Anti-corruption
News and blog
How will the EU Anti-Corruption Directive affect enforcement against corruption?
What does the EU's new Anti-Corruption Directive actually change, and where does it fall short? This article by Rita Simões of the Basel Institute’s International Centre for Asset Recovery takes a closer look at the final text. She looks at what was adopted, what was left out during negotiations, and what the final text is likely to mean for enforcement across the EU. For a broader reflection on what the directive reveals about changing corruption risks and the future direction of EU anti-corruption policy, see a companion analysis by Dr Jacopo Costa. The European Union EU has adopted and published its Anti-Corruption Directive, concluding a process that began with the Commission’s proposal in May 2023. Its adoption comes amid a broader recalibration of global anti-corruption enforcement, marked by decreased U.S. leadership through the scaling back of Foreign Corrupt Practices Act enforcement and increased expectations for the EU to assume a more central role in global anti-corruption efforts. Following a lengthy negotiation period, the final directive is a compromise between the widely differing levels of ambition reflected in the proposals put forth by the European Parliament and European Commission. It establishes a common baseline of corruption offences, corporate liability rules and jurisdiction, but leaves member states significant discretion to limit the scope of new measures. The final version also omits key provisions relating to political financing, non-trial resolutions and victims’ rights. Therefore, the directive's central achievement is the harmonisation of anti-corruption offences and sanctions. Its central limitation is that it leaves key aspects of enforcement practice largely in the hands of member states. Important changes in criminal law, liability and jurisdiction The directive establishes a detailed enforcement and prevention framework. It requires member states to, among others: - create independent anti-corruption bodies; - adopt national strategies; - conduct sector-specific risk assessments; - provide training for officials; and - use Europol’s SIENA system for information exchange. These measures are complemented by harmonised statistical reporting obligations on investigations, prosecutions and sanctions. On substantive criminal law, the directive introduces a harmonised baseline of corruption offences across member states including domestic and foreign bribery, trading in influence, misappropriation, abuse of functions and obstruction of justice. The directive also requires member states to establish a broad criminal liability regime for legal persons . Under this framework, companies can be held accountable for corruption offences, including those resulting from lapses in senior management supervision. Notably, the directive reinforces this regime through obligating the use of dissuasive measures, such as fines based on global turnover and exclusion from public procurement. The directive also strengthens jurisdictional rules. Member states must assert jurisdiction over offences committed on their territory or by their nationals. Furthermore, a member state can prosecute offences committed abroad without needing the state where the crime occurred to report it first. . How these could help enhance anti-corruption enforcement These measures aim to strengthen the EU’s enforcement capacity by expanding the legal tools available to investigate and prosecute corruption, particularly in cross-border cases. Measures on corporate liability, for instance, will strengthen the ability of member states to address complex bribery schemes involving multinational structures. Similarly, the enhanced jurisdictional rules will enable member states to pursue corruption cases that occurred outside their territory, even where the state in which the corruption took place is unwilling or unable to act. In addition, the institutional and procedural framework – particularly coordination, risk assessments and dedicated enforcement bodies – should strengthen the EU’s ability to prevent, detect, investigate and prosecute corruption. However, enforcement effectiveness will still depend heavily on national implementation capacity and political will. Three missed opportunities: political financing, non-trial resolutions and victim participation Previously identified as areas of significant potential, several key measures proposed by the European Parliament that could have further enhanced enforcement were excluded or significantly watered down in the final directive. Political financing The European Parliament had proposed stronger measures to tackle illicit political financing, including enhanced transparency requirements and potential criminalisation of certain violations. However, member states are only encouraged – not required – to address risks linked to political funding, with no binding obligation to implement transparency measures or criminalise political financing. This leaves the EU without a harmonised framework in this area. This is a critical gap given growing concerns about how illicit funding can distort electoral processes and enable undue influence over public decision-making, both globally and at the European level653631 EN.pdf . Non-trial resolutions Proposed mandatory frameworks for non-trial resolutions in cases involving legal persons, reflecting established practice in jurisdictions such as the United Kingdom, were not retained as binding obligations in the final directive. As a result, this instrument does not establish a level playing field across the EU. This is likely to lead to divergent enforcement approaches, with some jurisdictions relying on negotiated resolutions while others depending on full criminal proceedings. Such fragmentation may weaken the effective imposition of financial sanctions on companies, as well as the recovery of proceeds and their use for compensating victims of corruption or enhance anti-corruption efforts. Victim and public participation in corruption cases The final version of the directive requires member states to grant procedural rights to victims and members of the public affected by corruption offences. But it largely relies on existing EU frameworks and national law, providing participation rights only where they already exist domestically. By contrast, the European Parliament’s proposal was more ambitious: it sought to define these categories explicitly, regulate their procedural rights and grant victims a clear right to compensation. As a result, recognition of victims in corruption cases remains uneven across member states. This approach also may limit victim and civil society participation, despite growing international support for more participatory approaches. Anti-corruption ambition is now up to member states The directive adopts an anti-corruption approach that strengthens enforcement powers while maintaining deference to national legal systems. Its effectiveness will depend heavily on implementation, particularly where it sets only minimum standards or leaves room for national discretion. In practice, this is likely to produce uneven legal frameworks across the EU, shaped more by domestic political will than by EU-led harmonisation. Member states implementing the directive will face a choice: - Should they adhere to the minimum requirements only? - Or take the opportunity to pursue more ambitious anti-corruption reforms, including some of the broader measures originally proposed by the European Parliament? Choosing a more ambitious approach presents an opportunity to lead by example and influence future EU reform.
Corruption in the age of networks, data and influence – does the EU's new Anti-Corruption Directive rise to the challenge?
This article by Dr Jacopo Costa is one of two Basel Institute commentaries on the EU's new Anti-Corruption Directive. While the companion piece by Rita Simões examines the directive's legal and institutional implications, this article takes a political economy perspective. It considers what the directive reveals about changing understandings of corruption, how corruption risks are evolving in an increasingly interconnected and technology-driven environment, and where future EU anti-corruption efforts may need to focus. The key message is that the directive represents an important advance in legal harmonisation, but that effective anti-corruption policy will also require stronger strategic thinking, greater use of data and technology, and closer attention to emerging corruption risks linked to procurement, border security and financial infrastructure. April 2026, the European Union formally adopted Directive 2026/1021 on combatting corruption. Following years of negotiations, political disagreements and institutional bargaining, the EU now has a comprehensive anti-corruption framework establishing common definitions, offences, sanctions and preventive measures across its member states. This is a landmark achievement. But it would be a mistake to view the directive as the culmination of the European anti-corruption journey. In fact, its adoption marks the beginning of a much larger challenge: turning a legal framework into an effective EU Anti-Corruption Strategy that can address the evolving forms of corruption emerging in an increasingly complex geopolitical and technological landscape. Why the directive matters For years, the EU lacked a coherent anti-corruption framework. Although member states had their own legislation, there were significant differences in how corruption offences were defined, investigated and punished. These discrepancies created loopholes that could be exploited by corrupt individuals and hindered cross-border cooperation between national authorities. The new directive aims to address these issues by introducing common minimum standards across the EU. In particular, it: - harmonises the definitions of bribery in the public and private sectors, trading in influence, misappropriation, obstruction of justice, illicit enrichment and the concealment of criminal proceeds; - introduces common standards for criminal sanctions, corporate liability, statutes of limitation, whistleblower protection, anti-corruption strategies and specialised anti-corruption bodies; and - broadens the definition of public officials to encompass not only national officeholders, but also senior EU officials and individuals performing public duties on behalf of public institutions. This reflects the reality of contemporary governance, where public services are increasingly delivered through hybrid public–private arrangements. It is the most ambitious attempt yet to establish a shared European anti-corruption framework. A more modern understanding of corruption One of the directive's most significant strengths is its recognition that corruption is not confined to the traditional notion of an envelope stuffed with cash being exchanged. We welcome this change in perspective greatly, because our research demonstrates clearly that contemporary corruption is increasingly networked, sophisticated and relational. It often relies on intermediaries, influence brokers, hidden financial channels, luxury gifts, preferential treatment, future career opportunities and informal exchanges of favours. Including offences such as trading in influence, illicit enrichment, concealing criminal proceeds and aiding or abetting corruption schemes shows an understanding of how corruption operates in modern societies. This evolution is important because anti-corruption frameworks often struggle to keep up with the evolving nature of corruption. The directive is a valuable attempt to address this issue and close the resulting gap. The price of political compromise Legislation is never produced in isolation from politics. Significant disagreements emerged among EU institutions and member states during the adoption process. Several governments expressed concerns about subsidiarity and the potential consequences of criminalising particular behaviours. So, the final directive is less ambitious than the original proposal. One example concerns the offence previously known as “abuse of office”. Following intense political resistance, particularly from countries such as Germany and Italy, the final text replaced it with the more cautious formulation of “unlawful exercise of public functions”. The compromise facilitated agreement, but introduced ambiguity that could hinder enforcement. Similarly, criminal sanctions and limitation periods were reduced during negotiations. Maximum prison sentences were reduced, and statutes of limitation were scaled back considerably compared to earlier drafts. These compromises highlight a recurring dilemma in policymaking not only in Europe but everywhere: achieving consensus often necessitates compromising on ambition. The result is a directive that establishes a common baseline, yet leaves considerable room for interpretation among member states. The missing security lens Perhaps the most significant limitation of the directive is its relatively little guidance on what anti-corruption efforts should look like in today's rapidly changing security environment. Because corruption is increasingly also a geopolitical and security issue. Foreign influence operations, sanctions evasion schemes, strategic corruption, illicit financial networks, organised crime infiltration and the manipulation of critical supply chains all represent corruption-related risks affecting European security and resilience. Yet these challenges remain largely outside the directive's core focus. There is a risk that anti-corruption efforts will continue to focus on traditional forms of misconduct while underestimating emerging threats linked to geopolitical competition and hybrid forms of influence. The technology gap Considering the hype around artificial intelligence in society generally, the most striking omission in the directive is the limited attention devoted to technological innovation. Over the past decade, governments, international organisations and researchers have been exploring how artificial intelligence, big data analytics, risk indicators, predictive modelling and open-source intelligence can bolster anti-corruption initiatives. Technology is now essential for identifying suspicious procurement patterns, pinpointing conflicts of interest, tracing illicit financial flows and exposing corruption networks. Yet the directive contains almost no strategic vision regarding the role of technology in anti-corruption governance, which is surprising. Research conducted under the EU-funded FALCON project – of which the Basel Institute is a consortium member – demonstrates that effective anti-corruption systems are increasingly dependent on digital infrastructures capable of collecting, integrating, analysing and cross-referencing large volumes of information. Without these capabilities, many corruption risks remain invisible until significant damage has already occurred. It’s important to stress that adopting new technologies – purchasing software, etc. – is the easy part. EU states also need to create the institutional and data infrastructures that allow these technologies to function effectively. Digitisation, interoperability, standardised datasets, machine-readable information and cross-border information sharing are all prerequisites for the next generation of anti-corruption systems. Three areas that deserve greater attention From our research in the following areas, we can say for sure that they deserve particular attention in the EU’s Anti-Corruption Strategy and future initiatives: 1\. Public procurement Public procurement remains one of the sectors most vulnerable to corruption. This issue is exacerbated by Europe's increased investment in defence, critical infrastructure, energy security, technological innovation and strategic industrial policies. Central priorities should include strengthening transparency, reducing direct awards, improving oversight of sub-threshold contracts, and introducing AI-based risk assessment tools. 2\. Border governance Managing borders and customs procedures is another critical challenge, as research at the Port of Rotterdam and the Kapitan Andreevo crossing demonstrates. Corruption at the border facilitates a wide range of criminal activities, including smuggling, trafficking, evasion of sanctions, tax fraud and the movement of illicit goods. Greater automation, data integration and harmonisation of border management systems across member states could significantly reduce opportunities for corruption and strengthen the EU's capacity to detect emerging threats. 3\. Financial infrastructures Modern corruption relies heavily on financial infrastructure. Complex financial networks, shell companies, professional intermediaries, offshore structures and, increasingly, cryptoassets can facilitate the movement and concealment of illicit funds. The future of anti-corruption policy hinges on strengthening the links between anti-corruption and anti-money laundering frameworks, and on developing new approaches that can address digital financial ecosystems. Will the EU’s Anti-Corruption Strategy help put the directive into action? The adoption of Directive 2026/1021 sends an important message that corruption remains a priority issue for the European Union. The directive establishes a much-needed common foundation and introduces valuable innovations to improve both prevention and enforcement. It provides a stronger legal framework than the fragmented system that existed previously. But legal harmonisation alone will not be enough. The directive's effectiveness will ultimately depend on how member states implement its provisions, and on whether the European Union can develop a broader strategic vision capable of addressing emerging corruption risks. This is where the forthcoming EU Anti-Corruption Strategy could play a decisive role. To be effective and not just a paper exercise, it must be adaptive, technology-driven and security-conscious. This strategy must respond to current corruption and anticipate its potential evolution. And it needs to be based on a participative process that considers the valuable research and perspectives of civil society organisations, academics and others outside of government. If the directive provides the legal architecture, the strategy can provide the direction. Together, they could form the basis of a more adaptive and forward-looking European anti-corruption framework – one that is able to keep pace with a rapidly changing world.
Holding the corrupt to account: the promise and potential of corruption sanctions
When states fail to hold corrupt actors to account, ordinary citizens pay the price. Corruption sanctions were born from the idea that no one should be above the law, no matter where they are in the world. In a new Working Paper, Dr Anton Moiseienko explores how these tools have evolved and offers recommendations for their more effective and legitimate use. Here we share the foreword to his paper by the Basel Institute's Andrew Dornbierer, Head of Policy and Research, International Centre for Asset Recovery. Foreword Every state has an obligation to investigate and prosecute corruption within their jurisdiction. Unfortunately, many states around the world are not willing to fulfil this responsibility. As a result, the very individuals within these states tasked with serving the public interest are instead given free rein to commit acts that not only serve themselves but also corrode the fabric of the state. And ordinary citizens have no alternative but to endure the ensuing economic and social damage. The development of sanctions tools targeting corruption stemmed from the idea that justice should be universal; that no one in any society around the world should be above the law. They are powerful tools, built on powerful principles. States introducing them understand that unchecked corruption will always suffocate a state’s ability to provide security, fairness and prosperity to its citizens. Comparatively though, corruption sanctions are still an underdeveloped concept and are far from perfect. Only a handful of states have introduced them, and those that have are not often using them to their full potential. They also spark valid concerns surrounding due process. These criticisms shouldn’t be ignored: they offer an insight on how these tools could be further developed and enhanced to ensure that they are more credibly and consistently applied. In his paper, Anton Moiseienko provides an excellent and well-researched overview of how corruption sanctions could be designed and employed to better achieve their potential. He explains how these tools have evolved over the last two decades and how they could be further refined to be more effective and achieve a wider range of impact. Critically, his paper is an indispensable resource for those looking to understand exactly how such sanctions can help states deter, disrupt and debilitate the notoriously corrupt that are unreachable through standard criminal justice tools. Learn more Read Dr Anton Moiseienko’s Working Paper “Corruption sanctions: What governments need to know” for a deeper analysis of the topic and key policy recommendations. Get a brief introduction to corruption sanctions from our related Quick Guide. Register for our public webinar "Corruption sanctions – reaching those beyond the law" on 18 June 2026, marking the launch of Dr Moiseienko's Working Paper.
How stronger borders can create smarter corruption: lessons from one of Europe's most strategic border crossings
When Bulgaria joined the European Union in 2007, many believed it would lead to more secure, transparent and less corrupt borders. New regulations, infrastructure modernisation and digitalised customs procedures all followed. European standards and money arrived together. Yet corruption did not disappear at the Kapitan Andreevo border checkpoint, the main land crossing between Bulgaria and Türkiye and one of the busiest gateways between Europe and Asia. Instead, it evolved. This is the central finding of a recent article by the Prevention, Research and Innovation team of the Basel Institute on Governance – Dr Jacopo Costa, Dr Claudia Baez Camargo, Noémi Jäger and Dr Saba Kassa – published in the Journal of Illicit Trade, Financial Crime, and Compliance . The article examines how criminal networks, smugglers, businesses and corrupt officials adapted to Bulgaria’s EU integration. It illustrates how corruption behaves like an adaptive ecosystem: when regulations and border control technologies change, corruption changes with them. A border built for opportunity – legal and illegal Border spaces concentrate discretionary power in the hands of customs officers, border guards, inspectors and regulators, while bringing together also traders, transport companies, migrants, smugglers, criminal groups and political actors. Kapitan Andreevo is a particularly instructive case due to its strategic location, with thousands of trucks, travellers and goods passing through the border checkpoint daily. Before Bulgaria’s EU accession, corruption at the checkpoint was already deeply embedded. The 1990s brought economic crisis, shortages of consumer goods, weak state capacity and rapidly expanding informal markets. Smuggling became a profitable survival strategy. Border officials could be bribed to overlook undeclared goods, counterfeit products and tax evasion. Duty-free shops in the "no man's land" between Bulgaria and Türkiye became hubs for smuggling cigarettes, alcohol and petroleum products. Corruption operated at multiple levels: everyday exchanges between traders, drivers and officials, often based on long-standing personal relationships, at the lower level connections between politicians, senior civil servants, business elites and organised crime at the higher level. Smuggling routes required political protection. Profits flowed upward through patronage systems. EU accession changed the rules of the game Bulgaria’s EU accession radically transformed the legal and institutional environment. The country had to align its customs regulations, VAT rules, excise tax systems, phytosanitary standards and border procedures with EU standards – a gradual process requiring significant investment. The reforms affected almost every aspect of border governance. Customs procedures became increasingly digitalised. New systems such as the VAT Information Exchange System VIES and the Excise Movement and Control System EMCS improved cross-border monitoring. Phytosanitary and veterinary inspections became stricter. Migration controls tightened through alignment with Schengen rules and access to systems like the Schengen Information System SIS and international databases of stolen documents and vehicles. Meanwhile, new border control technologies – X-ray machines, scanners, thermal cameras and risk-analysis tools – expanded the state’s capacity to detect illicit activity. From a policy perspective, this appeared to be a modernisation success story. But criminal systems rarely remain static when the environment changes. Corruption did not decline – it adapted The most striking finding is that stronger controls often increase the strategic value of corruption. After EU accession, crossing the border illegally became more difficult, risky and expensive. Corruption became necessary not only to speed up procedures but to bypass sophisticated control and regulatory systems. In other words, modernisation transformed the function of corruption: Criminal actors began targeting specialised procedures, such as food safety inspections, VAT systems, automated license plate recognition, laboratory testing and digital customs controls. VAT fraud and the manipulation of digital systems VAT fraud illustrates this adaptation clearly. Within the EU, exports are often subject to a VAT rate of 0 zero percent, which means companies can reclaim any VAT they have already paid domestically. Criminal actors exploited this through "carousel fraud" schemes involving fictitious transactions chains. At Kapitan Andreevo border checkpoint, for example, corruption allegedly enabled traders to manipulate customs procedures. One method involved corrupt officials manually entering fake truck registrations into customs systems to simulate border crossings, enabling fraudulent VAT refunds for exports that never occurred. Even more revealing was the manipulation of automated license plate recognition: corrupt actors reportedly disabled automated recognition and manually entered altered plates using Cyrillic characters resembling Latin letters, allowing smugglers to bypass alerts and inspections. This illustrates a pattern seen in many modern corruption systems: digitalisation does not automatically eliminate corruption. Instead, corruption turns towards the technological systems themselves. Food safety, privatisation and rent-seeking EU food safety and phytosanitary regulations created new bottlenecks and forms of discretionary authority. The research describes two recurring manipulation strategies: selective sampling during inspections, where officials took samples only from "clean" sections of shipments; and falsification of laboratory tests to certify unsafe products as compliant. These risks increased after some border functions were outsourced to private companies. At Kapitan Andreevo, food testing, parking operations and vehicle disinfection were privatised. This reform, intended to increase efficiency, allegedly created new opportunities for rent extraction. The controversy surrounding Eurolab 2011, which reportedly obtained monopolistic control over food safety testing under questionable legal arrangements became emblematic of these tensions. The broader implication: privatisation of public functions does not necessarily reduce corruption risks. It can shift them into hybrid public-private arrangements where accountability is weaker and oversight is more fragmented. The rise of “routinised” corruption The study highlights the increased organisation of corruption itself. Today, no single official can independently guarantee a smuggling route. Procedures involve multiple agencies, overlapping inspections and layered oversight. As a result, corruption evolved towards collective coordination. Customs officers, border guards, supervisors, intermediaries and sometimes political actors participate in networks where bribes are pooled and redistributed. These schemes resemble coordinated organisational systems with revenue-sharing mechanisms, internal hierarchies and protection structures rather than isolated rogue actors. This reflects an important conceptual change: border corruption can function as an embedded institutional ecosystem sustained through cooperation, mutual dependence and political protection. Drug trafficking: when corruption becomes too risky Interestingly, corruption is not always the preferred strategy. In drug trafficking, for example, the risks are dramatically higher. Border officials caught facilitating drug trafficking could face severe criminal penalties, including organised crime charges and lengthy prison sentences. As a result, traffickers increasingly invest in sophisticated concealment methods. One example is the "twin trucks" strategy: several nearly identical trucks carrying similar cargo cross the border simultaneously during heavy traffic, with only one of them containing drugs. Since inspection capacity is limited, the probability is high that the "clean" trucks are checked while the drug shipment passes undetected. This shows that corruption and criminality do not always go hand in hand. Sometimes, stronger anti-corruption measures push criminals towards deception and concealment rather than bribery. The bigger lesson: criminal systems are adaptive The case study of the Kapitan Andreevo border crossing is not just about Bulgaria. Policymakers often assume that more technology, controls and regulation will automatically reduce corruption and illicit trade. But criminal systems and corruption adapt. Informal networks reorganise around the vulnerabilities created by reforms. Every regulatory innovation creates new incentives, bottlenecks and opportunities for exploitation. This does not mean reforms are useless. Many EU measures have clearly strengthened border management. However, reforms must be designed with an understanding of adaptive behaviour. Otherwise, states risk producing unintended consequences: stronger incentives for bribery, use of alternative trafficking routes, technological manipulation, new forms of collusion or opaque privatisation structures. I and my co-authors argue for a more integrated approach that combines anti-corruption and anti-crime strategies. We also emphasise the importance of anticipatory governance and foresight-oriented policymaking that try to predict how illicit actors will respond to institutional changes before reforms are implemented. This may be the most important lesson from Kapitan Andreevo. Borders are not static lines defended by static institutions against static threats. They are evolving ecosystems where states, markets, technologies and criminal actors constantly adapt to one another. Learn more Access the full article, “The Evolution of Corruption and Crimes at Kapitan Andreevo Border Checkpoint: The Impact of EU Accession”. Read our Quick Guide 38 to border corruption for a short introduction. Read our Working Paper 58, “Corruption as a facilitator of drug trafficking in the port of Rotterdam” for a related analysis.
Building trust: how Collective Action strengthens business ecosystems
In this article, Celia Lourens examines the role of cross-sectoral trust for a functional business environment. Collective Action, she argues, can be an approach to overcoming trust deficits between relevant stakeholders. Celia Lourens supports the organisation of our 6th International Collective Action Conference. At its core, anti-corruption Collective Action is about tackling corruption challenges together, rather than alone. Collective Action is primarily driven by businesses, often in collaboration with government representatives and civil society, to address a shared challenge and attain a common objective. Building trust is one critical element of Collective Action efforts, as it requires a genuine and sustained willingness from all involved stakeholders to collaborate. Trust across sectors: the foundation of effective markets Markets depend on trust – not only between businesses and their customers or employees and their organisational leadership, but between the institutions that shape the business environment: Business relies on regulatory bodies to create fair and predictable markets. Governments depend on businesses to act with integrity, beyond merely meeting compliance requirements. Civil society holds both public and private sectors accountable whilst advancing transparency and public confidence. Where these relationships are founded in trust, business ecosystems function more effectively and markets remain stable. Yet, cross-sector trust is increasingly under strain. Geopolitical volatility, tightening regulations and elevated complexity within supply chains are creating distance between the very actors who need to collaborate. The cost of low-trust systems When trust between the private sector, government and civil society breaks down, the consequences are immediate: slower transactions, higher compliance costs and due diligence burdens, duplicated oversight and heightened reputational risk. Oversight becomes adversarial, compliance turns reactive and businesses invest more time managing risks than creating value. In an era of heightened competitiveness, trust across sectors becomes the most valuable currency. Where it is systemically weak, a vicious cycle takes hold: low trust demands heightened scrutiny and more controls, which in turn erode trust further. Government enforcement of standards becomes inconsistent and civil society turns sceptical rather than being a partner. Breaking this cycle requires a different approach – one built on shared commitment, sustained engagement and coordinated action. This is where Collective Action comes into play. Collective Action as a trust-building mechanism In practice, Collective Action enables organisations to jointly raise integrity standards across industries, develop sector-specific norms and tackle systemic risks such as bribery and unethical conduct. Its ultimate objective – and the key incentive to participate in Collective Action initiatives – is to create fairer, more transparent markets where companies can compete on equal terms. But beyond its role as an anti-corruption approach, Collective Action also serves as a powerful trust-building mechanism. In a low-trust environment, individual organisations acting ethically on their own can find themselves at a disadvantage. Collective Action changes this dynamic. Shared commitments level the playing field, the involvement of multiple stakeholders builds credibility and joint accountability mechanisms increase transparency. Over time, this collaborative approach fosters trust where it is hardest to achieve – between actors with different roles, responsibilities and pressures. The result is a shift in systemic behaviour that lowers the cost of doing business and drives a more predictable business environment. From compliance to competitive advantage Too often, doing business with integrity is treated as a compliance obligation rather than a source of competitive advantage. Yet, in high-trust business environments, stronger partnerships and faster decision-making enable organisations to withstand disruptions. Organisations invested in building trust across their business ecosystem are better positioned to navigate complexity and sustain long-term value. Collective Action supports this shift by helping to shape markets that reward integrity, moving beyond a risk mitigation exercise. Building trust in practice This is exactly the focus of the 6th International Collective Action Conference, taking place on 9–10 June 2026 in Basel, Switzerland. Bringing together leaders from business, government and civil society, the conference is designed as a space not just for dialogue, but for practical exchange. It showcases how Collective Action initiatives are being implemented across sectors, what makes them effective and how they can be adapted to different contexts. The conference reflects a core conviction: trust across sectors does not happen by default but must be actively built. Organisations that commit to building trust together, as a collective, will not only manage risks more effectively, but help shape a new competitive advantage rooted in integrity. Learn more 6th International Collective Action Conference 2026 B20 Collective Action Hub Working Paper 56: Anti-corruption Collective Action: A typology for a new era Book: Collective Action in practice: a game-changer for business integrity
Publications
Quick Guide 43: Corruption sanctions
Working Paper 62: Corruption sanctions: What governments need to know
The Evolution of Corruption and Crimes at Kapitan Andreevo Border Checkpoint: The Impact of EU Accession
Published in the Journal of Illicit Trade, Financial Crime, and Compliance, this article examines how Bulgaria’s 2007 accession to the European Union transformed illegal activities and corruption at the Kapitan Andreevo border checkpoint.
While the introduction of stricter EU regulations and advanced surveillance technology aimed to secure the border, these measures had the effect of transforming criminal strategies and corruption. The authors detail a shift from blatant smuggling to more sophisticated financial frauds, VAT carousel schemes and the illicit privatisation of public border functions.
The article highlights that in some cases, it was the bribery schemes that evolved to bypass new standards. In other cases – particularly involving drug trafficking and the smuggling of human beings – it was the criminal strategies that transformed, including advanced concealment methods or new smuggling routes.
The study also offers a nuanced perspective on the relationship between corruption and criminal activites at border checkpoints: stronger capacity to counter criminal activities could lead to an increase in the risk of corruption, while a more coherent anti corruption framework could trigger criminal activities to evolve. Ultimately, the article argues that anti-crime and anti-corruption policies must account for this evolutionary nature.
Recommendations for combatting border corruption (FALCON Policy Brief)
Corruption at borders poses a significant threat to the integrity of the European Union’s external borders, undermining security, trust, and governance. And border corruption is not static — it evolves in response to new controls, technologies and enforcement strategies. This means that even well-designed measures may lose effectiveness over time.
A new Policy Brief by the FALCON (Fight Against Large-scale Corruption and Organised Crime Networks) project outlines actionable recommendations for EU policymakers and officials involved preventing and combatting border corruption.
The brief identifies four priority areas:
reducing discretionary face-to-face interactions at border crossing points through digitalisation;
developing harmonised, risk-based digital infrastructures that can detect corruption-prone patterns;
limiting manual data handling to close opportunities for manipulation; and
strengthening the conceptual alignment between anti-trafficking and anti-corruption strategies.
It argues that effective reform requires corruption-sensitive implementation frameworks, enhanced inter-agency coordination and a shift toward anticipatory governance.
The Basel Institute on Governance is an associated partner of the FALCON project. Jacopo Costa contributed to the Policy Brief and related research.
FALCON is funded under the Horizon Europe Framework Program Grant Agreement ID 101121281. The Basel Institute on Governance receives funding from the Swiss State Secretariat for Education, Research and Innovation (SERI).
Addressing conflicts of interest and corruption in Indonesia’s energy transition
This U4 Issue analyses Indonesia’s ambitious energy transition and highlights how political finance, weak regulations and a “revolving door” of personnel between public office and the private sector create vulnerabilities. The publication was produced by U4 and the Basel Institute on Governance through its Green Corruption programme.
About the paper
Conflicts of interest and corruption in Indonesia’s political economy pose significant risks to its energy transition, including the Just Energy Transition Partnership. Existing legal and institutional frameworks are fragmented, inconsistently applied, and often fail to address the risk of state capture by powerful political and economic actors, especially in the extractive and energy sectors.
The reliance on fossil fuel industries for political financing and the monopolistic nature of state-owned entities further complicate the shift to a low- or no-carbon system, despite the country’s ambitious renewable energy targets.
Potential pathways to greater anti-corruption resilience lie in improvements to beneficial ownership transparency and strengthening regulation, monitoring and sanctioning of conflict of interest violations.