Asset recovery

Peru to reform key asset recovery law with Basel Institute support

Peru’s Attorney General, Tomás Gálvez, has established a multidisciplinary Commission to propose comprehensive reform of the country’s non-conviction based forfeiture framework. The Basel Institute on Governance has been appointed as the Technical Secretariat to the commission, as an extension of our longstanding cooperation with Peru’s Public Prosecutor’s Office Ministerio Público del Perú . Non-conviction based forfeiture – in Peru in the form of extinción de dominio legislation – allows the state to recover assets linked to illicit activity outside of criminal proceedings. By preventing criminal wealth from being hidden, transferred or reinvested, it can strengthen asset recovery and help disrupt the financial foundations of organised crime and corruption. About the Commission Chaired by the Attorney General, the Commission brings together senior prosecutors and representatives of institutions responsible for financial intelligence, law enforcement, asset recovery, taxation and public registries. It will also hear directly from specialised prosecutors, lawyers, judges and academics about the challenges they face and their proposals for reform. The Commission will meet twice a week and aims to produce a legislative proposal within three months. Its broad and inclusive approach is designed to deliver legislation that is both effective and respectful of human rights. Technical assistance for legal reforms Oscar Solórzano, Head of Latin America for the Basel Institute’s International Centre for Asset Recovery, will serve as the Commission’s Technical Secretariat, together with Deputy Head Walther Delgado. This is an important opportunity to support a balanced reform that strengthens Peru’s ability to recover illicit assets while upholding due process, protecting legitimately acquired property and reflecting international standards. These are critical aspects to ensure the law’s legitimacy, as Oscar Solórzano argued in 2024 in a Working Paper: Targeting illicit wealth through non-conviction based forfeiture: Identifying human rights and other standards for Latin America. Timeline of Peru’s non-conviction based forfeiture law The journey of Peru’s extinción de dominio framework makes an interesting case study in the development and use of laws designed to help combat corruption and organised crime. The Basel Institute has been closely involved for more than a decade, under programmes of the Swiss SECO-funded Programa GFP Subnacional, whose asset recovery activities are coordinated by Sergio Jiménez Niño, and the Basel Institute’s International Centre for Asset Recovery. The Peruvian experience provides a concrete example of a non-conviction based confiscation system that, following a period of significant implementation, is now undergoing a process of reassessment and adaptation in response to a substantial legal and political backlash framed largely around constitutional guarantees, due process and the protection of fundamental rights. The following timeline provides some insight and sets the context for the debates to come: 2018–2023: Building and testing a specialised system Peru’s current extinción de dominio framework was established by Legislative Decree 1373 in 2018, replacing the previous pérdida de dominio regime with an autonomous, property-based judicial process for recovering assets linked to illicit activity without requiring a prior criminal conviction. A specialised judicial and prosecutorial system was subsequently established across the country. Over the following years, the framework moved from legislation to practice. Prosecutors and judges developed experience, jurisprudence emerged and institutions worked to harmonise criteria. The Basel Institute supported this process through training, technical advice, case-based assistance, international cooperation and the development of reference material such as a two-part Compendium of Jurisprudence on Extinción de Dominio. The team also organised national conventions for specialised prosecutors and judges to harmonise understanding and application of the law across Peru. The system delivered significant results, recovering assets worth well hundreds of millions in US dollars and allowing Peruvian decisions to be recognised and enforced in several cases internationally. But implementation also brought difficult legal and practical questions to the surface, particularly concerning the autonomy of extinción de dominio from criminal proceedings, property rights, temporal application, evidentiary rules and procedural safeguards. 2024–2025: Constitutional scrutiny and legislative change In 2024, a constitutional challenge brought by Peru’s Ombudsman placed central elements of Legislative Decree 1373 before the Constitutional Court. At the same time, Congress was considering substantial legislative changes to the system. The Basel Institute set out technical arguments to inform the discussion, among others in public articles and a series of recorded debates. In May 2025, Law 32326 substantially amended the framework. The changes affected, among other things, the autonomy and scope of extinción de dominio, evidentiary requirements and limitation periods. The Public Prosecutor’s Office subsequently challenged the constitutionality of several of those amendments – a pending case that remains relevant to the current reform process. Then came Judgment 135/2025 of the Constitutional Court. The Court declared parts of the original framework unconstitutional and established binding interpretative criteria on issues including property rights, due process and the relationship between extinción de dominio and criminal proceedings. It ruled, in particular, that Legislative Decree 1373 could only apply to circumstances occurring after its entry into force. Importantly, the judgment did not bring extinción de dominio to an end. It established constitutional limits that the reform must respect, while also leaving room for legislative choices on important aspects of the system. 2026: From successive changes to comprehensive reform This is the legal and institutional landscape inherited by the new Commission. It must consider: - the original architecture of Legislative Decree 1373; - the amendments introduced by Law 32326; - the binding constitutional parameters established by Judgment 135/2025; and - the unresolved constitutional questions concerning the 2025 amendments. Beyond correcting individual provisions of the law, the Commission must grapple with the question: What model of non-conviction based forfeiture should Peru have, taking into account its constitutional framework, international standards and the criminal reality the mechanism is intended to address? Four areas at the heart of the reform The Commission has organised its work around four thematic areas. Each addresses a set of issues that has emerged from the experience of applying the law, the legislative changes and the Constitutional Court’s judgment. 1. Nature, scope and autonomy What should be the purpose and scope of non-conviction based forfeiture? When should it be available, what assets should it cover and how autonomous should it remain from criminal proceedings? The discussion also concerns its relationship with conviction-based confiscation and other asset recovery mechanisms. 2. Temporal application, legal certainty and protection of rights How should the framework address temporal application and limitation periods while protecting property and fair trial rights, bona fide third parties and victims? What consequences should subsequent criminal decisions have for assets already forfeited? 3. Procedure, evidence and due process What rules are needed for financial investigations, interim measures, burdens and standards of proof, rights of defence and judicial review? These questions go directly to how an effective asset recovery mechanism can operate within clear procedural guarantees. 4. Effectiveness International cooperation, enforcement and asset management. A successful system must also work beyond the courtroom. This area covers international cooperation, recognition and enforcement of foreign decisions, early information exchange, execution of confiscation decisions, management and preservation of assets, restitution and asset sharing, and coordination between the institutions involved in the asset recovery process. The Commission is addressing these areas progressively. It began in September by listening to specialised extinción de dominio prosecutors from across Peru about the problems encountered in practice and the effects of the legislative reform and the Constitutional Court judgment. National and international experts are then being invited to examine the different thematic areas before the Commission moves into deliberation and legislative drafting. Value of a multidisciplinary, participatory approach This approach is particularly valuable because many of the questions now being examined in Peru are not new. The autonomy of non-conviction based forfeiture, its relationship with criminal proceedings, retroactivity, property rights, evidentiary standards and due process have historically been among the main grounds on which such systems have been questioned around the world. What makes the Peruvian experience unusual is the possibility of observing these questions in real time. Rather than examining them retrospectively, the Commission can consider how they have arisen in a mature system, listen to those who have applied the law, hear different legal and institutional perspectives and assess possible solutions while the framework itself is being reconsidered. In that sense, Peru provides a particularly interesting opportunity to revisit in practice issues that have accompanied non-conviction based forfeiture internationally for decades. These are also central to the Basel Institute’s Working Paper 54: Targeting illicit wealth through non-conviction based forfeiture: Identifying human rights and other standards for Latin America, which examines how effectiveness, human rights, procedural safeguards and international standards can be reconciled in the design and application of these mechanisms. A reform against the clock The Commission is working under an exceptionally demanding timeframe. It has only three months to develop a comprehensive proposal on issues involving constitutional rights, criminal policy and the practical effectiveness of asset recovery. The short deadline reflects a deliberate sense of urgency. After months in which the reform process had largely stalled, Attorney General Tomás Gálvez has decided to use his legislative initiative to move it forward and seek a workable proposal as quickly as possible. Organised crime and illicit economies have not stood still in the meantime, and Peru needs an effective legal framework to target the assets that sustain them. That urgency is also reflected in the way the Commission is working. It meets twice a week, bringing together specialised prosecutors and national and international experts to examine the four thematic areas, test different approaches and progressively build consensus. The methodology requires intensive legal and comparative analysis, but also negotiation between different institutional perspectives within a highly compressed timeframe. The task is difficult precisely because both considerations are real: the urgency of strengthening Peru’s response to organised crime, and the need to ensure that the resulting framework is constitutionally sound, effective and sustainable.

Latin American practitioners join forces against evolving financial crime

Cryptoassets are transforming the work of investigators, prosecutors and asset recovery specialists across Latin America. At a dedicated workshop in Luxembourg, more than 30 practitioners came together to share how they are responding to the challenge – with practical solutions, strong regional leadership and a readiness to learn from one another. The workshop was co-organised by the Basel Institute on Governance and the UK National Crime Agency NCA . It was hosted by Luxembourg’s Bureau de gestion des avoirs as a side event to the 10th Global Conference on Criminal Finances and Cryptoassets. Participants came from prosecution services, police forces, financial intelligence units, supervisory authorities and the judiciary. As members of the Latin America Crypto Community of Practice, they share a determination to confront the rapid growth of cryptoassets and their exploitation by organised crime. Regional leadership in action The workshop placed the region’s own expertise at its centre. Practitioners from Argentina, Brazil, Colombia and Peru presented cases involving cryptoassets and asset recovery. They shared the approaches they had tested, the obstacles they had encountered and the lessons they had learned. The discussions reflected the tremendous effort taking place across Latin America. Practitioners are tackling complex technical, legal and operational questions, often while the risks, technologies and criminal methods continue to evolve. Maria Cordeiro, Senior Specialist, Asset Recovery at the Basel Institute and coordinator of the Latin America Crypto Community of Practice, said: The commitment and creativity of practitioners across Latin America are remarkable. They are not waiting for perfect laws, unlimited resources or ready-made solutions. They are getting to grips with difficult cases, testing practical approaches and helping one another move forward. That passion and leadership are exactly what this community is designed to support. Working through shared challenges Participants worked together on practical challenges related to the seizure, confiscation, custody, management and sale of cryptoassets. The discussions were frank and focused on finding workable solutions. Held in Spanish and under the Chatham House rule, the workshop provided a trusted space in which practitioners could speak openly and learn from their peers. The group also explored ways to strengthen cooperation against organised crime, illicit trafficking and other threats involving cryptoassets. These crimes operate across borders, making strong professional relationships and rapid information exchange essential. The workshop was opened by Oscar Solórzano, Director for Latin America at the Basel Institute’s International Centre for Asset Recovery. Perla, a subject matter expert from the UK National Crime Agency NCA , co-moderated the session. Partnerships and looking forward We thank the NCA for co-organising the workshop under its Illicit Finance programme in Latin America and the Luxembourg Bureau de gestion des avoirs for hosting it so generously. We are also grateful to the NCA, the US Bureau of International Narcotics and Law Enforcement Affairs INL in Colombia, Ecuador, Mexico and Peru, and the International Criminal Investigative Training Assistance Program ICITAP in Colombia for funding the participation of practitioners in the workshop and the Global Conference. We also thank current sponsors of our Latin America Crypto Community of Practice for their support for this practitioner-led exchange: Kodex, Asset Reality, Tradias, VerifyVASP, Inca Digital, Coinbase, TRM Labs and CAT Labs. The workshop showed the value of bringing committed practitioners together around real cases and shared challenges. Discussions are already underway about a dedicated Latin America Crypto & Asset Recovery Conference in 2027.

African expertise takes centre stage at crypto and asset recovery workshop

Around 40 public-sector practitioners gathered in Luxembourg on 17 September 2026 for the Africa Crypto & Asset Recovery Workshop. The event put African experience, innovation and talent at the heart of discussions on cryptoasset investigations and asset recovery. Held as a side event to the 10th Global Conference on Criminal Finances and Cryptoassets, the workshop brought together specialists from financial intelligence units, law enforcement agencies, prosecution authorities, regulators and asset recovery bodies. Participants represented more than 15 African countries. The Basel Institute on Governance co-organised the workshop with the SecFin Africa. It was hosted by Luxembourg’s Bureau de gestion des avoirs. Learning from African experience The workshop was designed around peer learning. Practitioners from Cameroon, the Democratic Republic of the Congo, Kenya, Namibia, Nigeria, Sierra Leone and South Africa presented real cases to their regional peers. They spoke openly about the obstacles they had encountered and the practical approaches they had developed to overcome them. The workshop took place under the Chatham House rule. Participation was restricted to public-sector officials to provide a safe space for candid discussion, questions and learning. This practitioner-led approach is central to the Africa Crypto & Asset Recovery Network. The Network recognises that valuable expertise and creative solutions already exist across the continent. Its role is to help practitioners share this knowledge, learn from one another and build trusted relationships across institutions and borders. As H.E. Ambassador Mary Chirwa, Ambassador of Zambia to the Benelux countries, said in her closing remarks at the main conference: I can speak for Africa: it may not have the same resources as other regions, but it has large, young and technologically astute populations – quick to embrace new technologies, question established approaches and find imaginative solutions. Practical tools and international cooperation The workshop also introduced practical tools that can support investigations and asset recovery. - Alexandru Donciu, Virtual Assets Specialist at the Basel Institute, demonstrated free and open-source tools for conducting on-chain investigations. - A representative of the French Gendarmerie and France’s Agency for the Management and Recovery of Seized and Confiscated Assets AGRASC presented ASAC. The application guides magistrates and investigators through procedures for tracing, seizing and confiscating criminal assets. - A Europol representative illuminated the work and approach of the European Financial and Economic Crime Centre and its collaborations with global law enforcement partners. The contributions from international partners highlighted the importance of connecting strong regional networks across continents. Cryptoassets move globally and effective investigations depend on cooperation that does the same. Connections that last beyond Luxembourg Many of the participants also attended the main Global Conference on 15–16 September. This gave the large African delegation opportunities to exchange experience with hundreds of peers from law enforcement, policymaking, research and the private sector. These face-to-face connections matter. They build the trust that makes it easier to pick up the phone when an urgent cross-border case arises. Our sincere thanks go to SecFin Africa and to the workshop’s co-moderators, Philippe Pacaud, Operational Coordinator at SecFin Africa, and Simon Marsh, Head of Africa at the Basel Institute’s International Centre for Asset Recovery. SecFin Africa is funded by the European Union, France and Germany. We also gratefully acknowledge the organisations supporting the Africa Crypto & Asset Recovery Network: Kodex, Asset Reality, Tradias, VerifyVASP, Coinbase, TRM Labs, CAT Labs and iSanctuary. Their support helps make this public-sector community and its activities possible while preserving a trusted and product-free space for practitioner exchange. The enthusiasm in Luxembourg also raised an exciting possibility: a dedicated Africa Crypto & Asset Recovery Conference in 2027. Watch this space.

From private sector compliance to a Financial Intelligence Unit: how specialised education supported this shift

"I wanted to have more impact in helping my country prevent and combat money laundering." In her role as an Anti-Money Laundering Analyst at a commercial bank, Hortensia Uupindi felt that something was missing. After reporting suspicious transactions, she could not see what happened next. This curiosity evolved into a career objective: to transition into a role where she could take a more active part in combating financial crime and safeguarding the integrity of the financial system. With this in mind, she decided to enrol in the postgraduate programme "CAS Combating Financial Crime Through Asset Recovery", delivered by the Basel Institute on Governance together with the University of Basel. In this interview, she shares her experience on taking the course, the ways it contributed to her professional growth and how it helped her transition into her current role at the Financial Intelligence Unit of Namibia. You were working in the compliance department at a commercial bank. What motivated you to take this programme? Working as an Anti-Money Laundering Analyst really opened my eyes to money laundering and its links to real-world financial crimes. Like many countries, Namibia also faces ongoing challenges with predicate offences such as corruption, fraud and tax evasion. At the bank, whenever we identified suspicious behaviour, we reported it to the Financial Intelligence Unit FIU . But we did not get to see what happened after that. At that time, I was familiar with the term “asset recovery”, but I did not understand how the entire value chain worked, with all its processes and challenges. Joining the FIU had always been one of my career aspirations. I was eager to learn more about asset recovery and strengthen my ability to contribute to my country's efforts to prevent and combat money laundering. The programme immediately caught my interest, and I knew it was an opportunity I could not miss. A few months ago, I successfully transitioned into my new role as a Compliance Analyst at the Namibian FIU. What change in perspective did this programme bring to your professional career? The course helped me understand the whole asset recovery process and the role I am playing in combating financial crime. It also showed me how to come up with solutions to resolve some of the challenges that slow the process down. That understanding made me appreciate the work I do on a daily basis even more. The aim is to prevent money laundering, but when an offence has already occurred, we want to recover those assets because they are proceeds of crime and make sure they are reinvested for public good. The Fishrot case in Namibia is a clear example of why asset recovery is so important. The funds that were misappropriated could have been used to support education, infrastructure and social development initiatives that would benefit the wider population. Instead, they enriched only a select few individuals. Recovering these assets would make a significant contribution to Namibia’s economy and development. The diversity of the cohort was another important highlight of the programme. I came from a banking background, but we had people from FIUs, anti-corruption agencies, asset management units and other areas. We could see how our different roles connect along the asset recovery chain. All in all, the programme changed my perspective because it gave me a balance between where I was and where I wanted to be. What was a highlight of the programme for you? There were many, both in terms of the content and the career opportunities. I particularly valued learning about international anti-money laundering frameworks and laws governing offences such as corruption and bribery. It enhanced my understanding of how illicit assets are acquired, as well as techniques for identifying and tracing them, before they are frozen, confiscated, recovered and re-used. Career-wise, the programme expanded my horizons. Before, I didn’t know there were so many career opportunities in the anti-financial crime sector. The lecturers and speakers showed us the diversity in this space. You were able to join the programme thanks to the Gretta Fenner Scholarship Fund. What did this support mean to you? I was fascinated by the programme until I saw the tuition fees. I couldn’t afford to pay for it in full. Then I saw that a scholarship fund was available, so I applied for both the programme and financial support. Being one of the recipients of partial financial support was a blessing. The course came at the perfect time in my career, equipping me with valuable knowledge and practical skills that have strengthened my professional capabilities. I would really encourage individual donors and organisations to continue supporting the scholarship fund. Capacity building is important, because it's only when skilled people are at the forefront of countering financial crime that a real difference can be made to society. What would you say to other professionals, including those in the private sector, who are unsure whether the programme is worth it? The programme is worthwhile. It has a structure that you don’t often find: a mix of practical experience and deep knowledge, combining lectures with real-world experience. It is beneficial for colleagues who already work in this field, but we also had classmates from other fields who are aspiring to enter the sector. It is friendly both for beginners and experienced professionals. The Basel Institute demonstrated a high level of professionalism throughout the programme. The lecturers were highly knowledgeable and generous in sharing their expertise. They consistently took the time to address our questions and brought in professionals from various sectors to provide additional insights. This programme truly has equipped us to play our part in the fight against financial crime. For anyone contemplating, it is truly a worthwhile opportunity. Thank you, Hortensia, for sharing your story and highlighting the impact this postgraduate programme has had on your professional journey. 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. :::

Specialising in asset recovery: why this Argentinian prosecutor decided to take the leap

“When it comes to economic crime, securing a conviction is not always enough. If we do not recover the assets, we are not returning to society what was stolen from it.” This realisation marked a turning point in the career of Julio Petrucci, a prosecutor at the Attorney General’s Office of the Province of Buenos Aires, Argentina. Driven by this mindset and by his desire to keep pace with the way crime operates today, Petrucci decided to enrol in the postgraduate programme “CAS Combating Financial Crime Through Asset Recovery” delivered by the Basel Institute on Governance together with the University of Basel. In this interview, he tells us about the challenges of his work, the issues demanding greater specialisation and the advice he has for other public servants who, like him, are striving to serve their citizens better. A prosecutor’s work requires constant adaptation. What motivates your daily work and what challenges do you face? My main motivation is to try to do good and to help repair what is broken in society when a crime is committed. In my country, as well as across the region, there are many economic difficulties and high levels of social inequality. Many people who become victims of crime rely on the Public Prosecutor's Office and other public institutions for support. As a prosecutor, I want to be able to provide these victims with answers and practical tools. Over time, I began to realise that my initial training was largely focused on crime in traditional, physical settings. However, crime scenes are often digital or have a strong financial component. That's when I identified the need to look for new tools to strengthen my investigations. It was through this search that I discovered the Basel Institute on Governance and its educational programmes. Why did you choose the Basel Institute programme to specialise in asset recovery? I was particularly interested in the specialised programme on asset recovery for three reasons: - first, because asset recovery is a highly relevant and rapidly growing field; - second, because I could not find other advanced courses offering this level of specialisation in countering financial crime; - and third, because of the international reputation of the Basel Institute on Governance and the University of Basel. What change in perspective did this programme bring to your professional career? The course marked a before and after in my career. In Argentina, asset recovery is still a developing field. Historically, we have analysed criminal cases with the aim of securing convictions. However, when it comes to economic crime, securing a conviction is not always enough. If we do not recover the assets, we are not returning to society what was stolen from it. Throughout the course, I learned not only about the different legal frameworks that exist around the world in this area, but also how to apply them to specific cases. The academic team and the online learning platforms were excellent. All this new knowledge and practical tools are already proving extremely useful in my day-to-day work. They have even contributed to my professional growth in ways that I am not yet able to comment on officially. This was also my first international experience. I got to meet people from different countries and professional backgrounds, which was very enriching. You were able to join the programme thanks to a scholarship. What did this support mean to you? I am a public official in a country facing significant economic challenges. The salaries of public officials like me, both in Argentina and across Latin America, are not particularly high. In this context, I saw that the Basel Institute offered financial support through the Gretta Fenner Scholarship Fund and decided to apply for it. From the outset, the team was very receptive. After some interviews, I was awarded a partial scholarship thanks to the funds they had raised, which allowed me to take the course. To donors and benefactors, I would say that their contribution is not just individual support for a student: it is a direct investment in justice systems in our countries. Thanks to their contribution, I now have the tools to investigate complex crimes and recover assets that belong to society. Why would you recommend this training to other prosecutors or investigators in the region? When you work in public service, and especially in a role such as that of a prosecutor, it is very difficult to look beyond what you see in your daily work. But crime is changing. In fact, it has already changed, and if we do not adapt, we will not be able to do our jobs effectively or help repair what is broken in society when a crime is committed. For this reason, I encourage prosecutors and others interested in tackling financial crime to step outside their day-to-day routine and take courses like this. I highly recommend this programme to them, not only because of its academic quality but also because of the quality and dedication of the Basel Institute team. It was an incredible experience. Thank you, Julio, for sharing your story and highlighting the impact this postgraduate programme has had on your professional journey. Julio Petrucci is just one of many talented professionals who have been able to take this course thanks to the Gretta Fenner Scholarship Fund. We are deeply grateful to all those who have generously contributed, and continue to contribute, to this fund, especially the International Academy of Financial Crime Litigators, Bonifassi Avocats, Bennett Jones, ECO Strategic Communications and Kellerhals Carrard. 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. :::

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)

Quick Guide 41: Managing seized and confiscated assets

Working Paper 55: Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms