[{"data":1,"prerenderedAt":1279},["ShallowReactive",2],{"tag-879":3,"tag-events-879-1":6,"tag-stories-879-1":9,"tag-publications-879-1":11,"tag-news-879-1":786},{"id":4,"name":5},879,"Money laundering",{"items":7,"total":8},[],0,{"items":10,"total":8},[],{"items":12,"total":785},[13,190,353,525,645],{"id":14,"status":15,"sort":16,"date_created":17,"date_updated":18,"nid":19,"slug":20,"title":21,"body":22,"citation":23,"language":16,"year":24,"publisher":25,"date_published":26,"external":27,"topic":16,"link_internal":28,"link_external":32,"featured":27,"topics":36,"languages":38,"type":40,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":42,"short_version":16,"subtitle":16,"image":43,"countries":55,"tags":103,"pdf":150,"authors":173},2443,"published",null,"2026-06-01T22:10:26.000Z","2026-06-02T21:14:32.000Z",2948,"cs-14","Case Study 14: Madagascar: a landmark conviction for money laundering linked to environmental crime","This Case Study demonstrates how international cooperation and the follow-the-money approach revealed a transnational criminal network trafficking endangered species and led to Madagascar’s first money laundering conviction related to wildlife trafficking.\n\n### About this Case Study\n\nThis publication is part of the Basel Institute on Governance Case Study series, [ISSN 2813-3900](https:\u002F\u002Fbaselgovernance.org\u002Fcase-studies). It is licensed for sharing under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License ([CC BY-NC-ND 4.0](https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F)).\n\nPhoto: [Studio Sifaka](https:\u002F\u002Fwww.studiosifaka.org\u002Farticles\u002Factualites\u002Fitem\u002F8084-plus-de-mille-tortues-et-pres-d-une-cinquantaine-de-lemuriens-vivants-saisis-en-thailande.html) \u002F khaosodenglish (used with permission).\n\nThe Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery. This case relates to the Basel Institute's [Green Corruption programme](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption).\n\nThe development of this publication was funded through the Illegal Wildlife Trade (IWT) Challenge Fund.\n\nThe contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel.\n","Rakotondramanana, Joseph. 2026. “Madagascar: a landmark conviction for money laundering linked to environmental crime.” Case Study 14, Basel Institute on Governance. Available at: https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fcs-14",2026,"Basel Institute on Governance","2026-03-31",false,[29],{"url":30,"caption":31},"\u002Fresources\u002Fpublications?type=Case%20Study","View all Case Studies",[33],{"url":34,"caption":35},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=369","View online on Basel LEARN",[37],"Green Corruption",[39],"English",[41],"Case Study","- In 2024, Thai authorities carried out the country's largest ever single wildlife seizure, intercepting 48 lemurs and more than 1,000 tortoises endemic to Madagascar.\n- The seizure triggered a joint Thai-Malagasy investigation that traced smuggling routes through Indonesia, uncovered a transnational criminal network and led to arrests in both countries, the freezing of bank accounts and the confiscation of vehicles and vessels.\n- In 2025, the Anti-Corruption Court in Antananarivo convicted 10 individuals for trafficking in protected species, money laundering and criminal conspiracy. Sentences of up to 10 years in prison were handed down, alongside approximately USD 8.7 million in customs penalties and damages. This is the first time Madagascar has applied the offence of money laundering to a wildlife trafficking case.\n- Training on financial investigations by the Basel Institute on Governance, together with the facilitation of information exchange and peer learning among enforcement practitioners, contributed to this landmark result. The Malagasy authorities are now better equipped to overcome structural challenges in applying a “follow-the-money” approach to organised environmental crime, including limited technical expertise, insufficient resources and the complexity of cross-border financial investigations.",{"id":44,"storage":45,"filename_disk":46,"filename_download":47,"title":48,"type":49,"created_on":50,"modified_on":50,"charset":16,"filesize":51,"width":52,"height":53,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":54,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":50},"ea8361c6-bffd-4cfd-9119-7bc822b39af7","local","ea8361c6-bffd-4cfd-9119-7bc822b39af7.jpg","Case-Study-14_Madagascar_ML-conviction-for-IWT_Cover.jpg","Case Study 14: Madagascar ML conviction for 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Rakotondramanana",{"id":191,"status":15,"sort":16,"date_created":192,"date_updated":193,"nid":194,"slug":195,"title":196,"body":197,"citation":198,"language":39,"year":199,"publisher":200,"date_published":201,"external":27,"topic":202,"link_internal":204,"link_external":211,"featured":27,"topics":215,"languages":217,"type":218,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"image":220,"countries":229,"tags":279,"pdf":314,"authors":315},2309,"2023-10-04T10:04:39.000Z","2026-06-02T14:08:41.000Z",2514,"organisational-forms-corruption-networks-odebrecht-toledo-case","Organisational forms of corruption networks: the Odebrecht-Toledo case","Actors in grand corruption schemes often conspire and deliberately create sophisticated networks to extract huge amounts of public resources from government systems. They hide such conspiracies behind hybrid formal\u002Finformal arrangements.\n\nUsing a mixed methods approach, this study investigates the corruption scheme initiated by former Peruvian President Alejandro Toledo and the Brazilian construction giant Odebrecht Group. We argue that separating the networks of the client (Odebrecht) and the agent (Toledo) sides provides analytical leverage for studying complex corrupt arrangements.\n\nWe found that the organisational forms designed by corrupt actors on either side were essential to ensuring the secret and safe operation of the network. Introducing the concept of organisational form into corruption research helps better understand the nature of these networks. We also found that different parts of the networks are shaped by different types of corruption. The article concludes with implications for practice.","David Jancsics & Jacopo Costa (29 Sep 2023): Organizational forms of corruption networks: the Odebrecht-Toledo case, International Public Management Journal, DOI: 10.1080\u002F10967494.2023.2260368",2023,"","2023-10-04",[203],"Public Governance",[205,208],{"url":206,"caption":207},"\u002Fresources\u002Fpublications\u002Fworking-paper-36-revealing-networks-behind-corruption-and-money-laundering-schemes"," See related paper: Revealing the networks behind corruption and money laundering schemes: an analysis of the Toledo–Odebrecht case using social network analysis and network ethnography",{"url":209,"caption":210},"\u002Fresources\u002Fpublications\u002Fresearch-case-3"," See related paper: Exposing the networks behind transnational corruption and money laundering schemes",[212],{"url":213,"caption":214},"https:\u002F\u002Fwww.tandfonline.com\u002Fdoi\u002Ffull\u002F10.1080\u002F10967494.2023.2260368","View article at Taylor & 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Costa","90469998-3598-471d-9499-48b19f557c7d",{"id":354,"status":15,"sort":16,"date_created":355,"date_updated":356,"nid":357,"slug":358,"title":359,"body":360,"citation":200,"language":39,"year":199,"publisher":25,"date_published":361,"external":27,"topic":362,"link_internal":363,"link_external":369,"featured":27,"topics":370,"languages":371,"type":372,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"image":374,"countries":382,"tags":420,"pdf":487,"authors":509},2283,"2023-05-31T10:04:29.000Z","2026-06-02T14:09:06.000Z",2454,"research-case-3","Research Case Study 3: Exposing the networks behind transnational corruption and money laundering schemes","Corruption is increasingly understood as a form of collective, social behaviour. It slips easily across borders and involves sophisticated financial strategies and transactions to launder the stolen money. \n\nYet the nexus between corruption and money laundering is poorly understood. So too are the structures, functions and mechanisms that enable these crimes.\n\nWe applied analytical tools to reveal the complex networks behind a corruption and money laundering scheme involving Odebrecht and Peru’s former president. The insights can support strategic approaches to fight transnational corruption.","2023-05-31",[203],[364,366],{"url":206,"caption":365}," View related Working Paper",{"url":367,"caption":368},"\u002Fresources\u002Fpublications?type=Research%20Case%20Study"," View all research case studies",[],[216],[39],[373],"Research Case Study",{"id":375,"storage":45,"filename_disk":376,"filename_download":377,"title":378,"type":49,"created_on":355,"modified_on":355,"charset":16,"filesize":379,"width":226,"height":380,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":381,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":355},"ca5d66b9-58f2-42fd-afa6-1d3224f01f9d","ca5d66b9-58f2-42fd-afa6-1d3224f01f9d.jpg?itok=aj4xmZHu","Pages-from-230511-Research-case-study-03.jpg?itok=aj4xmZHu","Cover page of Research Case Study 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Guide 29: Money laundering and sanctions evasion using the art market","The art market is often described as ‘niche’. In reality, it is a significant trade industry: sales of art and antiques by dealers and auction houses reached an estimated USD 65.1 billion in 2021. And like many industries of this size, it attracts people seeking to abuse it to launder proceeds of crime or evade sanctions.\n\nThis quick guide briefly explains the unique characteristics of the art market that make it vulnerable to this type of abuse. It also outlines steps that jurisdictions can take to prevent and combat abuse of the sector for illicit purposes.\n\n### About this Quick Guide\n\nThis work is licensed under a \u003Ca href=\"https:\u002F\u002Fcreativecommons.org\u002Flicenses\u002Fby-nc-nd\u002F4.0\u002F\">Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License\u003C\u002Fa>. It is part of the Basel Institute on Governance Quick Guide series, \u003Ca href=\"https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications?type=2428\">ISSN 2673-5229\u003C\u002Fa>.","2023-04-12",[535,536],"Anti-Money Laundering","Asset Recovery",[],[539],{"url":540,"caption":541},"https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=176"," View on Basel LEARN",[535,543],"Asset Recovery and Enforcement",[39],[546],"Quick Guide",{"id":548,"storage":45,"filename_disk":549,"filename_download":550,"title":551,"type":49,"created_on":527,"modified_on":527,"charset":16,"filesize":552,"width":226,"height":380,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":553,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":527},"8029c862-8f97-4c17-8c3d-570ea42a1ba4","8029c862-8f97-4c17-8c3d-570ea42a1ba4.jpg?itok=wU7zwOOH","Pages-from-230412-quickguide-29.jpg?itok=wU7zwOOH","Money laundering and sanctions evasion using the art 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industry",{"id":691,"publications_id":733,"directus_files_id":746},{"id":646,"status":15,"sort":16,"user_created":233,"date_created":647,"user_updated":59,"date_updated":648,"nid":354,"slug":649,"image":667,"title":650,"body":651,"citation":200,"language":39,"year":652,"publisher":25,"date_published":653,"external":27,"topic":734,"link_internal":735,"link_external":737,"featured":27,"topics":739,"languages":740,"type":741,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":742,"tags":743,"pdf":744,"authors":745},[536],[736],{"url":657,"caption":658},[738],{"url":661,"caption":662},[543],[39],[546],[],[676,688],[690,691],[693,694],{"id":747,"storage":45,"filename_disk":748,"filename_download":749,"title":749,"type":169,"folder":170,"uploaded_by":233,"created_on":647,"modified_by":16,"modified_on":647,"charset":16,"filesize":750,"width":16,"height":16,"duration":16,"embed":16,"description":751,"location":16,"tags":16,"metadata":16,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":647},"c0acb748-9e74-4f5d-8137-46b148450ad2","c0acb748-9e74-4f5d-8137-46b148450ad2.pdf","QG28-further-reading.pdf",66743," View recommended reading list on gambling and money laundering",[753,770],{"id":693,"publications_id":754,"authors_id":767},{"id":646,"status":15,"sort":16,"user_created":233,"date_created":647,"user_updated":59,"date_updated":648,"nid":354,"slug":649,"image":667,"title":650,"body":651,"citation":200,"language":39,"year":652,"publisher":25,"date_published":653,"external":27,"topic":755,"link_internal":756,"link_external":758,"featured":27,"topics":760,"languages":761,"type":762,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":763,"tags":764,"pdf":765,"authors":766},[536],[757],{"url":657,"caption":658},[759],{"url":661,"caption":662},[543],[39],[546],[],[676,688],[690,691],[693,694],{"id":768,"name":769,"position":16,"image":16},510,"Isys Lam",{"id":694,"publications_id":771,"authors_id":784},{"id":646,"status":15,"sort":16,"user_created":233,"date_created":647,"user_updated":59,"date_updated":648,"nid":354,"slug":649,"image":667,"title":650,"body":651,"citation":200,"language":39,"year":652,"publisher":25,"date_published":653,"external":27,"topic":772,"link_internal":773,"link_external":775,"featured":27,"topics":777,"languages":778,"type":779,"area":16,"programme":16,"websites":16,"summary":16,"pdf_text":16,"main_points":16,"short_version":16,"subtitle":16,"countries":780,"tags":781,"pdf":782,"authors":783},[536],[774],{"url":657,"caption":658},[776],{"url":661,"caption":662},[543],[39],[546],[],[676,688],[690,691],[693,694],{"id":642,"name":643,"position":16,"image":644},12,{"items":787,"total":1278},[788,934,1010,1159,1220],{"id":789,"status":15,"date_created":790,"date_updated":791,"title":792,"type":793,"body":794,"date":795,"topic":796,"slug":799,"activity":800,"nid":803,"topics":804,"activities":806,"programme":16,"area":16,"websites":807,"language":16,"image":809,"translation_of":16,"countries":819,"tags":855,"authors":914,"images":931,"translations":932,"content":933},10509,"2024-11-27T11:01:43.000Z","2026-05-07T21:29:56.000Z","Money dirtying: shining a light on how clean money turns into bribes","News","There’s a lot of attention to the laundering of “dirty money” – but very little about how clean money can be turned into bribes, kickbacks or payments to terrorists.\n\nTogether with David Jancsics, I examined the money-dirtying strategies at the heart of one of the world’s most dramatic corruption scandals: the _Lava Jato_ or Car Wash case. How did the multinational company Odebrecht manage to secretly channel millions in legitimately earned funds to bribe politicians and bureaucrats across the continent? Our article [_Turning Legally Obtained Resources into Illegal Payments: A Money Dirtying Scheme_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fturning-legally-obtained-resources-illegal-payments-money-dirtying-scheme) attempts to answer this question and to explore the networks of individuals and entities that made the schemes possible.\n\nExploring the concept and practice of money dirtying could help practitioners get a more holistic view of major financial crime cases. It could also potentially lead to new ways to prevent, detect and intercept illicit financial flows.\n\n### What is “money dirtying”?\n\nWe use the term “money dirtying” to refer to the process by which clean, legitimate resources are turned into illicit payments used for corruption, the financing of terrorism and other illegal activities.\n\nThe term was originally coined to describe the mechanisms of terrorism financing in the late 1990s and early 2000s. Following the terrorist attacks of 9\u002F11, researchers worked to understand the financial structures that allowed Al-Qaeda to finance the attacks. We have repurposed the term to fit the field of corruption, but the underlying idea is the same.\n\n### What are the typical characteristics?\n\nOn the face of it, money dirtying has similar characteristics to money laundering:\n\n*   Complex, multi-layered schemes using redundant payments and fake contracts to make funds difficult to trace.\n*   The use of specialised professionals who can create sophisticated financial infrastructures and know all the tricks to evade detection.\n*   The use of informal actors such as _halawadars_ or _doleiros_ to escape regulatory radars.\n*   Often transnational, with money, resources and information shared along a cross-border network of individuals and entities.\n\n### What makes it different to money laundering?\n\nThe key differences lie in the purpose and the direction of the flow.\n\n*   Money laundering seeks to clean dirty money by reintegrating it into the legal financial system. It is a circular system, where the funds return to their point of origin.\n*   Money dirtying serves to transfer money undetected from the bribe giver to the bribe taker. It is linear.\n\nFor example, in our case study, the money took the following route:\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-11\u002FUntitled.jpg)\n\nIn reality, it looked more like this:\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-11\u002FUntitled%20design.png)\n\n### The Lava Jato case\n\nThe _Lava Jato_ case (Operation Car Wash) was a major judicial investigation launched in Brazil in 2009. Initially focused on money laundering and illegal activities linked to a car wash company, it quickly expanded into one of the largest corruption investigations in history. By the early 2010s, investigations and plea deals had exposed the intricate financial structures and corrupt management systems of the Odebrecht Group at the heart of a web of illicit payments in countries across the region.\n\nUnlike other cases, there is significant public information available about Lava Jato thanks to judicial investigations, journalistic work, academic studies and other reports. This allowed us to map and analyse the “money dirtying” network in detail.\n\nThe case is also an ideal case study in advanced corruption schemes. It was large, long-running and used complex, multi-layered networks that spread across the world. \n\n### Skeleton and muscles\n\nTo map the complex networks of the Odebrecht Group’s money dirtying networks we looked at the data in two ways:\n\n*   We analysed the transactions, performing a [social network analysis](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-4-social-network-analysis-combating-organised-crime-and-trafficking) and looking at the “skeleton” of the network – how it was shaped, where transactions centred and how they moved.\n*   At the same time, we tried to understand the _substance_ of the network. If you like, the muscles surrounding the skeleton. We read interviews and wiretaps, and looked at personal histories to understand the relationships between people in the network and how they operated together.\n\nWe then created a coherent framework of both the “skeleton” and “muscles”. This includes a description of each role and its function within the network.\n\n[](https:\u002F\u002Fbaselgovernance.org\u002Fsites\u002Fdefault\u002Ffiles\u002F2024-11\u002Fnew%20version.png)\n\n### So what?\n\nPaying more attention to how legitimate funds are channelled towards illegal activities can help anti-corruption practitioners to gain a more holistic view of major corruption schemes.\n\nWith the increase in internal controls and regulatory scrutiny, those that engage in corruption are forced to use more sophisticated methods than just declaring bribes as “consultancy fees”, for example. A better understanding of these methods could help inform stronger internal controls and compliance systems.\n\nThis focus also helps practitioners to see how some of the same methods – legal structures in offshore financial centres, shell companies, professional enablers, informal value transfer service providers for example – can be misused not only for money laundering but for other parts of a corruption scheme.\n\nThe research also showcases the power of social network analysis in mapping the key individuals and entities involved in transforming clean money into illicit payments. Combined with evidence of their relations and interactions, this can create a valuable source of information for both law enforcement and the development of evidence-based strategies for targeting corrupt networks.\n\n### Learn more\n\n[Organisational forms of corruption networks: the Odebrecht-Toledo case](http:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Forganisational-forms-corruption-networks-odebrecht-toledo-case)\n\n[Quick Guide 4: Social network analysis in combating organised crime and trafficking](http:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-4-social-network-analysis-combating-organised-crime-and-trafficking)\n\n[Research Case Study 3: Exposing the networks behind transnational corruption and money laundering schemes](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fresearch-case-3)","2024-11-25",[797,798],"Prevention"," Research and Innovation","money-dirtying-shining-a-light-on-how-clean-money-turns-into-bribes-2723",[801,802],"Research","Insights",2723,[805],"Prevention Research and Innovation",[801,802],[808],"Main page",{"id":810,"storage":45,"filename_disk":811,"filename_download":812,"title":792,"type":813,"created_on":814,"modified_on":814,"charset":16,"filesize":815,"width":816,"height":817,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":818,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":814},"04afeb59-9775-4b6c-b487-de86baa29a94","04afeb59-9775-4b6c-b487-de86baa29a94.webp","tmp.webp","image\u002Fwebp","2025-05-12T21:10:07.000Z",43618,1400,878,{},[820,841],{"id":821,"news_id":822,"countries_id":840},7080,{"id":789,"status":15,"user_created":233,"date_created":790,"user_updated":59,"date_updated":791,"title":792,"type":793,"body":794,"image":810,"date":795,"topic":823,"slug":799,"activity":824,"nid":803,"topics":825,"activities":826,"programme":16,"area":16,"websites":827,"translation_of":16,"language":16,"countries":828,"tags":830,"authors":835,"images":837,"translations":838,"content":839},[797,798],[801,802],[805],[801,802],[808],[821,829],7081,[831,832,833,834],4862,5685,5686,5687,[836],1099,[],[],[],{"id":253,"name":254,"code":255,"latitude":256,"longitude":257},{"id":829,"news_id":842,"countries_id":854},{"id":789,"status":15,"user_created":233,"date_created":790,"user_updated":59,"date_updated":791,"title":792,"type":793,"body":794,"image":810,"date":795,"topic":843,"slug":799,"activity":844,"nid":803,"topics":845,"activities":846,"programme":16,"area":16,"websites":847,"translation_of":16,"language":16,"countries":848,"tags":849,"authors":850,"images":851,"translations":852,"content":853},[797,798],[801,802],[805],[801,802],[808],[821,829],[831,832,833,834],[836],[],[],[],{"id":274,"name":275,"code":276,"latitude":277,"longitude":278},[856,870,884,898],{"id":831,"news_id":857,"tags_id":869},{"id":789,"status":15,"user_created":233,"date_created":790,"user_updated":59,"date_updated":791,"title":792,"type":793,"body":794,"image":810,"date":795,"topic":858,"slug":799,"activity":859,"nid":803,"topics":860,"activities":861,"programme":16,"area":16,"websites":862,"translation_of":16,"language":16,"countries":863,"tags":864,"authors":865,"images":866,"translations":867,"content":868},[797,798],[801,802],[805],[801,802],[808],[821,829],[831,832,833,834],[836],[],[],[],{"id":4,"name":5},{"id":832,"news_id":871,"tags_id":883},{"id":789,"status":15,"user_created":233,"date_created":790,"user_updated":59,"date_updated":791,"title":792,"type":793,"body":794,"image":810,"date":795,"topic":872,"slug":799,"activity":873,"nid":803,"topics":874,"activities":875,"programme":16,"area":16,"websites":876,"translation_of":16,"language":16,"countries":877,"tags":878,"authors":879,"images":880,"translations":881,"content":882},[797,798],[801,802],[805],[801,802],[808],[821,829],[831,832,833,834],[836],[],[],[],{"id":468,"name":469},{"id":833,"news_id":885,"tags_id":897},{"id":789,"status":15,"user_created":233,"date_created":790,"user_updated":59,"date_updated":791,"title":792,"type":793,"body":794,"image":810,"date":795,"topic":886,"slug":799,"activity":887,"nid":803,"topics":888,"activities":889,"programme":16,"area":16,"websites":890,"translation_of":16,"language":16,"countries":891,"tags":892,"authors":893,"images":894,"translations":895,"content":896},[797,798],[801,802],[805],[801,802],[808],[821,829],[831,832,833,834],[836],[],[],[],{"id":485,"name":486},{"id":834,"news_id":899,"tags_id":911},{"id":789,"status":15,"user_created":233,"date_created":790,"user_updated":59,"date_updated":791,"title":792,"type":793,"body":794,"image":810,"date":795,"topic":900,"slug":799,"activity":901,"nid":803,"topics":902,"activities":903,"programme":16,"area":16,"websites":904,"translation_of":16,"language":16,"countries":905,"tags":906,"authors":907,"images":908,"translations":909,"content":910},[797,798],[801,802],[805],[801,802],[808],[821,829],[831,832,833,834],[836],[],[],[],{"id":912,"name":913},973,"Corruption",[915],{"id":836,"news_id":916,"authors_id":928},{"id":789,"status":15,"user_created":233,"date_created":790,"user_updated":59,"date_updated":791,"title":792,"type":793,"body":794,"image":810,"date":795,"topic":917,"slug":799,"activity":918,"nid":803,"topics":919,"activities":920,"programme":16,"area":16,"websites":921,"translation_of":16,"language":16,"countries":922,"tags":923,"authors":924,"images":925,"translations":926,"content":927},[797,798],[801,802],[805],[801,802],[808],[821,829],[831,832,833,834],[836],[],[],[],{"id":929,"name":930,"position":16,"image":352},550,"Dr Jacopo Costa",[],[],[],{"id":935,"status":15,"date_created":936,"date_updated":937,"title":938,"type":793,"body":939,"date":940,"topic":941,"slug":942,"activity":943,"nid":946,"topics":947,"activities":948,"programme":16,"area":16,"websites":949,"language":16,"image":950,"translation_of":16,"countries":957,"tags":958,"authors":1006,"images":1007,"translations":1008,"content":1009},10302,"2022-09-06T14:07:42.000Z","2026-05-29T22:22:23.000Z","Cryptocurrencies key to tackling organised crime – Europol and Basel Institute on Governance ","The 6th Global Conference on Criminal Finances and Cryptocurrencies ([#6CRC](https:\u002F\u002Fbaselgovernance.org\u002F6crc)) – a two-day gathering of thousands of crypto specialists and financial investigators from law enforcement, regulators and the private sector – came to an end today at Europol’s headquarters in The Hague, the Netherlands.\n\nAs cryptocurrency use expands into practically every country and sector, so does its abuse to commit new forms of crime and launder dirty money, said speakers.\n\nYet with the right tools, capacity and cooperation, the unique characteristics of blockchain-based technologies offer an unprecedented opportunity to investigate organised crime and money laundering networks and to recover stolen funds.\n\n### Keeping up as crypto enters the mainstream\n\nThe speeches and panels painted a picture of how “traditional” and virtual organised crime and money laundering typologies are merging. Cryptocurrencies are increasingly involved in trade-based money laundering cases, for example, and linked to a broad range of crimes including drug smuggling, sports match fixing and proliferation financing.\n\nProfessional money launderers are taking advantage of the ever-growing options provided by crypto assets – from mining to decentralised services – to launder proceeds from both physical and cyber crimes.\n\nBut law enforcement, regulators and the private sector are working hard to stay ahead of those who abuse crypto assets to commit crimes and launder money.\n\n*   Legislation is tightening. New EU regulations, for example, will ensure that crypto assets are treated like any other assets for the purposes of anti-money laundering regulation and supervision.\n*   Multiple successful cases, some laid bare during the conference, illustrate how investigators are taking advantage of the unique characteristics of blockchain-based technologies to “follow the money”. This has allowed them to identify not only scammers and hackers but also more traditional organised crime groups and money laundering networks.\n*   Law enforcement and judicial authorities are increasingly treating virtual assets like any other asset from a legal perspective, easing their seizure, management and eventual transformation into fiat currency.\n*   Private companies are innovating fast to provide the tools and analytical capacity to trace funds laundered across multiple blockchains using different obfuscation techniques.\n\nIncreasing understanding and capacity in the crypto sphere among all players – regulators, law enforcement, the private sector – is vital to tackling organised crime and money laundering, both physical and virtual.\n\n### About the conference\n\nThe 6th edition of the annual Global Conference on Criminal Finances and Cryptocurrencies took place in hybrid format on 1–2 September 2022. The conference was hosted by Europol with the support of the Basel Institute on Governance through the joint Working Group on Criminal Finances and Cryptocurrencies.\n\nWith over 1,700 registered participants from 119 countries, the first day was dedicated to public-private cooperation and exchange. Speakers represented regulators (European Parliament), law enforcement (Europol), think tanks (Royal United Services Institute), virtual asset service providers (Binance), and specialised companies involved in crypto investigations, data analysis and asset recovery (Asset Reality, Chainalysis, CipherTrace, Sportradar and TRM Labs).\n\nThe second day of the conference was strictly limited to law enforcement and related public authorities, such as financial intelligence units. Specialised cryptocurrency investigators from France, Korea, Hungary, the Netherlands, Spain and the United States shared case studies and experiences with their international colleagues, which numbered more than 1,100 from 95 countries.\n\n### Learn more\n\n*   See the joint recommendations: [Seizing the opportunity: 5 recommendations for crypto assets-related crime and money laundering](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fseizing-opportunity-5-recommendations-crypto-assets-related-crime-and-money-laundering) \n*   To view recommendations and videos from the previous (2021) conference, which was hosted by the Basel Institute on Governance, see [baselgovernance.org\u002F5crc](https:\u002F\u002Fbaselgovernance.org\u002F5CrC).\n*   Media enquiries: [press@europol.europa.eu](mailto:press@europol.europa.eu) (Europol); [monica.guy@baselgovernance.org](mailto:monica.guy@baselgovernance.org) (Basel Institute on Governance).","2022-09-02",[536],"cryptocurrencies-key-to-tackling-organised-crime-europol-and-basel-institute-on-governance-2279",[944,945],"Events","Partnerships",2279,[543],[944,945],[808],{"id":951,"storage":45,"filename_disk":952,"filename_download":812,"title":938,"type":813,"created_on":953,"modified_on":953,"charset":16,"filesize":954,"width":816,"height":955,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":956,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":953},"280823ad-8d5f-4dc5-bc9f-c70a9a12144e","280823ad-8d5f-4dc5-bc9f-c70a9a12144e.webp","2025-05-12T21:16:19.000Z",60410,932,{},[],[959,978,992],{"id":960,"news_id":961,"tags_id":975},4951,{"id":935,"status":15,"user_created":233,"date_created":936,"user_updated":59,"date_updated":937,"title":938,"type":793,"body":939,"image":951,"date":940,"topic":962,"slug":942,"activity":963,"nid":946,"topics":964,"activities":965,"programme":16,"area":16,"websites":966,"translation_of":16,"language":16,"countries":967,"tags":968,"authors":971,"images":972,"translations":973,"content":974},[536],[944,945],[543],[944,945],[808],[],[960,969,970],4952,4953,[],[],[],[],{"id":976,"name":977},854,"Virtual assets",{"id":969,"news_id":979,"tags_id":991},{"id":935,"status":15,"user_created":233,"date_created":936,"user_updated":59,"date_updated":937,"title":938,"type":793,"body":939,"image":951,"date":940,"topic":980,"slug":942,"activity":981,"nid":946,"topics":982,"activities":983,"programme":16,"area":16,"websites":984,"translation_of":16,"language":16,"countries":985,"tags":986,"authors":987,"images":988,"translations":989,"content":990},[536],[944,945],[543],[944,945],[808],[],[960,969,970],[],[],[],[],{"id":4,"name":5},{"id":970,"news_id":993,"tags_id":1005},{"id":935,"status":15,"user_created":233,"date_created":936,"user_updated":59,"date_updated":937,"title":938,"type":793,"body":939,"image":951,"date":940,"topic":994,"slug":942,"activity":995,"nid":946,"topics":996,"activities":997,"programme":16,"area":16,"websites":998,"translation_of":16,"language":16,"countries":999,"tags":1000,"authors":1001,"images":1002,"translations":1003,"content":1004},[536],[944,945],[543],[944,945],[808],[],[960,969,970],[],[],[],[],{"id":312,"name":313},[],[],[],[],{"id":1011,"status":15,"date_created":1012,"date_updated":1013,"title":1014,"type":1015,"body":1016,"date":1017,"topic":1018,"slug":1019,"activity":1020,"nid":1022,"topics":1023,"activities":1024,"programme":16,"area":16,"websites":1025,"language":16,"image":1026,"translation_of":16,"countries":1033,"tags":1070,"authors":1141,"images":1156,"translations":1157,"content":1158},9581,"2022-05-26T22:52:48.000Z","2026-05-29T22:21:44.000Z","New analysis of the Toledo-Odebrecht case illuminates the complex transnational networks behind corruption and money laundering schemes","Blog","What does the web of connections look like that underlies grand corruption and money laundering schemes and the abuse of offshore financial centres? Who are the people involved, how do they interact and what do they do?\n\nAnd what insights can we draw by looking at complex corruption and money laundering schemes from the perspective of social networks, rather than solely individuals?\n\nThese questions are at the heart of a new analysis of the so-called Lava Jato or Odebrecht scandal that has engulfed Latin America.\n\nIn [_Working Paper 36: Revealing the networks behind corruption and money laundering schemes_](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fworking-paper-36-revealing-networks-behind-corruption-and-money-laundering-schemes), we have applied a combination of social network analysis and network ethnography to a specific nexus within this complex of cases: former Peruvian President Alejandro Toledo and the network that enabled him to launder bribes obtained from the construction giant Odebrecht through offshore jurisdictions.\n\n### What do the results show?\n\nFirst, it shows how the illicit scheme worked, step by step, and the functions of the different individuals and clusters of individuals involved.\n\nThe scheme was highly sophisticated both technologically and financially, involving complex illicit exchanges across borders and within the murky space of offshore financial infrastuctures. The interaction between the “business” pillar (Odebrecht’s leadership and representatives) and the “political” pillar (senior public officials and other politically exposed persons) was smooth and efficient, facilitated by a web of service providers and revolving around companies, offshore corporate vehicles and bank accounts.\n\nIt was this “social-financial complex” of individuals and structures that enabled the beneficiaries to disconnect themselves from the corrupt acts and money laundering – not just the technical and legal loopholes that exist in offshore financial centres or even the weaknesses of international cooperation on crime and corruption.\n\nSecond, the research illuminates the social norms and informal governance practices that regulated the scheme.\n\nThe inner circles of the key players on both the business and the political sides acted as the first line of defence. This is common in corruption schemes and made possible by the level of proximity, trust and reciprocity between a business leader and their subordinates, or between a politically exposed person and their circle of relatives, colleagues and friends.\n\nThe second line of defence is the set of knowledge, skills and social capital that service providers and financial intermediaries bring to the table. Through their services, these actors design the complex financial infrastructure that allows the illicit proceeds of corruption to be laundered through multiple layers and tangled chains until it is nearly impossible to be traced.\n\nThese service providers and intermediaries, together with the financial infrastructure they design, form a multi-layered ecosystem that works efficiently thanks to a strong informal governance system.\n\n*   Strategic decisions on inputs, outputs and rules are _centralised_ among the core political and business actors.\n*   Operations are _decentralised_ and spread out among lower-level business managers or employees and among the political actors’ sprawling networks, who in turn employ service providers and financial intermediaries to carry out the work.\n\nThis mix between centralisation and decentralisation results in an efficient, effective and resilient way to govern such a large, cross-border, multi-layered and complex social-financial structure – and most importantly, to keep it hidden for so long.\n\n### Shifting the focus from individuals to networks\n\nThe research results add a further illustration to the growing recognition that corruption is a form of collective, social behaviour that slips easily across borders and involves highly sophisticated financial strategies and transactions.\n\nThe clear implication is that narrow approaches to corruption, from a national perspective and focused on individuals and their self-interested behaviours, provide an incomplete picture at best.\n\nShifting the focus from individuals to networks through techniques such as social network analysis and network ethnography can offer valuable insights to inform anti-corruption policies, law enforcement strategies and the academic theories that underpin these.\n\n*   For law enforcement, this analysis illustrates how SNA and network ethnography techniques can be applied to identify key individuals and clusters, the spaces in which they operate and the criminal strategies they employ. This approach has the potential to make major investigations and prosecutions more efficient, more targeted and more likely to succeed, as it opens up new pathways and tools to break into the case and gain the information hidden within the network.\n*   For policy, the research provides further insight into some of the legislative weaknesses that allow offshore financial centres to be abused, as well as the consequence of these weaknesses for global efforts to combat corruption and other crime. Shining a light on the illicit nexus that exists between corruption and money laundering may help policymakers to close those gaps.\n*   For the academic debate, the research adds fresh empirical evidence to the study of the relation between grand corruption and money laundering. It explores key analytical and theoretical concepts that are as yet under-explored in this field, and provides a starting point for future research to illuminate these.\n\n### Widening perspectives\n\nAll of us who wish to find more effective ways to combat corruption and money laundering should be open to new ways to analyse corruption schemes, understand their workings and to follow the money as it flows around the world. The value of the “network” perspective is something that our wider Public Governance research demonstrates time and again in very different contexts.\n\nLearn more about the research, training and technical assistance activities of our [Public Governance team](https:\u002F\u002Fbaselgovernance.org\u002Fpublic-governance) and about how our [International Centre for Asset Recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery) helps build the capacity of partner countries to trace illicit financial flows and recover money stolen through corruption.\n\nView and download [Working Paper 36: Revealing the networks behind corruption and money laundering schemes: an analysis of the Toledo–Odebrecht case using social network analysis and network ethnography](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fworking-paper-36-revealing-networks-behind-corruption-and-money-laundering-schemes).","2021-07-08",[536,797,798],"new-analysis-of-the-toledo-odebrecht-case-illuminates-the-complex-transnational-networks-behind-corruption-and-money-laundering-schemes-2051",[801,1021,802],"Reports",2051,[543,805],[801,1021,802],[808],{"id":1027,"storage":45,"filename_disk":1028,"filename_download":812,"title":1014,"type":813,"created_on":1029,"modified_on":1029,"charset":16,"filesize":1030,"width":816,"height":1031,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":1032,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":1029},"b9261861-e157-4940-b515-8a1b318a8b55","b9261861-e157-4940-b515-8a1b318a8b55.webp","2025-05-12T21:18:00.000Z",48766,933,{},[1034,1056],{"id":1035,"news_id":1036,"countries_id":1055},7319,{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1037,"slug":1019,"activity":1038,"nid":1022,"topics":1039,"activities":1040,"programme":16,"area":16,"websites":1041,"translation_of":16,"language":16,"countries":1042,"tags":1044,"authors":1050,"images":1052,"translations":1053,"content":1054},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],7320,[1045,1046,1047,1048,1049],5131,5798,5799,5800,5801,[1051],1191,[],[],[],{"id":253,"name":254,"code":255,"latitude":256,"longitude":257},{"id":1043,"news_id":1057,"countries_id":1069},{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1058,"slug":1019,"activity":1059,"nid":1022,"topics":1060,"activities":1061,"programme":16,"area":16,"websites":1062,"translation_of":16,"language":16,"countries":1063,"tags":1064,"authors":1065,"images":1066,"translations":1067,"content":1068},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],[1045,1046,1047,1048,1049],[1051],[],[],[],{"id":274,"name":275,"code":276,"latitude":277,"longitude":278},[1071,1085,1099,1113,1127],{"id":1045,"news_id":1072,"tags_id":1084},{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1073,"slug":1019,"activity":1074,"nid":1022,"topics":1075,"activities":1076,"programme":16,"area":16,"websites":1077,"translation_of":16,"language":16,"countries":1078,"tags":1079,"authors":1080,"images":1081,"translations":1082,"content":1083},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],[1045,1046,1047,1048,1049],[1051],[],[],[],{"id":4,"name":5},{"id":1046,"news_id":1086,"tags_id":1098},{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1087,"slug":1019,"activity":1088,"nid":1022,"topics":1089,"activities":1090,"programme":16,"area":16,"websites":1091,"translation_of":16,"language":16,"countries":1092,"tags":1093,"authors":1094,"images":1095,"translations":1096,"content":1097},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],[1045,1046,1047,1048,1049],[1051],[],[],[],{"id":451,"name":452},{"id":1047,"news_id":1100,"tags_id":1112},{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1101,"slug":1019,"activity":1102,"nid":1022,"topics":1103,"activities":1104,"programme":16,"area":16,"websites":1105,"translation_of":16,"language":16,"countries":1106,"tags":1107,"authors":1108,"images":1109,"translations":1110,"content":1111},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],[1045,1046,1047,1048,1049],[1051],[],[],[],{"id":468,"name":469},{"id":1048,"news_id":1114,"tags_id":1126},{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1115,"slug":1019,"activity":1116,"nid":1022,"topics":1117,"activities":1118,"programme":16,"area":16,"websites":1119,"translation_of":16,"language":16,"countries":1120,"tags":1121,"authors":1122,"images":1123,"translations":1124,"content":1125},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],[1045,1046,1047,1048,1049],[1051],[],[],[],{"id":485,"name":486},{"id":1049,"news_id":1128,"tags_id":1140},{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1129,"slug":1019,"activity":1130,"nid":1022,"topics":1131,"activities":1132,"programme":16,"area":16,"websites":1133,"translation_of":16,"language":16,"countries":1134,"tags":1135,"authors":1136,"images":1137,"translations":1138,"content":1139},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],[1045,1046,1047,1048,1049],[1051],[],[],[],{"id":912,"name":913},[1142],{"id":1051,"news_id":1143,"authors_id":1155},{"id":1011,"status":15,"user_created":233,"date_created":1012,"user_updated":59,"date_updated":1013,"title":1014,"type":1015,"body":1016,"image":1027,"date":1017,"topic":1144,"slug":1019,"activity":1145,"nid":1022,"topics":1146,"activities":1147,"programme":16,"area":16,"websites":1148,"translation_of":16,"language":16,"countries":1149,"tags":1150,"authors":1151,"images":1152,"translations":1153,"content":1154},[536,797,798],[801,1021,802],[543,805],[801,1021,802],[808],[1035,1043],[1045,1046,1047,1048,1049],[1051],[],[],[],{"id":929,"name":930,"position":16,"image":352},[],[],[],{"id":1160,"status":15,"date_created":1161,"date_updated":1162,"title":1163,"type":1015,"body":1164,"date":1165,"topic":1166,"slug":1167,"activity":1168,"nid":1170,"topics":1171,"activities":1172,"programme":16,"area":16,"websites":1173,"language":16,"image":1174,"translation_of":16,"countries":1181,"tags":1182,"authors":1199,"images":1217,"translations":1218,"content":1219},9659,"2022-05-26T22:53:55.000Z","2026-05-29T22:21:48.000Z","Phyllis Atkinson's quick guide to offshore structures and  beneficial ownership","Money laundering schemes frequently involve complex webs of transactions and structures that offer disguise, concealment and anonymity, and transcend international borders. The use of corporate vehicles or “structures” is a common way to launder dirty money and make it appear to come from a legitimate source.  Yet while major corruption and money laundering cases often have an international dimension and involve such complex schemes, investigators and prosecutors generally have little knowledge of corporate vehicles outside their own country, and often lack the resources to obtain evidence from other jurisdictions. These difficulties are compounded by differences in legal systems and terminology, and by the random use of terms like “tax haven” and “secrecy jurisdiction”. This quick guide looks at how criminals obtain a veneer of respectability and exploit secrecy by manipulating and misusing corporate vehicles in offshore jurisdictions. It focuses on the meaning of \"corporate vehicle\" and \"offshore\" and other related concepts such as beneficial ownership. It also gives an example of how a trust, which is one common type of corporate vehicle in the vast \"offshore ecosystem\", can be used for illicit purposes. \n\n### What is a corporate vehicle? \n\n_Corporate_ primarily means relating to a company, as defined [here](http:\u002F\u002Fwww.duhaime.org\u002FLegalDictionary\u002FC\u002FCompany.aspx). From the juristic point of view, a company is a separate, legally recognised corporate entity, created by means of a fictional veil between the company and its members. This “corporate veil” shields the people behind the company from personal liability. The corporate veil is pierced when: \n\n*   Firstly, it is established that the individuals behind the corporate entity control its finances and business practices to the extent that it no longer has a separate will or existence. \n*   Secondly, the control has resulted in a criminal, dishonest or unjust act which caused injury or unjust loss. \n\nCorporate vehicles, including corporations, trusts, foundations, partnerships with limited liability and similar structures, have become an integral and indispensable component of the modern global financial landscape. However, as the Financial Action Task Force (FATF) has emphasised for years, they may be exploited for unlawful purposes including money laundering, in addition to bribery\u002Fcorruption and the misappropriation of public funds.  Criminals can be extremely creative in their use of techniques and mechanisms to obscure their ownership and control of illicitly obtained assets. The challenge for practitioners is to \"see through\" the corporate veil provided by the structure to identify the controlling party and ultimate beneficial owner. \n\n### Offshore financial centres – what and where are they?\n\nAlthough the term _offshore_ is not defined by the FATF, in the context of corporate vehicles, offshore refers to something located or based in a foreign country. It is commonly used to describe foreign banks, trusts, corporations, investments and deposits.  Although a company may legitimately move offshore for the purpose of (legal) tax avoidance or to enjoy relaxed regulations, offshore structures can also be used for illicit purposes such as money laundering and tax evasion. This is particularly the case for structures such as companies, partnerships or trusts formed in offshore financial centres (OFCs).  OFCs are jurisdictions whose corporate vehicles are primarily used by non-residents. They include well-known centres like Switzerland, Bermuda and the Cayman Islands, and less well-known centres like Mauritius, Dublin and Belize. The level of regulatory standards and transparency differs widely among OFCs.  The significance of offshore jurisdictions in the context of criminal investigations is the manner in which some provide excessive secrecy for their corporate vehicles, thereby creating a favourable environment for their use for illicit purposes.\n\n### How are corporate vehicles used for criminal purposes?\n\nCorporate vehicles often play a central role in concealing the proceeds of corruption, money laundering and the beneficial ownership of illicit assets. Corrupt public officials and money launderers do not want to keep their dirty money in their own names. Therefore, what they typically do is create a company – or a series of companies – and have the company own their assets. The company can open a bank account, buy a yacht or a mansion, and wire money around the world. Particularly in offshore jurisdictions that offer excessive secrecy for their corporate vehicles, it is immensely difficult and sometimes totally impossible to trace the money back to the person who really owns it. This makes these vehicles an attractive mechanism for hiding, moving and using illicitly obtained money or other assets.  There is a large range of corporate vehicles in different jurisdictions. Sometimes they have the same or similar names but different characteristics or else similar characteristics but different names. This brief description of three commonly used structures – shell companies, shelf companies and trusts (in the English common law tradition) – is designed only to give a flavour of how offshore structures can be abused.\n\n#### Shell company\n\nA _shell company_ can be defined as a non-operational company, i.e. a legal entity that has no independent operations, significant assets, ongoing business activities or employees. Typically, a shell company is provided by a professional intermediary to a corrupt party who then uses it to obscure the money trail by transferring the illicit funds into and out of the company’s bank accounts. A shell company has no physical presence in its jurisdiction. Its main or sole purpose is to insulate the real beneficiary (ultimate beneficial owner) from taxes, disclosure or both. Shell companies are also referred to as front companies or mailbox\u002Fletterbox companies. One specific type of shell company structure is the international business corporation (IBC) which is typically used for shell companies set up by non-residents in OFCs. IBCs make ideal shell companies because they are not permitted to conduct business in the incorporating jurisdiction and are generally exempt from local income taxes. Shell companies constitute a substantial proportion of the corporate vehicles established in some OFCs. Given their function, shell companies face an increased risk of being misused.  \n\n#### Shelf company\n\nA _shelf_ (or _off the shelf_) company is a category of, and similar to, shell companies, in that it offers no real \"brick and mortar\" company. A shelf company is a corporation that has had no activity. It has been created, left dormant and put on the \"shelf\". This corporation is then later usually sold to someone who would prefer to have an existing corporation than a new one. The significant difference between shell and shelf companies lies in the age of the respective companies since incorporation, with the value of a shelf company being based upon its history and banking relationships in addition to its age.  In some jurisdictions, incorporation procedures can be time-consuming. It is often easier, quicker and less expensive to transfer ownership of a shelf company than to incorporate a new one. Lenders sometimes require a business to have been in existence from six months to two years or more before lending it money, and many agencies will only sign contracts with a company that has been in business for at least two years.\n\n#### Trust\n\nThe concept of a _trust_ is probably less familiar with most than that of the company but it has been around for longer. The trust is a legal relationship which originated historically in England and developed mainly in states with a common law or Anglo-Saxon legal tradition, e.g. Great Britain, USA, Australia, Canada, South Africa and New Zealand. Structures similar to trusts can be found in other countries, e.g. Japan, Panama, Liechtenstein, Mexico, Colombia, Israel and Argentina. A trust in this sense is a legal arrangement or relationship whereby a person (\"trustee\") owns assets not for their own use and benefit but for the benefit of others (\"beneficiaries\"). Unlike a company, it is a corporate vehicle which does not have a separate legal personality and distinguishes legal ownership from beneficial ownership of assets vested in a trust.  The key points to understand are:\n\n*   The essential components or parties to a trust are the settlor, trustee, beneficiaries and trust property. \n*   The settlor transfers ownership of certain assets to trustees by means of a trust deed or declaration of trust (although it does not have to be reduced to writing).\n*   These assets are to be managed and used for the benefit of named or unnamed beneficiaries. This constitutes a binding obligation. \n*   In the process of transferring, or \"settling\", certain property, the legal ownership or control of the assets (known as the trust property) is separated from the beneficial interest in such assets. \n\nIn this context, a beneficiary is a person who is designated to receive something as a result of a trust arrangement. A trust may be set up with no identified existing beneficiaries, but the beneficiaries to a trust must be ultimately ascertainable. In this case, the trust provides the trustee with certain powers to administer the assets, which operate until such point when, under the terms of the trust, an individual or group of individuals become entitled as beneficiaries to income or capital on the expiry of a defined period. Some types of trust allow the beneficiary to be named or changed at any time, meaning their identify can be kept secret until ownership of the assets is transferred to them. The separation of the legal ownership of the trust assets, which lies with the trustee, from the right to benefit from those assets, which lies with the beneficiaries, is the crucial factor to understanding trusts. Simultaneously, it is essential to understand that a \"beneficiary\" is not the equivalent of  a \"beneficial owner\" (see below).\n\n### Unravelling beneficial ownership of trusts\n\nDuring a criminal investigation involving corporate vehicles, particularly those formed in offshore jurisdictions, the crux of the issue for any practitioner is identifying the \"beneficial owner\" of the corporate vehicle. This refers to the person (or group of people) who have an interest in or control over ill-gotten gains and are trying to conceal the fact through the misuse of corporate vehicles. According to the FATF definition, [beneficial owner](https:\u002F\u002Fwww.fatf-gafi.org\u002Fglossary\u002F) refers to the natural person(s) who ultimately owns or controls an asset, and directly or indirectly enjoys its benefits. The beneficial owner also owns or controls the customer and\u002For the natural person who may appear to own or control the asset and on whose behalf a transaction is being conducted in order to hide the true ownership. The term also includes those persons who exercise ultimate effective control over a legal person or arrangement.  The defining characteristic of the beneficial owner of a trust asset (as opposed to a beneficiary) is that he (or she) holds a degree of control over the asset that allows him to benefit from it. Whether he is the _legal_ owner, i.e. holds a legal title to it, or a trust beneficiary is irrelevant. Importantly, a beneficial owner must always be a natural person, as a legal person cannot exert \"ultimate\" control over an asset. This is due to the fact that legal persons are always controlled, directly or indirectly, by natural persons.  In the context of legitimate trusts, none of the following qualify as the beneficial owner as previously defined:\n\n*   The trustee exerts control over an asset but is not an ultimate controller as he is legally bound to act in the interests of the beneficiary. \n*   The settlor of the trust initiates the trust and relinquishes legal ownership of trust assets to the trustee for the benefit of the beneficiary; however, he may also continue to exert some level of control or influence over the trust. \n*   The beneficiary stands to benefit but generally cannot exercise any control over the trust.\n\nHowever, for criminal investigative purposes, beneficial ownership for trusts can arguably encompass a combination of actors: the settlor, the trustees, the beneficiaries or any other individual who, in practice, exercises ultimate effective control over the trust and enjoys its ill-gotten benefits.\n\n### Find out more\n\n*   These topics are covered in much (much!) greater detail and depth in [training courses of the International Centre for Asset Recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) (ICAR), in particular on [Offshore Structures and Mutual Legal Assistance](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes\u002Foffshore-structures-and-mutual-legal-assistance). \n*   As Head of Training ICAR, the author Phyllis Atkinson has developed and delivered highly specialised training on these and related topics to investigators, prosecutors, financial analysts and judges all over the world. You can find out about ICAR’s unique approach to training in her [quick guide to effective training on financial investigations](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-6-effective-training-financial-investigations). \n*   The OECD’s 2001 publication [_Behind the Corporate Veil: using corporate entities for illicit purposes_](https:\u002F\u002Fwww.oecd.org\u002Fdaf\u002Fca\u002Fbehindthecorporateveilusingcorporateentitiesforillicitpurposes.htm) looks at the types of corporate entities that are most frequently misused and “urges governments to combat such misuse by acting to ensure the availability of information about ownership and control”.\n*   Key FATF publications on this topic include: [_FATF guidance on transparency and beneficial ownership_](http:\u002F\u002Fwww.fatf-gafi.org\u002Fmedia\u002Ffatf\u002Fdocuments\u002Freports\u002FGuidance-transparency-beneficial-ownership.pdf) (October 2014) and [_Best practices on beneficial ownership for legal persons_](https:\u002F\u002Fwww.fatf-gafi.org\u002Fmedia\u002Ffatf\u002Fdocuments\u002FBest-Practices-Beneficial-Ownership-Legal-Persons.pdf) (October 2019).\n*   [Download this guide as a PDF](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fquick-guide-19-offshore-structures-and-beneficial-ownership) or view on our [LEARN](https:\u002F\u002Flearn.baselgovernance.org\u002Fcourse\u002Fview.php?id=49) platform alongside other quick guides and resources to fight financial crime.","2020-11-12",[535,536],"phyllis-atkinson039s-quick-guide-to-offshore-structures-and-beneficial-ownership-1912",[1169],"Training",1912,[535,543],[1169],[808],{"id":1175,"storage":45,"filename_disk":1176,"filename_download":812,"title":1177,"type":813,"created_on":1161,"modified_on":1161,"charset":16,"filesize":1178,"width":1179,"height":1180,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":16,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":1161},"7bf899e0-c153-44e7-b2c7-2a1568f60d7e","7bf899e0-c153-44e7-b2c7-2a1568f60d7e.webp","Phyllis Atkinson's quick guide to offshore structures and  beneficial ownership",17030,800,533,[],[1183],{"id":1184,"news_id":1185,"tags_id":1198},4285,{"id":1160,"status":15,"user_created":233,"date_created":1161,"user_updated":59,"date_updated":1162,"title":1163,"type":1015,"body":1164,"image":1175,"date":1165,"topic":1186,"slug":1167,"activity":1187,"nid":1170,"topics":1188,"activities":1189,"programme":16,"area":16,"websites":1190,"translation_of":16,"language":16,"countries":1191,"tags":1192,"authors":1193,"images":1195,"translations":1196,"content":1197},[535,536],[1169],[535,543],[1169],[808],[],[1184],[1194],822,[],[],[],{"id":4,"name":5},[1200],{"id":1194,"news_id":1201,"authors_id":1213},{"id":1160,"status":15,"user_created":233,"date_created":1161,"user_updated":59,"date_updated":1162,"title":1163,"type":1015,"body":1164,"image":1175,"date":1165,"topic":1202,"slug":1167,"activity":1203,"nid":1170,"topics":1204,"activities":1205,"programme":16,"area":16,"websites":1206,"translation_of":16,"language":16,"countries":1207,"tags":1208,"authors":1209,"images":1210,"translations":1211,"content":1212},[535,536],[1169],[535,543],[1169],[808],[],[1184],[1194],[],[],[],{"id":1214,"name":1215,"position":16,"image":1216},305,"Phyllis Atkinson","20349a63-a604-4335-b829-b948b434e359",[],[],[],{"id":1221,"status":15,"date_created":1222,"date_updated":1223,"title":1224,"type":793,"body":1225,"date":1226,"topic":1227,"slug":1228,"activity":1229,"nid":1231,"topics":1232,"activities":1233,"programme":16,"area":16,"websites":1234,"language":16,"image":1235,"translation_of":16,"countries":1242,"tags":1243,"authors":1274,"images":1275,"translations":1276,"content":1277},9774,"2022-05-26T22:55:30.000Z","2025-08-31T23:14:59.000Z","High-level workshop on the legal consequences of corruption and money laundering in international arbitration","Over 80 arbitrators, lawyers and experts from around the world gathered at the University of Basel on 10 January 2020 to tackle the thorny issues of corruption and money laundering in international arbitration.\n\nCorruption and money laundering affecting an underlying dispute are a considerable challenge for arbitrators and parties in investment and commercial arbitration. If corruption and\u002For money laundering is established, arbitrators need to decide about the legal consequences for the parties’ claims.\n\nThe high-level workshop, Legal Consequences of Corruption and Money Laundering in International Arbitration, covered several questions.\n\nIn investment arbitration:\n\n*   Corruption always takes two. Should a host state be held responsible for the corruption of its officials?\n*   Should a bribe at the beginning of an investment allow a state to successfully raise the corruption defence years later?\n*   Should the giving of a relatively small bribe result in the investor losing all protection under international dispute settlement mechanisms?\n*   What if a real dispute between parties involves the transfer of funds of illicit origin?\n\nIn commercial arbitration:\n\n*   What is a proportionate solution for contracts procured by bribery?\n*   What about restitution of the bribe?\n*   What is the practice of courts in France, UK, Switzerland etc. regarding enforcement of arbitral awards?\n*   What if the parties bring a fake dispute to arbitration in order to get an award that involves the transfer of funds of illicit origin?\n*   Should arbitrators and\u002For arbitral institutions have a duty (or a right) to report suspected money laundering?\n\n### About the workshop\n\nThe University’s Competence Centre for Arbitration and Crime organised the workshop as a follow-up to the 2019 [Toolkit for Arbitrators](https:\u002F\u002Fwww.baselgovernance.org\u002Fpublications\u002Fcorruption-and-money-laundering-international-arbitration-toolkit-arbitrators) workshop and resulting publication. The Toolkit was mentioned several times as providing useful assistance to Tribunals when examining red flags.\n\nThe organisers wish to thank the event sponsors: [PWC](https:\u002F\u002Fwww.pwc.ch\u002F), [BDO](https:\u002F\u002Fwww.bdo.ch\u002Fen-gb\u002Fhome-en), [Bonifassi Avocats](https:\u002F\u002Fbonifassi-avocats.com\u002Fen\u002F), [Homburger](https:\u002F\u002Fwww.homburger.ch\u002F), [Vischer](https:\u002F\u002Fwww.vischer.com\u002Fen\u002F), and [Schellenberg Wittmer](https:\u002F\u002Fwww.swlegal.ch\u002Fen\u002F). Partner organisations are the [University of Basel](https:\u002F\u002Fwww.unibas.ch\u002Fen.html), [Basel Institute on Governance](http:\u002F\u002Fwww.baselgovernance.org\u002F), [Swiss Institute of Comparative Law](https:\u002F\u002Fwww.isdc.ch\u002Fen\u002F) and [The International Academy of Financial Crime Litigators](http:\u002F\u002Fwww.financialcrimelitigators.org\u002F).\n\nThe workshop was opened by [Mark Pieth](https:\u002F\u002Fwww.pieth.ch\u002F), Professor of Criminal Law at the University of Basel and President of the Basel Institute on Governance. The keynote speech was given by [Alexis Mourre](https:\u002F\u002Fwhoswholegal.com\u002Falexis-mourre), President of the ICC International Court of Arbitration.\n\n### Learn more\n\n*   See the [Arbitration and Crime Competence Centre website](https:\u002F\u002Farbcrime.org\u002Fworkshop2020).\n*   Read the [opening remarks by Alexis Mourre](https:\u002F\u002Ffiles.web.host.ch\u002Fb8\u002F79\u002Fb879cd88-7475-4be6-828c-0840879b01cf.pdf), President of the ICC International Court of Arbitration.\n*   [View and download photos on Flickr](https:\u002F\u002Fwww.flickr.com\u002Fphotos\u002F186407681@N02\u002Falbums\u002F72157712606359982)[.](https:\u002F\u002Farbcrime.org\u002Fworkshop2020)","2020-01-10",[535],"high-level-workshop-on-the-legal-consequences-of-corruption-and-money-laundering-in-international-arbitration-1055",[944,1230],"Presentations",1055,[535],[944,1230],[808],{"id":1236,"storage":45,"filename_disk":1237,"filename_download":812,"title":1224,"type":813,"created_on":1238,"modified_on":1238,"charset":16,"filesize":1239,"width":816,"height":1240,"duration":16,"embed":16,"description":16,"location":16,"tags":16,"metadata":1241,"focal_point_x":16,"focal_point_y":16,"tus_id":16,"tus_data":16,"uploaded_on":1238},"fcf07252-3936-482c-b317-836874bd077e","fcf07252-3936-482c-b317-836874bd077e.webp","2025-05-12T21:21:09.000Z",54566,844,{},[],[1244,1260],{"id":1245,"news_id":1246,"tags_id":1259},5374,{"id":1221,"status":15,"user_created":233,"date_created":1222,"user_updated":60,"date_updated":1223,"title":1224,"type":793,"body":1225,"image":1236,"date":1226,"topic":1247,"slug":1228,"activity":1248,"nid":1231,"topics":1249,"activities":1250,"programme":16,"area":16,"websites":1251,"translation_of":16,"language":16,"countries":1252,"tags":1253,"authors":1255,"images":1256,"translations":1257,"content":1258},[535],[944,1230],[535],[944,1230],[808],[],[1245,1254],5375,[],[],[],[],{"id":912,"name":913},{"id":1254,"news_id":1261,"tags_id":1273},{"id":1221,"status":15,"user_created":233,"date_created":1222,"user_updated":60,"date_updated":1223,"title":1224,"type":793,"body":1225,"image":1236,"date":1226,"topic":1262,"slug":1228,"activity":1263,"nid":1231,"topics":1264,"activities":1265,"programme":16,"area":16,"websites":1266,"translation_of":16,"language":16,"countries":1267,"tags":1268,"authors":1269,"images":1270,"translations":1271,"content":1272},[535],[944,1230],[535],[944,1230],[808],[],[1245,1254],[],[],[],[],{"id":4,"name":5},[],[],[],[],7,1780676636643]