I look forward to the publication in 2026 of the Oxford Handbook of Global Animal Law , which I co-edited and which seeks to authoritatively establish this fairly new field of international law. Alongside my research I continue to advise the German Foreign Affairs Department and sometimes the Swiss, too , and will serve as an expert witness on international legal questions in a case before a domestic court. And, of course I will continue to follow and support what the Basel Institute is doing. The organisation and its mission remain dear to my heart. Thank you, Anne Peters, for your time and for your unwavering support and guidance over so many years. We wish you well in your future endeavours and adventures.
Holding the line: Betsy Andersen on corruption and hope in uncertain times (The Academy Bulletin)
Corruption corrodes trust, weakens institutions, and undermines societies. Few people understand this better than our Executive Director Elizabeth Andersen. With more than two decades of experience advancing the rule of law around the world, Betsy brings a wealth of insight into why corruption matters and how to confront it. In the fifth issue of the Bulletin of the International Academy of Financial Crime Litigators, Betsy is in conversation with the Bulletin’s co-editor Dr Maria Nizzero. She discusses what drew her to the Basel Institute, the challenges of sustaining anti-corruption momentum in a turbulent geopolitical climate, and why, despite the setbacks, she remains deeply optimistic about the fight ahead. The interview is republished here with permission from the Academy. Can you tell us a little bit more about yourself and what drew you to the Basel Institute on Governance? Elizabeth Andersen: I’ve spent more than 20 years working to strengthen the rule of law globally, and one of the most pressing challenges we face is corruption. It undermines institutions, harms societies and erodes trust in government. The Basel Institute’s reputation for impact made it a compelling place to continue this work. What especially attracted me is its model: combining hands-on technical assistance with research and policy engagement. I was particularly drawn to the way in which the Basel Institute transforms lessons learnt from their very impactful technical assistance and case-based assistance on the ground into policy recommendations. These recommendations contribute to global conversations and policymaking that can in turn deliver systemic change. This virtuous cycle of on-the-groundwork, learning and policy engagement was really very attractive to me as a terrific model. You previously led the World Justice Project. What lessons are you bringing to Basel? EA: Both organisations share a commitment to data-driven, evidence-based solutions. At the World Justice Project, I saw how indices can be powerful diagnostic tools and motivators for change, as countries or jurisdictions work to strengthen their scores. They open the door for really important conversations on the path forward for change. I intend to carry this work forward to the Basel Institute, as I believe the Basel AML Index – our flagship tool for assessing risks of money laundering and related financial crimes at the country level – has the potential to achieve even more than what it is already doing. Another key point these organisations have in common is the value they place on multi-stakeholder approaches. The rule of law isn’t just for lawyers and judges: it requires governments, businesses and civil society to work together. At the Basel Institute, one of the ways in which we’re advancing that vision is through Collective Action initiatives. These bring together the private sector and other stakeholders – typically government and civil society – in sustained, collaborative efforts to overcome shared corruption challenges and raise standards of business integrity and fair competition. I look forward to building on the Basel Institute’s track record in convening such multi-stakeholder initiatives, so critical to combating corruption effectively. From geopolitical shifts, to the threat of war, to tariffs, to climate change, with so many urgent global issues, how do you keep anti-corruption on the agenda? EA: This is something I have been thinking about a lot – in particular about the ways in which we need to frame, or reframe, the work that we do in terms of the policy priorities that prevail today. We have to link corruption to today’s top policy concerns, whether that’s defence spending, organised crime or the energy transition. There is an important corruption dimension to all of these contemporary priorities. By highlighting that connection through research, we can make the case that anti-corruption work isn’t a distraction or unnecessary expense; it’s foundational and an investment in long-term success. Illicit financial flows are another critical issue. These are not victimless crimes, but ones that rob communities of resources. Especially at a time when development assistance is shrinking, asset recovery and international cooperation to return stolen funds are more urgent than ever. That has always been at the core of the Institute’s work, but it feels all more urgent now. Some argue momentum on asset recovery is waning. Do you agree? EA: In fact, demand for our support in partner countries is growing. We have more demand than we can currently meet from governments asking us to help them develop capacity to investigate, prosecute and recover assets. We’re also seeing governments adopt stronger legal tools, such as non-conviction based forfeiture and improved anti-money laundering frameworks. And international cooperation mechanisms are maturing, which gives me confidence that progress is possible. There may be some fatigue, but there is also a growing awareness that asset recovery is not only a strategy for recovering stolen assets and obtaining much needed resources; it also acts as a deterrent and signals that organised crime will not pay. We also find a lot of promise in the work of the International Anti-Corruption Coordination Centre IACCC , the ongoing Global Forum on Asset Recovery GFAR Action Series and the GlobE Network – the Global Operational Network of Anti-Corruption Law Enforcement Authorities. This kind of international cooperation on anti-corruption and asset recovery is essential, and there are a lot of opportunities to enhance it through such initiatives. In this context, UK Deputy Prime Minister David Lammy’s commitment to tackling illicit finance and the announcement of a summit next year on this topic are really important. The summit represents a great opportunity for financial centres in particular to re-energise and re-focus the fight against illicit finance. How does the Basel Institute bridge the gap between international standards and local realities? EA: This is a really important question, and its answer is a legacy of Gretta Fenner, the Basel Institute’s Managing Director for many years who tragically passed away in 2024. I am proud to say that we never parachute in with a one-size-fits-all presentation. For example, each Basel Institute training on financial investigations and asset recovery is tailored to the local context – to reference the local laws, the local procedures, even the local evidence and context in which crime happens. And this training is typically followed up with mentoring by expert advisors who are often embedded directly with partner agencies in the country. This high-touch approach is time intensive, but it’s the only way to ensure international standards translate into meaningful local practice, and this is something the Institute really excels in. Funding challenges, especially rising from the new US administration’s decisions to cut USAID, have shaken civil society. How is the Basel Institute responding? EA: We’re incredibly fortunate to have a loyal group of donors who have sustained or even increased their support. We don’t take it for granted, however, so we’re also working to diversify funding, including by engaging the private sector. Many companies now recognise that good governance is essential to their bottom line. We’ve also received generous support for education from individuals, such as scholarships for our new graduate-level anti-corruption and asset recovery courses with the University of Basel. Investing in the next generation of leaders is something I’m particularly excited about. I really want to give a shout out to the International Academy of Financial Crime Litigators, which has through the Academy itself and a couple of generous members committed to fund two scholarships for talented professionals who would otherwise not be able to attend the course. Talking about the private sector, what role does the private sector play in fighting corruption? EA: It’s a critical role. We’ve promoted Collective Action for decades, helping to establish initiatives like the Wolfsberg Group and the Metals Technology Initiative. On our B20 Collective Action Hub – a leading free resource centre on this approach – we’ve documented over 300 such initiatives. This growing dataset allows us to identify what works when engaging the private sector in fighting corruption. It allows us to push beyond rhetoric or box-ticking towards initiatives that have meaningful impact. Despite setbacks, what keeps you hopeful? EA: Above all, the people. My colleagues at the Institute, many recruited by my predecessor Gretta Fenner, are extraordinarily talented and committed. Our partners around the world often take up this cause at personal risk, which is deeply inspiring. And then there are the broader networks drawn from government, businesses, civil society, the media and ordinary citizens, standing up against corruption. When you see that collective energy, it’s impossible not to feel optimistic. Finally, what research is the Basel Institute prioritising next? EA: We’re looking closely at how to strengthen legal tools while safeguarding human rights, for example, with a comparative study of non-conviction based forfeiture laws. We’re also exploring mechanisms to help ensure fines from foreign bribery cases can be used to support anti-corruption initiatives, including in communities that have been harmed by corruption. Both areas aim to make anti-corruption and asset recovery frameworks not only more effective, but also more just. The Academy's Bulletin 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.
How tackling green corruption can help us get ahead in the race to net zero
Juhani Grossmann and Amanda Cabrejo le Roux explain the strategic re-focusing of our Green Corruption programme on energy and climate: What is “green” corruption and why does it matter? Green corruption refers to corruption and other financial crimes and governance failures that harm the environment and hinder global efforts to combat climate change. It’s the reason crimes such as illicit deforestation, mining and wildlife trade continue to be multimillion-dollar illegal industries making organised criminals rich at the expense of our planet and the livelihoods of local communities. Green corruption also diverts crucial investments intended for renewable energy and other climate-related projects. Adapting to humanity’s changing energy needs in a just and sustainable manner are challenging enough. We cannot afford to let corruption undermine these generational challenges. What are some key achievements of the programme so far? We are proud that since its launch in 2018, the Green Corruption programme has contributed to significant strides in tackling corruption affecting the environment. Our programme started with an enforcement focus: applying “follow the money” approaches to environmental crimes like illegal wildlife trade and illegal logging. In practice, that means mentoring and training law enforcement officers of national partner agencies to investigate financial transactions that fuel environmental crimes, including between criminal groups and corrupt facilitators. And ideally, to seize and confiscate illicit profits or assets used in the crimes. That’s the only way to get beyond the low-level perpetrators – such as poachers – to the high-level facilitators and organised crime networks. And the only way to take the profit out of the crime, reducing the incentives to engage in it. At the end of 2024, assets worth around CHF 29.6 million were being targeted in 56 cases directly supported by our advisors. We had quite a few “firsts” – like Uganda’s first ever indictment for tax evasion and money laundering against a wildlife trafficking syndicate, Malawi’s first ever corruption cases related to natural resource crimes, Peru’s confiscation of over CHF 3 million in assets related to forestry and gold trafficking, and Indonesia’s first ever conviction on money laundering in relation to an illegal logging case. Behind the headlines lie many more positive steps towards changing mindsets and the priorities of law enforcement agencies to go after the finances of environmental criminals. Our prevention work rapidly grew as we and our partners realised the chronic under-investment in building systems that strengthen resilience to corruption in the environmental sector. Government agencies and state-owned enterprises in countries as diverse as Indonesia, Malawi, Ukraine and Bolivia have now begun to systematically assess and address corruption risks that are affecting their ability to carry out their important functions of protecting the environment and natural resources. Our prevention specialists supported these in applying our bespoke methodology of assessing and prioritising corruption risks and implementing targeted mitigation measures. We developed a customised internal controls maturity assessment tool to reflect the historic lack of investment in this space, which meant that mainstream assessment tools were insufficiently granular at the first stage of maturity to reflect nuances and chart paths to growth. As result of our partnerships, mitigation measures have been institutionalised in many agencies – for example: in Malawi through the creation of Internal Integrity Committees in environmental agencies; in Ukraine through the empowerment of anti-corruption officers to participate in key decision-making processes; in Ecuador by reducing unsupervised discretion in environmental inspections; in Indonesia in the adoption of conflict of interest regulations in the management of timber sales; and in Peru through the automation and digitalisation of numerous permitting and licensing processes related to the wood value chain. Also pleasing to see are the many collaborations and partnerships that have sprung from our work. In Latin America, for example, forestry officials in Peru, Bolivia and Ecuador are now collaborating on protecting the Amazon rainforest through corruption prevention. Still, targeting and preventing corruption tends to be a lonely effort. So, we have established the Countering Environmental Corruption Practitioners Forum together with WWF, TRAFFIC and Transparency International as a support network, and it has now grown to over 800 members and four working groups. There are frequent meetings and collaborations between practitioners dedicated to tackling corruption and improving governance, and those specialised in environmental conservation or climate initiatives. It’s a sign there’s much appetite and energy for action against green corruption Why is now the time to focus on the energy transition? Whatever happens in these volatile times, one thing is certain: we’ll continue to see growing demands for energy transition and climate mitigation and adaptation. The urgency of tackling the energy transition, and the rapid increase in investments from both the public and private sectors, leaves the door wide open to criminals and the corrupt seeking to profit at the expense of investors and donors – as well as the planet. A clear example in this space is the growing geopolitical centrality of critical minerals and rare earths. The rapid rise in demand has been accompanied by particularly fragile governance structures, intense political and economic subsidies, and even warfare. Our experience shows that these are all breeding grounds for corruption. We are therefore prioritising efforts to analyse and mitigate corruption risks in this space in Bolivia, Indonesia and Ukraine. Ensuring that the energy transition is safeguarded from corruption is essential for achieving net-zero goals. As outlined in our Working Paper on good governance and the just transition, corrupt practices can jeopardise renewable energy investments and hinder the development of clean energy infrastructure. Rapidly emerging market-based solutions to stimulate responsible behaviour, such as carbon offsets, are also affected by weak governance systems and opportunities for corruption. The fast-evolving and highly technical nature of these activities only increases this risk. Corruption risks similarly threaten the effectiveness of climate mitigation and adaptation efforts. If funds are embezzled, used fraudulently or diverted to benefit powerful elites, that’s bad for donors and investors. And it’s bad for local communities, many of which are also directly affected by climate change. On the other hand, there are opportunities. Using corruption risk management tools and enhancing enforcement capabilities can help companies and governments to create thriving, profitable supply chains of critical minerals needed for renewable energy facilities, electric vehicles and the like. What does this shift in priorities mean in practice? Through our Green Corruption programme, we are adapting to this evolving landscape by sharpening our focus on transition minerals and the renewable energy sector. We will continue our dual approach of prevention and enforcement, working closely with long-standing partners in Ukraine, Indonesia, Madagascar, Malawi, Uganda, Peru, Bolivia and Ecuador. Some things you might see us doing in the next years: Strengthening transparency and anti-corruption measures in the extraction and trade of lithium, nickel, germanium and other minerals and rare earths essential for the energy transition. Customising financial investigation and asset recovery tools to the specifics of the energy transition. Working with governments, financial institutions and civil society to safeguard energy transition and climate mitigation funds from corruption, fraud and related crimes. We will continue full force our ongoing engagement related to metals gold in particular and the forestry sector, which remain highly strategic. In other areas, such as illegal wildlife trade, fisheries and waste, we will be more discerning, carefully assessing the potential of engagements prior to pursuing them. What impact do we hope to achieve? By applying our expertise to emerging climate and energy challenges, we want to contribute to measurable improvements in the energy transition, environmental conservation, climate change mitigation and equitable economic development. Through these efforts, our Green Corruption programme will continue to play a vital role in ensuring that the green transition is not only sustainable but also just, transparent and a win-win for all: businesses, local communities and society at large – as well as our planet.
Come study with us!
We are thrilled to launch Basel STUDY, deepening our mission to empower professionals and practitioners working to counter corruption and financial crime. In conjunction with the University of Basel, the Basel Institute now offers advanced postgraduate qualifications in anti-corruption and asset recovery. Corruption and financial crime undermine the foundations of our societies – from stalling economic growth to eroding public trust. Understanding their dynamics and how to fight them effectively is essential for professionals from any sector and any corner of the world. The programmes are designed to boost your knowledge, skills and career. They combine advanced research, real-world insights, practical examples and hands-on activities. You’ll also benefit from valuable peer networking, despite the primarily online setting. A wealth of resources for self-study will be available on the university’s easy-to-access learning platform. This means great flexibility for people with busy schedules. The academic qualifications build on our existing learning and training activities. These include free eLearning courses on Basel LEARN, training for anti-corruption agencies, and teaching at the University of Basel and elsewhere. Choose from two postgraduate courses Discover what really works in the fight against corruption with our first Certificate of Advanced Study programme on Mastering Today's Anti-Corruption Challenges. Develop a holistic understanding of how corruption impacts governance at every level – and gain the expertise you need to safeguard integrity and accountability in your field. The six-month course starts in September 2025. Asset recovery is key to tackling organised and financial crimes – that’s what our second certificate programme on Combating Financial Crime Through Asset Recovery is all about. Gain a practice-oriented understanding and sharpen your ability to identify, trace, seize and recover illicit funds. Watch out for more details on this course and the start date Is this for you? Are you dedicated to fighting corruption and financial crime or otherwise involved in the broader field of governance? Do you want to advance your career with a relevant qualification? Then this might just be for you A university degree, relevant work experience, proficiency in English and some spare time are required to apply. Find out more on Basel STUDY and contact us with your questions via study@baselgovernance.org or the contact form.
Publications
Quick Guide 43: Corruption sanctions
How can governments respond to serious corruption when those responsible are beyond the reach of the law?
Weak institutions, political protection or limited law enforcement capacity can make it difficult to investigate or prosecute powerful individuals suspected of corruption. In response, some governments have turned to corruption sanctions.
Corruption sanctions allow governments to impose restrictions on people suspected of serious corruption even without a criminal conviction.
This Quick Guide introduces corruption sanctions, explains how they work and highlights both their potential and the concerns they raise.
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 62: Corruption sanctions: What governments need to know
How can governments respond to serious corruption when those responsible are beyond the reach of the law? Some governments have turned to corruption sanctions to address this issue.
This Working Paper examines how corruption sanctions – tools that allow governments to impose asset freezes and travel bans on individuals suspected of corruption without any finding of guilt in a court – have evolved over the past decade, and offers recommendations for their more effective and legitimate use.
Download the Working Paper hereAdvantages and limitations of corruption sanctions
Corruption sanctions emerged primarily to address situations where notoriously corrupt individuals enjoy impunity within their own legal systems. Their key strengths lie in their flexibility and versatility:
- they can be applied regardless of any geographical link between the sanctioning state and the alleged corruption, based on relatively low evidentiary thresholds; and
- they can serve a wide range of objectives – from disrupting and deterring corrupt activity to condemning corruption, facilitating asset recovery and signalling support for another country’s law enforcement efforts.
However, the paper also highlights important limitations. Corruption sanctions are often wielded without a clear post-imposition strategy. And: their inherent flexibility comes with due process trade-offs, including broad governmental discretion and limited judicial oversight.
Recommendations
Drawing on an extensive analysis of the experiences of key jurisdictions – including the US, UK, EU, Canada and Australia – the author puts forward nine recommendations for governments on how to design and maintain credible and effective corruption sanctions regimes. These include publishing clear criteria for high-priority targets, strengthening transparency around licensing and delisting decisions, and exploring sanctions against professional enablers in major financial centres.
The paper is aimed primarily at policymakers but will also be of interest to anti-corruption activists, private-sector financial crime specialists and academics.
About this paper
This 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.
This is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.
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.
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.
The International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance provided technical assistance as part of a Memorandum of Understanding with the General Prosecutor’s Office of Colombia.
On 30 November 2023, the Fourth Court of the Specialised Extinción de Dominio Circuit of Colombia ordered the non-conviction based forfeiture of a Guernsey trust account issued by Northern Trust Fiduciary Services (Guernsey) Limited. The beneficiary was María Marcela Serrano Camacho, a Colombian model and former beauty queen.
The Colombian forfeiture order extinguished property rights over the account – amounting to GBP 361,146 – on the grounds that the funds were the proceeds of drug trafficking offences committed by Efraín Antonio Hernández Ramírez (“Don Efra”), a well-known Colombian drug trafficker, and his former spouse María Serrano in the 1990s.
On 30 January 2025, following successful mutual legal assistance proceedings between Colombia and the Bailiwick of Guernsey, the two jurisdictions concluded an asset sharing agreement for the repatriation of the confiscated assets.
This marked Colombia’s first successful international recovery through non-conviction based forfeiture.
This Case Study examines how early and effective coordination between Colombia and Guernsey enabled the identification, freezing, forfeiture and repatriation of the assets. It analyses the legal framework underpinning Colombia’s Extinción de dominio regime and how it was applied, leading to the forfeiture of the Guernsey acccount. It also describes the procedural mechanisms used in Guernsey to execute foreign non-conviction based forfeiture orders.
The interaction between the authorities in both jurisdictions offers valuable lessons and examples of good practices.
Main takeaways of the case:
- Early and trust-based international cooperation is decisive
- Non-conviction based forfeiture is indispensable when criminal routes are closed
- Identifying beneficial ownership is central to effective asset recovery
- Direct enforcement of foreign forfeiture orders increases efficiency and legal certainty
- Asset sharing agreements strengthen cooperation incentives
The Case Study can be read alongside Policy Brief 16: “Enforcing foreign non-conviction based forfeiture orders: FATF standards and asset recovery practice in Latin America and financial centres”.
About this Case Study
This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BYNC-ND 4.0).
The Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery.
This is a publication of the International Centre for Asset Recovery (ICAR) at the Basel Institute on Governance. ICAR receives core funding from the Governments of Jersey, Liechtenstein, Norway, Switzerland and the UK.
Disclaimer: This Case Study is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. The contents are the sole responsibility of the authors and do not necessarily reflect the views or the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.
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.