[{"data":1,"prerenderedAt":314},["ShallowReactive",2],{"news-operational-credibility-is-a-strategic-asset-in-the-defence-industry-what-does-that-mean-for-ukraine-and-its-partners-2965":3,"news-operational-credibility-is-a-strategic-asset-in-the-defence-industry-what-does-that-mean-for-ukraine-and-its-partners-2965-similar":77,"i-heroicons:arrow-left-20-solid":309},[4],{"id":5,"status":6,"date_created":7,"date_updated":8,"title":9,"type":10,"body":11,"date":12,"topic":13,"slug":15,"activity":16,"nid":18,"topics":19,"activities":21,"programme":22,"area":22,"websites":22,"language":23,"image":24,"translation_of":22,"countries":34,"tags":56,"authors":57,"images":74,"translations":75,"content":76},10618,"published","2026-06-04T21:13:47.000Z","2026-06-06T09:37:02.000Z","Operational credibility is a strategic asset in the defence industry. What does that mean for Ukraine and its partners?","Blog","_Europe’s defence sector is changing fast. More money, political attention and international partnerships are flowing into the industry. At the same time, defence companies face growing pressure to show not just what they produce, but how they operate._ \n\n_In this blog, Yuliia Brusko explores why transparency and operational credibility are becoming more important – especially for Ukraine’s wartime-built defence industry. The article builds on the Basel Institute’s ongoing work in Ukraine, including with defence-sector stakeholders on governance, integrity and operational resilience under wartime conditions._ \n\n### Defence companies are entering a new era of scrutiny\n\nEuropean defence companies are attracting unprecedented levels of capital, political attention and strategic relevance. Yet alongside this growth comes a level of external scrutiny many firms were never built for.\n\nA recent public dispute involving Czech defence company Czechoslovak Group (CSG) illustrates this shift. A [report](https:\u002F\u002Fhntrbrk.com\u002Fcsg\u002F) published by Hunterbrook Media questioned aspects of CSG’s production claims, business model and corporate structure. Among other issues, the report raised questions about the transparency of certain ownership and subsidiary structures, the company’s reliance on intermediary and external procurement arrangements, and the extent to which publicly communicated production and business claims could be independently substantiated by external actors. \n\nWhile the company strongly [rejected](https:\u002F\u002Fcsg.com\u002Fen\u002Fnews\u002Fcsg-sets-the-record-straight-in-response-to-short-seller-allegations) the allegations, the case reveals a broader structural change: the increasing demand for operational verifiability.\n\nIn the booming defence industry, investors, procurement actors and international partners are no longer relying on growth narratives or high-level political positioning. Increasingly, they are trying to independently verify how companies actually operate, including: \n\n*   Where key dependencies sit\n*   How production is organised\n*   Whether public claims align with realities\n\nThis shift is partly driven by the changing structure of the defence market itself. Alongside traditional defence primes, the sector now includes rapidly scaling private manufacturers, drone producers and venture-backed technology firms. \n\nMany are entering international financing and export ecosystems that expect a level of operational accountability historically uncommon in parts of the defence sector.\n\n### Bridging wartime pragmatism and market expectations in Ukraine\n\nThis demand for clarity creates a unique challenge for Ukraine’s defence industry. Developed under wartime conditions, Ukrainian companies have prioritised speed, adaptability and survivability over externally defensible corporate structures. \n\nDistributed manufacturing, fragmented supply chains and parallel operational entities are practical wartime adaptations, not signs of weak governance.\n\nHowever, as the sector seeks deeper integration with European partners, these same features can create friction. Documentation and traceability systems built under the urgency of survival often struggle to meet the requirements of international financing and export ecosystems.\n\nThe problem is not necessarily the complexity or the inherent opacity of these arrangements; it is the inability to credibly explain and defend them to external stakeholders who can no longer rely on informal trust alone.\n\n### Operational credibility is becoming a strategic requirement\n\nAs scrutiny becomes more operational, companies are increasingly assessed not only on what they produce, but on whether their operational realities can withstand external examination. When structures are too opaque to confidently assess, perceived risk can outweigh strategic value.\n\nThis creates pressure not only for Ukrainian manufacturers, but also for European defence companies navigating a rapidly changing market. For those seeking long-term integration into international financing, procurement and partnership ecosystems, the ability to defend operational realities is becoming a core business capability.\n\n### A shift from trust-based networks to verifiable systems\n\nThe transition from relatively closed government and industry networks toward a more financialised and internationally interconnected market is reshaping how defence companies are assessed. Shifting to this next step is crucial as deftech companies move from niche producers to systemically important security providers. As their technology increasingly moves independently from the large defense primes, the obvious question arises of “going it alone.” While technologically, the choice is obvious, providing sufficient assurance for direct competitive government procurements will require solid systems. \n\nThe challenge is not eliminating operational complexity or wartime opacity. In many cases, these are unavoidable features of how modern defence industries function under pressure. The challenge is whether companies can credibly explain and defend those realities once they enter ecosystems built around external review, institutional accountability and sophisticated due diligence.\n\nFor many defence companies, this will require the ability to clearly explain aspects like: \n\n*   How production is organised\n*   How supplier and partnership structures operate in practice\n*   How key decisions are documented under wartime conditions\n*   How public production claims can be substantiated when questioned by investors, procurement actors or international partners. \n\nThis is likely to require more structured approaches to documentation, traceability and internal oversight – not to replicate peacetime bureaucracy, but to ensure that wartime realities can be credibly defended when scrutiny arises.\n\n### Adaptability alone will no longer be enough\n\nIn this environment, the ability to combine wartime adaptability with institutional credibility may increasingly determine which companies are able to scale, attract financing and secure long-term positions within international markets.\n\nThis increases the importance of building credible systems for transparency, documentation, internal oversight and operational accountability in individual companies and across the defence ecosystem. \n\nAchieving this is no easy task. It will require sustained cooperation between Ukrainian defence companies, international partners, investors, procurement actors and policymakers – indeed, any actor keen to see Ukraine’s phenomenal defence capabilities more deeply integrated into international markets and partnerships. \n\nAt the Basel Institute, we are increasingly working directly with Ukrainian defence companies and their associations to strengthen compliance on an individual or collective basis and welcome new partners. \n\n_The Basel Institute's work on Ukraine's defence integrity is supported by Norway. This blog represents the views of the author only._","2026-05-13",[14],"","operational-credibility-is-a-strategic-asset-in-the-defence-industry-what-does-that-mean-for-ukraine-and-its-partners-2965",[17],"Insights",2965,[20],"Ukraine",[17],null,"English",{"id":25,"storage":26,"filename_disk":27,"filename_download":28,"title":9,"type":29,"created_on":7,"modified_on":7,"charset":22,"filesize":30,"width":31,"height":32,"duration":22,"embed":22,"description":22,"location":22,"tags":22,"metadata":33,"focal_point_x":22,"focal_point_y":22,"tus_id":22,"tus_data":22,"uploaded_on":7},"6e5fbb34-c87f-4281-94cb-55f2cd75b3a0","local","6e5fbb34-c87f-4281-94cb-55f2cd75b3a0.webp","tmp.webp","image\u002Fwebp",50746,800,533,{},[35],{"id":36,"news_id":37,"countries_id":51},7816,{"id":5,"status":6,"user_created":38,"date_created":7,"user_updated":39,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":40,"slug":15,"activity":41,"nid":18,"topics":42,"activities":43,"programme":22,"area":22,"websites":22,"translation_of":22,"language":23,"countries":44,"tags":45,"authors":46,"images":48,"translations":49,"content":50},"03bebfd8-0b40-4a2a-820d-b9d9c13b9de6","b0662e2a-864d-4888-a1b7-4342b7570b30",[14],[17],[20],[17],[36],[],[47],1374,[],[],[],{"id":52,"name":20,"code":53,"latitude":54,"longitude":55},225,"UA",48.37943,31.16558,[],[58],{"id":47,"news_id":59,"authors_id":70},{"id":5,"status":6,"user_created":38,"date_created":7,"user_updated":39,"date_updated":8,"title":9,"type":10,"body":11,"image":25,"date":12,"topic":60,"slug":15,"activity":61,"nid":18,"topics":62,"activities":63,"programme":22,"area":22,"websites":22,"translation_of":22,"language":23,"countries":64,"tags":65,"authors":66,"images":67,"translations":68,"content":69},[14],[17],[20],[17],[36],[],[47],[],[],[],{"id":71,"name":72,"position":22,"image":73},593,"Yuliia Brusko","cc09d8f1-ec52-4638-a612-a87fbd5f4d2d",[],[],[],[78,114,139,170,194,218,242,265,286],{"id":79,"body":80,"status":6,"type":10,"date":81,"slug":82,"title":83,"image":84,"countries":85,"topic":87,"activity":88,"tags":90,"nid":103,"topics":104,"activities":105,"authors":106,"images":108,"websites":22,"area":22,"programme":22,"language":23,"translations":109,"translation_of":22,"user_created":38,"date_created":110,"user_updated":39,"date_updated":111,"content":112,"link":113},10578,"_Ukraine is already central to Europe’s security. Its defence manufacturers are increasingly eligible for participation in the rapidly growing EU defence procurements. However, unless Ukraine’s defence manufacturers are able to meet strict EU anti-corruption and ESG standards, they risk being shut out of EU supply chains. Europe needs Ukraine’s battlefield-tested innovation and production capacity, yet compliance gaps and unclear expectations are slowing integration. Juhani Grossmann, who leads the Basel Institute’s anti-corruption programme in Ukraine, explains how joint actions to overcome compliance barriers can help secure Ukraine’s place in Europe’s defence ecosystem and strengthen our collective security._\n\n### Ukraine’s central role in EU defence\n\nThe last three and a half years have been hard fought in Ukraine. Ukrainian resilience on the battlefield is legendary. The unparalleled military support from Ukraine’s allies, fused with its own relentless technical innovation, have forged bonds that could define Europe’s emerging security infrastructure.\n\nDaring political decisions by Ukraine and its allies have hastened this integration. Among them: the European Union has adopted the Security Action For Europe ([SAFE](https:\u002F\u002Fdefence-industry-space.ec.europa.eu\u002Feu-defence-industry\u002Fsafe-security-action-europe_en)) mechanism, using its combined fiscal firepower to raise low-cost loans on capital markets to encourage joint military procurement.\n\nSAFE explicitly includes Ukrainian firms in its stringent corporate and sourcing geographical origin requirements, which are designed to stimulate a native European defence industry. This recognises both Ukraine’s ongoing contribution to Europe’s security and the value of the country’s combat-driven technical innovations. From this angle, Ukraine’s defence industry is now even more critical to the EU than the UK, historically the continent’s dominant player.\n\n### Europe is vulnerable – but can’t meet its demand for defence hardware\n\nThe United States’ interest in taking responsibility for European and global security is waning, while Russia continues to probe Europe’s hard and soft defences.\n\nFeeling justifiably vulnerable, European nations have therefore committed to a huge increase in defence spending, which could reach [EUR 2 trillion](https:\u002F\u002Fwww.consilium.europa.eu\u002Fen\u002Fpolicies\u002Fdefence-numbers\u002F) over the next five years.\n\nYet EU defence industry leaders struggle to manufacture defence equipment in sufficient quality and quantity to meet the unprecedented demand and lack the battlefield-tested innovations that are at the core of Ukraine’s industry.\n\n### Ukraine could help meet demand for military equipment\n\nPartly due to the above dynamics, deep public debates are taking place in Ukraine about lifting a _de facto_ ban on the export of military goods in place since the full-scale invasion. The government is establishing [defence production offices in Berlin and Copenhagen](https:\u002F\u002Fkyivindependent.com\u002Fukraine-to-open-defense-production-offices-in-berlin-copenhagen-this-year-zelensky-says\u002F) to facilitate limited export.\n\nThis sounds counterintuitive, considering the devastating shortage of materiel at the front. Yet the truth is: Ukraine’s military is simply unable to afford all the weaponry that its manufacturers can deliver. So, the economic argument for export is strong:\n\n*   Selling excess capacity for a profit could generate significant revenue.\n*   That revenue could be used for economies of scale in production as well as for research and development.\n*   The resulting taxes would allow the state to increase the procurement of materiel for its own troops.\n\nIn a confirmation of the compelling market forces, Ukrainian drone manufacturers have started investments in Europe to set up production outside of Ukraine.\n\nThey certainly have products that would be marketable: their innovation has resulted in weekly software updates and continued hardware improvements. The more traditional howitzers, tanks and armoured personnel carriers are cost competitive and highly scalable. Battlefield command and control software is reported to be top notch.\n\n### What could derail Ukraine’s integration in EU defence markets\n\nOn the surface, the pieces of the puzzle of European defence are aligning neatly. But one major obstacle needs to be cleared for a healthy and thriving trade: Ukrainian defence manufacturers must meet EU standards on anti-corruption compliance and related environmental, social and governance (ESG) matters.\n\nThese include issues such as sustainable sourcing of aviation fuel, employee protections and human rights across the supply chain, as well as good governance of these topics. They also include regulations and standards on integrity and anti-corruption.\n\nThe defence sector globally is struggling to meet many of these requirements. And Ukraine’s fast-growing innovators have understandably not prioritised such matters over the wartime need to deliver at speed.\n\nWithout a rapid move to address this shortfall, Ukraine’s innovators could be shut out from European markets. The EU defence industry – and its citizens – would in turn be deprived of crucial expertise, leaving all allies weaker and poorer. Temptations would mount to soften standards, as is already the case with [fiscal probity requirements](https:\u002F\u002Fwww.consilium.europa.eu\u002Fen\u002Fpress\u002Fpress-releases\u002F2025\u002F10\u002F10\u002Feconomic-governance-council-approves-germany-s-fiscal-expenditure-path-and-its-flexibility-to-increase-defence-spending\u002F) when it pertains to military spending.\n\nThat would be a mistake for both Ukraine and its European allies. Instead, overcoming these challenges could be a boost for both the EU and the Ukrainian defence industry and further cement their partnership.\n\n### Robust internal controls bring many benefits\n\nThe measures required to attain EU standards on anti-corruption compliance and related ESG topics are no doubt arduous. Solid internal control systems, which can produce verifiable data, will need to be established.\n\nBut that brings solid benefits. Information from internal control systems will help to convince customers that the products they are literally entrusting their lives to are reliable, safe and effective. It will provide the basis for ESG reporting in future.\n\nAnd while the effectiveness of Ukraine’s defence systems is convincingly demonstrated through frontline usage, as its defence industry matures, it could greatly benefit from the efficiencies that robust internal control systems bring. \n\n### Challenges meeting EU regulations\n\nEuropean defence firms are eager to work with Ukrainian partners, yet are finding it difficult to meet their own regulatory obligations at the same time. We see several reasons for this:\n\n*   Sourcing of components is swift, creative and results driven. Without control systems, companies might struggle to verifiably certify their ability to meet the SAFE requirement that 65 percent of the weapon’s value must originate from EU\u002FEEA\u002FEFTA member states or Ukraine.\n*   Corporate ownership structures in Ukraine can be challenging for due diligence – particularly when it comes to establishing ultimate beneficial owners of companies.\n*   There is a lack of consensus on what good anti-corruption and ethics policy implementation looks like. This leaves Ukrainian partners unsure of the priorities, direction and speed of any required internal reforms.\n*   Track and trace measures are insufficiently robust. This makes it hard to reliably avoid sanctions violations in the procurement of components and to ensure environmentally sustainable sourcing of raw materials.\n*   Wartime lack of physical access to sites makes traditional verification mechanisms impossible.\n\nThese obstacles are formidable and have the potential to threaten otherwise promising partnerships.\n\n### There is a joint path forward\n\nThankfully, we see a strong desire on both sides to navigate a path through these obstacles.\n\n*   Reforms are progressing fast. Ukrainian Defence Industry, the holding company for the majority of state-owned defence manufacturers, has made impressive strides in adopting reforms at the top level. It is gradually cascading these down to the 50+ companies under its purview, including the producers of such notable products as the _Lyutii_ drone, the _Neptune_ subsonic cruise missile_,_ the _Bohdana_ howitzer and the _Stugna_\u002F_Skif_ anti-tank missile. While a long road remains to reform these highly traditional producers, the political will and technical capacity at the top are formidable.\n*   Anti-corruption policies are being implemented. The more established private manufacturers are increasingly adopting and publicising ethics and anti-corruption policies. They are also implementing and developing channels for reporting violations of integrity standards, and organising contractual activities based on ethical and compliance requirements.\n*   Engagement is strengthening. European manufacturers, who act as both suppliers and potential customers, are keen to engage more closely with their existing or potential Ukrainian partners to smooth the compliance obstacles as their relationships develop. These manufacturers are also keen to bolster their own contextual understanding of the operating environment in Ukraine, allowing them to manage the reputational and legal risks more professionally.\n*   Corruption is being investigated and prosecuted. Ukraine’s National Anti-Corruption Bureau (NABU) and Specialized Anti-Corruption Prosecutor’s Office (SAPO) are making significant headway in pursuing officials and company representatives who are willing to use criminal behaviour, including corruption, to personally benefit from wartime deprivations.\n*   Risk prevention measures are underway. The National Agency on Corruption Prevention (NACP) is leading the process of conducting a comprehensive risk assessment in the defence sector.\n*   International support is there. Increasingly, Ukrainian and international policy and advisory supporters are engaging in the sector. This includes the International Forum on Business Ethical Conduct for the Aerospace and Defence Industry ([IFBEC](http:\u002F\u002Fifbec.info\u002F)), NATO’s [Building Integrity](https:\u002F\u002Fwww.nato.int\u002Fcps\u002Fen\u002Fnatohq\u002Ftopics_68368.htm) programme and Norway’s Centre for Integrity in the Defence Sector ([CIDS](https:\u002F\u002Fwww.regjeringen.no\u002Fen\u002Ftopics\u002Fdefence\u002Fcentre-for-integrity-in-the-defence-sector-cids\u002Fid3114785\u002F)). The Basel Institute on Governance has recently commenced efforts in this space through funding from Norway.\n\nTogether, these efforts have the potential to make significant progress in overcoming obstacles.\n\n### How to accelerate progress\n\nWhile progress is happening, it is still insufficient given the urgency of the security situation in Europe. That is why we propose the following five catalysts:\n\n*   Set clear compliance requirements. EU member states at the forefront of defence procurement should spell out their internal control and anti-corruption requirements in plain and detailed terms. This would enable Ukrainian firms to participate in projects, either in collaboration with EU partners or independently. Providing early support and education would help potential Ukrainian partners meet these standards quicker.\n*   Improve implementation and verification systems. Industry associations should strengthen their anti-corruption standards and\u002For guidance by creating clear systems for implementation, verification and measurement.\n*   Allow time to comply. Companies should share their subcontracting compliance requirements with prospective partners well ahead of procurement deadlines, and work with them to build the systems needed to meet these standards.\n*   Share risk insights. Independent corruption risk assessment findings in the defence manufacturing sector, in both Europe and Ukraine, should be shared widely within the professional community.\n*   Collective integrity standards. Private manufacturers in Ukraine should create joint anti-corruption standards, ideally through a [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) approach – i.e. involving all relevant stakeholders working together in a trust-based environment over a sustained period of time. This would help stop individual companies using corrupt practices while others play fair, and reduce compliance costs for individual companies.\n\nAt the Basel Institute we are proud to continue and expand our work in this space with the generous support of Norway. We welcome partners to join these efforts and help ensure Ukraine’s defence innovation becomes a permanent pillar of Europe’s security.","2025-11-06","ukraines-place-in-europes-defence-industry-could-compliance-catalyse-integration-2868","Ukraine’s place in Europe’s defence industry: could compliance catalyse integration?","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Fc5b007eb-82d5-4cda-a6e1-773cfa16ad5d?width=1000&height=650&format=webp&quality=80",[86],7800,[14],[17,89],"Partnerships",[91,95,99],{"tags_id":92},{"id":93,"name":94},1376,"Defence and security",{"tags_id":96},{"id":97,"name":98},982,"Anti-corruption",{"tags_id":100},{"id":101,"name":102},1303,"Environment",2868,[20],[17,89],[107],1357,[],[],"2025-11-06T17:01:42.000Z","2026-05-23T09:18:31.000Z",[],"\u002Fresources\u002Fnews\u002Fukraines-place-in-europes-defence-industry-could-compliance-catalyse-integration-2868",{"id":115,"body":116,"status":6,"type":10,"date":117,"slug":118,"title":119,"image":120,"countries":121,"topic":123,"activity":124,"tags":126,"nid":127,"topics":128,"activities":129,"authors":130,"images":132,"websites":22,"area":22,"programme":22,"language":23,"translations":133,"translation_of":22,"user_created":38,"date_created":134,"user_updated":135,"date_updated":136,"content":137,"link":138},10567,"Today, the Basel Institute on Governance jointly published a report with Ukraine's National Agency on Corruption Prevention and State Audit Service on corruption risks in Ukraine's civil infrastructure restoration efforts. \n\nWith damage from the Russian aggression estimated to exceed EUR 500 billion, safeguarding state and foreign donor investments in restoration projects is imperative. \n\nThe report highlights 10 key priority risks and suggests mitigation measures. These cover areas such as establishing clear prioritisation criteria for projects, improving public procurement processes and strengthening oversight for construction projects.\n\nThe report, _Assessment of corruption risks in the construction, reconstruction and renovation of civilian infrastructure of Ukraine_, is available [here in Ukrainian](https:\u002F\u002Fnazk.gov.ua\u002Fpdfjs\u002F?file=\u002Fwp-content\u002Fuploads\u002FPages\u002Fa6\u002F84\u002Fa684c9bcc3dd2ba5e6135be3f225c688759f81ac32d035fb14ef47fad29dddbf2744054.pdf) on the NACP website. The Basel Institute and our Kyiv-based team contributed to its development with the support of Switzerland.\n\nThe launch event brought together key stakeholders in the restoration process, including Members of Parliament, representatives of the Ministry for Development of Communities and Territories of Ukraine, the State Agency for Restoration and Development of Infrastructure of Ukraine, the Accounting Chamber of Ukraine, the Antimonopoly Committee, the National Anti-Corruption Bureau, as well as representatives of local self-government and the private sector.\n\nJuhani Grossmann, who leads the Basel Institute's support to Ukraine on anti-corruption, delivered introductory remarks highlighting the centrality of a robust and independent anti-corruption infrastructure to safeguard restoration funds. These are found below:\n\n> Dear colleagues, dear friends,\n> \n> It is a pleasure to be with you today and discuss this crucial topic: restoring Ukraine's infrastructure and services efficiently and transparently, making the best use of limited funds.\n> \n> Allow me to start by acknowledging the exceptionally challenging circumstances you operate under and my appreciation for your continued bravery in the light of seemingly impossible obstacles.\n> \n> As members of the European family, your sacrifices made at the front are the investment in our collective European security. You are protecting the family, a fact which we have to treat with respect. It is my ardent hope that we will be able to honour these sacrifices by jointly building a Ukrainian future that makes today’s deprivations worthwhile.\n> \n> Family members support each other, and so we at the Basel Institute seek to support you. A top priority for us is to provide the tools you need in the face of unprecedented challenges.\n> \n> Those of us not in the military space provide support to the extent of our own capacity. For us at the Basel Institute, that means supporting your efforts to combat corruption – an enemy you have been fighting for decades, and an enemy that continues to have the potential to threaten your ability to mount an effective defence and restoration of your country today.\n> \n> Corruption is such a complicated topic: most of us just want to wish it away, like a bad dream, but unfortunately, it continues to be a reality. That does not mean it is stagnant. Like any enemy, it adapts, mutates, strengthens or weakens, depending on how we treat it.\n> \n> Ukraine’s relentless fight against corruption over the last decade has meant that you, in turn, have been able to hone your anti-corruption weapons. Conceptually similar to your relentless military innovation, you have step by step built your anti-corruption arsenal to a degree where Ukraine’s anti-corruption infrastructure – consisting of specialised agencies, decentralised corruption prevention officers, robust civil society and independent media – met some of the highest global standards and often exceeded that of Western counterparts.\n> \n> There is a dedicated international standard about the independence of anti-corruption agencies, called the [Jakarta Principles](https:\u002F\u002Fwww.unodc.org\u002Fdocuments\u002Fcorruption\u002FWG-Prevention\u002FArt_6_Preventive_anti-corruption_bodies\u002FJAKARTA_STATEMENT_en.pdf). This highlights the importance of ensuring independence in the appointment of the leadership, continuity in the agencies’ work and budgetary autonomy, as well as protecting employees from malicious civil and criminal proceedings.\n> \n> I don't say this lightly: when I travel around the world to the countries with which I work, and tell them about the fact that you continue to robustly pursue corruption during a full-scale war, my colleagues tell me they wish they had your anti-corruption infrastructure.\n> \n> We understand that this anti-corruption infrastructure is not something that was achieved easily. Rather, you had to fight for every law to remain intact, strengthen every regulation repeatedly to address residual risk, build and protect every case against obstacles, shepherd every risk assessment to the mitigation stage and then negotiate, argue, cajole and convince opponents to have these mitigation measures implemented.\n> \n> I know how carefully you considered the recruitment of every detective, analyst, prosecutor and judge. And the resulting system has been impressive – a national treasure. You should be proud of it, as should all Ukrainian citizens and leaders alike. We have certainly been privileged to be associated with it.\n> \n> The value of this anti-corruption infrastructure to Ukraine is not (only) sentimental. It is also of crucial importance as a counter-message to those who say – often without any personal experience or understanding of the issue – that any money or resources sent to Ukraine will only fuel corruption. It is also a crucial counter-message to russian propaganda which loves to portray Ukraine as hopelessly corrupt. You, the anti-corruption institutions, helped us build the arguments against these sceptics:\n> \n> *   How can Ukraine be hopeless, we argue, if it has managed to decrease corruption perceptions by 5 points between 2019 and this year, showing one of the best results in the region?\n> *   How can Ukraine be hopeless if it manages to investigate, arrest and convict high-level corrupt officials?\n> *   How can Ukraine be hopeless if the maturity of its anti-corruption institutions, as recently assessed by the OECD, surpasses many of those in OECD member countries?\n> *   How can Ukraine be hopeless if it has one of the most transparent public procurement systems?\n> *   How can it be hopeless if its public service digitalisation has drastically decreased opportunities for rent-seeking by bureaucrats?\n> *   How can Ukraine’s restoration be hopeless if it has as sophisticated a corruption risk analysis as the one we are presenting today?\n> \n> These are real-life arguments that result in real-life financial, political and military support because they confirm your responsible stewardship of the support you receive. They have allowed us to say that Ukraine is not a corrupt country; it is a country that fights corruption.\n> \n> To those of you in the anti-corruption community: thank you for your hard work over the last 12 years to build and sustain this anti-corruption infrastructure against extraordinary odds.\n> \n> We understand that this week’s efforts have changed the landscape drastically, but fighting corruption remains as important as ever.\n> \n> Your work has been inspiring us, and we will continue to support Ukraine’s anti-corruption aspirations to safeguard this essential dimension of your national defence and restoration.","2025-07-24","mitigating-corruption-risks-in-ukraines-restoration-new-report-2836","Mitigating corruption risks in Ukraine's restoration: new report","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Fd9cd78fe-043c-482d-92c1-5152e324e1c7?width=1000&height=650&format=webp&quality=80",[122],7791,[14],[125,17],"Reports",[],2836,[20],[125,17],[131],1349,[],[],"2025-08-21T23:48:00.000Z","3d9ff205-1640-4f34-b5b6-86977f51bbd6","2026-06-05T19:01:18.000Z",[],"\u002Fresources\u002Fnews\u002Fmitigating-corruption-risks-in-ukraines-restoration-new-report-2836",{"id":140,"body":141,"status":6,"type":142,"date":143,"slug":144,"title":145,"image":146,"countries":147,"topic":149,"activity":151,"tags":153,"nid":154,"topics":155,"activities":158,"authors":159,"images":160,"websites":161,"area":163,"programme":22,"language":23,"translations":165,"translation_of":22,"user_created":38,"date_created":166,"user_updated":135,"date_updated":167,"content":168,"link":169},10557,"Five practitioners from Ukraine’s leading anti-corruption institutions have been certified as national trainers in financial investigations and asset recovery following their successful completion of the [Train-the-Trainer programme](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes) of our International Centre for Asset Recovery (ICAR).\n\nThe group includes Andrii Kasian, Rostyslav Batih and Serhii Podhorets from the Specialised Anti-Corruption Prosecutor’s Office (SAPO), Oleksii Geiko from the National Anti-Corruption Bureau of Ukraine (NABU) and Oleksii Kravchuk from the High Anti-Corruption Court (HACC). Congratulations to all.\n\nAmid the ongoing full-scale invasion, Ukraine and its international partners continue to invest in long-term solutions to strengthen the fight against corruption. The certification of these trainers marks an important step towards embedding sustainable, practitioner-led training across national anti-corruption institutions.\n\nIt also brings a valuable secondary impact: as practitioners themselves, the trainers are well placed to promote and apply innovative approaches to investigations and asset recovery within their institutions.\n\n### Investing in local capacity\n\nAcross four financial investigation and asset recovery workshops, which began in June 2024, the newly certified trainers received close mentoring from our ICAR training team. During the process, they gradually progressed from co-facilitators to fully independent trainers.\n\nIn the final workshop, they successfully delivered the programme to 25 peers from their own institutions. This brings the total number of anti-corruption practitioners trained during the programme to 102.\n\nWith certification now complete, the newly qualified trainers are expected to lead further sessions in the coming months.\n\n### Practical, immersive and localised\n\nICAR's methodology is built around realistic case simulations that mirror the complexity of actual financial investigations. Participants analyse documents, follow leads and justify evidence requests from foreign counterparts. This enables them to develop the mindset and skills needed to tackle real cases.\n\nA key aim of the Train-the-Trainer programme was to ensure this approach could be effectively localised and delivered by Ukrainian professionals. When taught by national practitioners who understand the legal and institutional context, the methodology becomes even more relevant and impactful.\n\nOne participant from the final workshop described the training as\n\n> “a chance to piece together knowledge like a puzzle and sharpen judgement like a diamond being polished”.\n\nAnother commented:\n\n> It was probably the best and most practical training I’ve attended in recent years.\n\n### From training to practice: dual impact\n\nBeyond their new role, the certified trainers are experienced practitioners embedded in key anti-corruption institutions in Ukraine. This dual role enables them to reinforce training messages through daily casework and to champion innovative practices from within. All trainers noted that they are currently testing and promoting new tools, including standalone money laundering prosecutions, the use of circumstantial evidence and a \"follow the money\" approach that reduces reliance on direct proof of financial crimes like bribery.\n\nOne trainer reflected that the sessions provided:\n\n> “structured knowledge of money laundering that I used in one of my cases”.\n\nThey also noted the training offered\n\n> clear guidance to work through lengthy civil confiscation materials, which come in constantly.\n\nBeyond improving casework, the opportunity to train others was described as a chance to\n\n> test and discuss ideas, receive additional knowledge of the subject and valuable points of view from other specialists in the same field of work.\n\nNow equipped to deliver training, and with further workshops planned, they are bridging training and practice. Their work is helping to embed good practices in their institutions and shape how complex financial crime cases are tackled in Ukraine.\n\n### About the training and the Basel Institute’s wider support to Ukraine\n\nThe ICAR Train-the-Trainer programme was supported by the Swiss Agency for Development and Cooperation through the Anti-Corruption and Asset Recovery Support Project ([ACARSU](https:\u002F\u002Fwww.eda.admin.ch\u002Fcountries\u002Fukraine\u002Fde\u002Fhome\u002Finternationale-zusammenarbeit\u002Fprojekte.html\u002Fcontent\u002Fdezaprojects\u002FSDC\u002Fen\u002F2017\u002F7F09386\u002Fphase2?oldPagePath=\u002Fcontent\u002Fcountries\u002Fukraine\u002Fde\u002Fhome\u002Finternationale-zusammenarbeit\u002Fprojekte.html)). The final workshop, held on 26–30 May 2025, received additional financial and logistical support from the US Department of State’s Bureau of International Narcotics and Law Enforcement Affairs.\n\nMore broadly, the Basel Institute on Governance has supported Ukraine’s anti-corruption and asset recovery efforts since 2014. Our holistic programme includes:\n\n*   Helping government ministries, agencies and state-owned enterprises to prevent corruption in critical sectors related to reconstruction, infrastructure and natural resources. Assisting with transnational corruption investigations and the recovery of assets from abroad. Working with investors and contractors to minimise integrity risks in construction and development cooperation projects.\n\nThis programme of work is carried out by a combination of a local team based in Kyiv and Basel Institute staff who travel regularly to Ukraine.","News","2025-06-05","five-ukrainian-anti-corruption-practitioners-certified-as-national-trainers-2817","Five Ukrainian anti-corruption practitioners certified as national trainers","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Ffe2fe038-6bcd-4d4e-82e5-e0aee16fb0c8?width=1000&height=650&format=webp&quality=80",[148],7780,[150],"Asset Recovery",[152],"Training",[],2817,[156,20,157],"Asset Recovery and Enforcement","Learning and training",[152],[],[],[162],"Main page",[164],"Anti-Corruption & Prevention",[],"2025-06-05T16:01:34.000Z","2026-06-06T09:17:51.000Z",[],"\u002Fresources\u002Fnews\u002Ffive-ukrainian-anti-corruption-practitioners-certified-as-national-trainers-2817",{"id":171,"body":172,"status":6,"type":142,"date":173,"slug":174,"title":175,"image":176,"countries":177,"topic":179,"activity":181,"tags":182,"nid":183,"topics":184,"activities":185,"authors":186,"images":187,"websites":188,"area":22,"programme":22,"language":22,"translations":189,"translation_of":22,"user_created":38,"date_created":190,"user_updated":39,"date_updated":191,"content":192,"link":193},10356,"We are delighted to have signed a Memorandum of Cooperation with the Ministry of Communities, Territories and Infrastructure Development of Ukraine, the Ministry responsible for Ukraine's restoration. Under the agreement, we will work to minimise corruption risks in the use of state and donor funds allocated for the reconstruction of critical infrastructure.\n\nThis will include strengthening anti-corruption compliance in the road sector and assessing integrity risks when determining the cost of road works and services.\n\nOleksandr Kubrakov, Deputy Prime Minister for the Restoration of Ukraine, signed the Memorandum of Cooperation with Peter Maurer and Gretta Fenner, President and Managing Director of the Basel Institute on Governance.\n\n### Anti-corruption: a critical need\n\nAs the Ministry stated in its [Facebook post](https:\u002F\u002Fm.facebook.com\u002Flogin.php?next=https%3A%2F%2Fm.facebook.com%2Fstory.php%3Fstory_fbid%3Dpfbid0kbZLjavApNcrxp99SWuYTQ8P36N8h2YoxBaGAKise9CVuHNmABCCVSpLEUMxY5Yel%26id%3D100064745704510&refsrc=deprecated&_rdr), the World Bank has estimated the total reconstruction need at USD 411 billion. Housing and critical infrastructure facilities require the most funds.\n\nUkraine is actively working to attract international partners, governmental and non-governmental organisations to assist in financing the reconstruction. The consistency of financial assistance directly depends on effective anti-corruption measures.\n\nUkraine is already working on digitalising processes and reforming the procurement sector to ensure transparency and accountability at all stages of reconstruction.\n\nReferring to these challenges, Minister Kubrakov said:\n\n> We are grateful to have the Basel Institute on Governance as a partner in our efforts to strengthen internal controls and promote integrity in the infrastructure sector.\n\nJuhani Grossmann, the Institute’s Senior Advisor for Central and Eastern Europe noted:\n\n> “The Basel Institute has long supported the Ukrainian government in the fight against the “enemy within” – corruption. With the full-scale invasion over a year ago, the corruption risk profile in Ukraine has evolved significantly and the need to prevent corruption in the restoration processes is essential. It is our honour to support the Ministry and its agencies in this endeavour.”\n\n### Cooperation agreement\n\nThe memorandum provides support for Ukraine's efforts to maintain and restore critical infrastructure. It focuses on strengthening resilience and integrity in the operational processes of the Ministry and its subordinate enterprises.\n\nThe cooperation also includes: \n\n*   conducting corruption risk assessments;\n*   development of plans to identify the risks of corruption-related criminal offences and anti-corruption plans\n*   identification of measures to reduce the risks of fraud and corruption;\n*   training of officials responsible for integrity and anti-corruption policy implementation.\n\nOur work in Ukraine is supported by the European Bank for Reconstruction and Development and the Swiss Agency for Development and Cooperation, as well as the Principality of Liechtenstein which is funding our Green Corruption work on [illegal logging in Ukraine](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fdeepdive1-ukraine).\n\n### More\n\n*   View joint recommendations by the Basel Institute and Transparency International Ukraine presented at the [Ukraine Recovery Conference](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fukraine-recovery-conference-anti-corruption-critical-condition-sustainable-recovery) and [International Anti-Corruption Conference](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fstrengthening-ukraines-anti-corruption-and-judicial-infrastructure-safeguard-recovery) last year.\n*   Read a [joint blog](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fdont-let-kleptocrats-war-destroy-ukraines-reconstruction) by Gretta Fenner (Basel Institute) and Andrii Borovyk (Transparency International Ukraine) on safeguarding Ukraine's reconstruction from corruption.\n*   Learn more about financing Ukraine's reconstruction using recovered assets in this [panel discussion](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fasset-recovery-developments-start-war-ukraine) and [working paper](https:\u002F\u002Fbaselgovernance.org\u002Fpublications\u002Fwp-42).\n*   Read about the [RISE Ukraine coalition](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Frise-ukraine-coalition-launched-today-basel-institute-among-20-partners-promoting-transparent) of Ukrainian organisations and international partners that promotes a vision of integrity, sustainability and efficiency for the country’s post-war reconstruction.","2023-04-05","transparent-reconstruction-in-ukraine-ministry-for-restoration-and-basel-institute-on-governance-sign-memorandum-of-cooperation-2425","Transparent reconstruction in Ukraine: Ministry for Restoration and Basel Institute on Governance sign Memorandum of Cooperation","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F0c954837-9f58-4922-893e-a488e62b694f?width=1000&height=650&format=webp&quality=80",[178],7190,[180],"Private Sector",[89],[],2425,[180,20],[89],[],[],[162],[],"2023-03-31T10:01:24.000Z","2026-05-23T09:20:06.000Z",[],"\u002Fresources\u002Fnews\u002Ftransparent-reconstruction-in-ukraine-ministry-for-restoration-and-basel-institute-on-governance-sign-memorandum-of-cooperation-2425",{"id":195,"body":196,"status":6,"type":10,"date":197,"slug":198,"title":199,"image":200,"countries":201,"topic":202,"activity":205,"tags":206,"nid":207,"topics":208,"activities":209,"authors":210,"images":211,"websites":212,"area":22,"programme":22,"language":23,"translations":213,"translation_of":22,"user_created":38,"date_created":214,"user_updated":135,"date_updated":215,"content":216,"link":217},10538,"J. Edward “Ned” Conway became Executive Secretary of the [Wolfsberg Group](https:\u002F\u002Fwolfsberg-group.org\u002F) on 1 November 2024, succeeding Alan Ketley. With its 12 member banks, the Wolfsberg Group is a globally respected source of expertise on financial crime risk management, setting industry standards and building bridges between financial institutions and other stakeholders. The Basel Institute serves as Secretariat to the Group, which is now in its 25th year.\n\nIn this Q&A, Ned challenges us to consider how we can make the fight against financial crimes more effective. He also highlights the value that the Wolfsberg Group can provide to the financial services industry, policymakers and law enforcement, with its global reach and technical knowledge of the financial crime landscape and financial industry.\n\n### What drives your career in countering financial crime?\n\nYou can read my [bio here](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F77\u002F), but I can highlight a couple of things that motivate me.\n\nFirst, my experiences working for the US Department of Defence in Iraq, in a unit focused on analysing and disrupting the financing of terrorist groups and insurgent networks. Most of the old-school ideas and methods we were trying were just not working. That made us ask: What are we _ultimately_ trying to achieve by countering threat finance? What plan or strategy will get us there more effectively?\n\nAs financial crime evolves, it remains vital to keep questioning our goals and the effectiveness of the measures we are using to achieve them. It’s a fascinating, ever-changing field.\n\nSecond, I’m an analyst at heart and love digging into data, so finance is a natural field. But I also relish personal interactions and am fascinated by psychology and behaviour, especially decision-making.\n\nAfter leaving the Department of Defence I studied for a PhD in international relations. During my field work in Central Asia, I saw the real-life impacts of corruption and financial crime on ordinary people and businesses. It was clear that financial crime compliance and risk management are not only interesting fields in themselves. They are also a chance to put the structural pressures in place to incentivise good behaviour, to make it easier for those in power to “do the right thing” and for ordinary people to feel the benefits.\n\nAnd third, properly managing financial crime risks can also have a positive impact on the environment, another area of focus I have been passionate about from a young age. Take illegal logging, illegal mining and wildlife trafficking in places like the Amazon. If financial institutions and law enforcement can do more to disrupt the finances of the organised crime groups profiting from these crimes, the impact on their operations will be significant. That’s positive for biodiversity and for the climate, as well as for local people.\n\n### What drew you to the Wolfsberg Group?\n\nFirst and foremost, it’s the people. It’s exhilarating to work with a group of individuals who are highly knowledgeable about the technical side of countering financial crime and just as passionate about doing it as me.\n\nSo who are we exactly? Our members represent 12 global banks. When you consider their correspondent banking networks, the majority of the US dollar, euro and pound sterling financial system relies on our member banks to process transactions. And these 12 banks collectively have hundreds of millions of customers in their own right, from individuals to large corporations across the world.\n\nPrimary delegates to the Group are usually the heads of the banks’ financial crime compliance divisions, and the secondary delegates are their deputies. Other senior bank staff specialised in, for example, complex investigations, fraud, virtual assets or sanctions form subject-matter expert working groups.\n\nWe also engage with external stakeholders like law enforcement, financial intelligence units, regulators and supervisors, and civil society, depending on the topic.\n\nIt’s safe to say that all of us see the importance and value of our work and want to get it right. That’s vital to our reputation as a trusted source of technical expertise on financial crime risk management.\n\nI pay tribute to Alan Ketley, Tracy Paradise, Hans-Peter Bauer, John Cusack, and other previous secretaries, chairs and members for developing this committed group not just of financial institutions but of people.\n\n### What does the Group do?\n\nIn essence, we act as a bridge between financial institutions and the needs and goals of policymakers and law enforcement.\n\nOn the policy side, we can contribute to shaping more effective laws, regulatory guidance and measures against financial crime. For example, if the EU is thinking of developing new regulations on payment transparency, we can provide constructive feedback on proposed measures and drafts. We can also help regulators and supervisors to responsibly cut red tape and foresee the consequences of deregulation.\n\nOn the law enforcement side, we exchange on investigative techniques, trends and typologies in financial crime. This helps financial institutions to hone their financial crime risk management and reporting frameworks. It also helps law enforcement and FIUs to understand how they can use banks’ information and capabilities more effectively.\n\n### How does your work translate to practical guidance?\n\nWe provide [practical frameworks and guidance](https:\u002F\u002Fwolfsberg-group.org\u002Fresources?type=cbddq-fccq) for the financial services industry as a whole.\n\nA prime example is the [Correspondent Banking Due Diligence Questionnaire](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F36) or CBDDQ. This is an industry standard for conducting reasonable due diligence before agreeing correspondent banking relationships. We have translated the related Guidance, Glossary and FAQs into various languages to make it more accessible.\n\nOther examples include a recent [Statement on Monitoring for Suspicious Activity](https:\u002F\u002Fwolfsberg-group.org\u002Fnews\u002F69). That line of work essentially outlines the responsible framework for innovation in a highly regulated sector, applying artificial and machine learning to improve our ability to support law enforcement and meet supervisory expectations.\n\n### How does the Group work?\n\nOur approach is to build trust and provide constructive feedback based on our technical expertise and deep understanding of the global financial services industry.\n\nWe are a consensus-based group and we do what we say. When our member banks agree on a document, like a statement or a set of guidance, we collectively commit to doing what we recommend in the document. That’s a very powerful statement. And building, finding, and maintaining that consensus takes constant care and management.\n\nOne area I’m keen on advancing is how we can better move from strategic alignment – high-level agreement on financial crime goals and measures – to operational gains, i.e. more effective systems in practice.\n\nFor example, it’s easy to say we should use artificial intelligence to improve systems for monitoring and reporting suspicious activities to the authorities. In practice, doing so will need things like testing, validation, analysing results, explaining how algorithms are working… technical steps that don’t make headlines but that are essential to making progress and doing so responsibly.\n\nWe’ll be doing more workshops and face-to-face interactions to advance those technical steps. That will also help us to tease out areas where there are legitimate differences of opinion between parties, and we can then focus our efforts on addressing those concerns.\n\n### What are the Group’s priorities?\n\nThematically, we continue to take a deep look at:\n\n*   Suspicious activity monitoring. As an industry, we put a huge amount of resources into monitoring and reporting suspicious activities to the competent authorities. But it is broadly recognised that the system is not achieving the desired results.\n*   How we assess risk. This includes applying a risk-based approach to financial crime compliance to avoid detrimental impacts on the underbanked, including non-profit organisations, improving financial inclusion while simultaneously prioritising resources to address clear financial crime risk.\n*   Fraud, especially “confidence scams”, where victims are convinced they are investing in an opportunity or relationship that turns to be completely false.\n\nWe are also very interested in better ways to measure and assess the effectiveness of our financial crime compliance efforts in general. We work with key regulatory authorities in the US, UK EU and other countries and regions as regulation is reformed.\n\n### What bridges do you see with the Basel Institute’s work?\n\n[Like the Basel Institute](https:\u002F\u002Fbaselgovernance.org\u002Fabout), we are primarily focused on technical competence and building bridges between stakeholders, not advocacy in support of narrow interests.\n\nIn fact, the Wolfsberg Group is an early example of [Collective Action](https:\u002F\u002Fcollective-action.com\u002F) – bringing together different stakeholders in a sustained engagement to improve business integrity, or in our case, the management of financial crime risks. The Basel Institute has huge credibility in this space and contributed to the Group’s foundation 25 years ago.\n\nAnd beyond our alignment with the goals of the Basel Institute’s [asset recovery](https:\u002F\u002Fbaselgovernance.org\u002Fasset-recovery\u002F) and [Green Corruption](https:\u002F\u002Fbaselgovernance.org\u002Fgreen-corruption) workstreams, a clear point of interest is the [Basel AML Index](https:\u002F\u002Findex.baselgovernance.org\u002F). This tool for country-based financial crime risk assessments is a core aspect of any financial institution’s risk management process. Most banks use the Basel AML Index in their risk models.","2025-03-10","making-financial-crime-risk-management-work-for-all-insights-from-the-wolfsberg-group-2779","Making financial crime risk management work for all: Insights from the Wolfsberg Group","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002Facf339c5-225b-42b7-bd8a-8a6ef363264f?width=1000&height=650&format=webp&quality=80",[],[203,204,180],"Anti-Money Laundering","Collective Action",[17],[],2779,[203,204,180],[17],[],[],[162,204],[],"2025-03-10T11:01:36.000Z","2026-04-27T21:01:58.000Z",[],"\u002Fresources\u002Fnews\u002Fmaking-financial-crime-risk-management-work-for-all-insights-from-the-wolfsberg-group-2779",{"id":219,"body":220,"status":6,"type":10,"date":221,"slug":222,"title":223,"image":224,"countries":225,"topic":227,"activity":228,"tags":229,"nid":230,"topics":231,"activities":232,"authors":233,"images":235,"websites":236,"area":22,"programme":22,"language":22,"translations":237,"translation_of":22,"user_created":38,"date_created":238,"user_updated":135,"date_updated":239,"content":240,"link":241},9734,"Before joining the Basel Institute’s International Centre for Asset Recovery, [Tom Walugembe](https:\u002F\u002Fwww.baselgovernance.org\u002Fabout\u002Fpeople\u002Ftom-walugembe-0) was a Senior State Attorney at Uganda’s Office of the Director of Public Prosecutions. In this role, he secured the first ever money laundering conviction in Uganda in the case of _Uganda v Serwamba David Musoke and 6 Others_.\n\nThis landmark case blazes a trail not just for Uganda but for other countries to prosecute cases of money laundering and recover illicit assets.\n\nAs part of ICAR's efforts to encourage innovation and peer learning in the anti-corruption and asset recovery communities, we would like to share Tom's reflections on the case. His article raises considerations about what other anti-corruption practitioners and policymakers, especially in Africa, can take forward from it.\n\nThe short history of money laundering prosecutions in Uganda\n------------------------------------------------------------\n\nMoney laundering is the process of making large amounts of money generated through criminal activity appear to come from a legitimate source. In most countries, the conversion or transfer of proceeds of crime to disguise or conceal its illicit origin is criminalised as the offence of money laundering.\n\nIn 2013, Uganda passed the Anti-Money Laundering Act (AML Act). Prior to this, the offence of money laundering was not criminalised under Ugandan law. Uganda’s Financial Intelligence Authority (FIA) was only established in July 2014. There was very little knowledge about money laundering among police detectives, prosecutors and even judicial officers.\n\nAt the Office of the Director of Public Prosecutions, we quickly realised that the new AML Act could give us impetus in fighting organised crimes like corruption, terrorism, drug trafficking and human trafficking. However, for the first year no prosecutor dared to try it.\n\nIt was not until May 2015 that we decided to test the provisions of the Act in the case of _Uganda Versus Serwamba David Musoke and 6 Others_.\n\nAbout the case\n--------------\n\nThe complainant (Equity Bank Uganda Ltd) is a commercial bank in Uganda with subsidiaries throughout the East African region. The prime suspect, Serwamba David Musoke, was the operations manager of Equity Bank Oasis Mall Branch in Kampala.\n\nOn 28 and 29 March 2015, Serwamba colluded with various other conspirators to embezzle USD 1,450,000 from the accounts of two Southern Sudanese nationals. The money was withdrawn in three instalments using fake withdrawal slips by fraudsters who impersonated the real account holders and presented fake passports. Serwamba, the architect of the fraud, did not conduct biometric verification on the imposters before approving the withdrawal of the money, which the conspirators divided amongst themselves.\n\nOn 29 March 2015, some of the conspirators posted a video on WhatsApp with them posing with bundles of US dollars in their apartment. This video would later go viral and lead to the arrest of some of the conspirators. The fraud came to the Bank’s attention on 1 April 2015 when one of the real account holders in South Sudan went to transact at the Juba branch, and uncovered strange transactions on his bank account. The matter was immediately reported to the police in Kampala.\n\nA financial investigation was conducted to follow the money and recover the illicit assets. The financial investigation revealed the purchase of various assets:\n\n*   On 31 March 2015, one of the conspirators bought a Mercedes Benz 4matic 500 for USD 25,000 in cash, leaving it registered in the names of the seller.\n*   On 31 March 2015, the same conspirator purchased a plot of land in Buziga (a suburb of Kampala) for about UGX 100,000,000 (about USD 30,000) in cash. The sale agreement indicated the names of his mother as the purchaser.\n*   In mid-April 2015, the main conspirator, Serwamba, purchased a plot of land in Wakiso for UGX 110,000,000 (about USD 32,000) in cash. The sale agreement indicated the name of his girlfriend’s mother as the purchaser.\n*   In April 2015, Serwamba purchased a Mercedes Benz 4matic valued at UGX 80,000,000 (about USD 23,000), leaving it registered in the names of the seller.\n*   In the same month, Serwamba used UGX 8,000,000 (about USD 2,300) to clear taxes on a Toyota Corona. His girlfriend had imported the car for about UGX 16,000,000 (about USD 4,600) before the crime was committed.  \n*   In April 2015, Serwamba kept cash UGX 255,000,000 (about USD 73,000) in a closet at his brother’s home. The money was recovered during a police search. \n*   Investigations revealed that two of the conspirators went on holiday to Dubai in mid-April 2015, where they spent luxuriously.\n\nMost of the stolen money was not recovered.\n\nIn May 2017, seven of the conspirators were convicted for the offences of embezzlement, causing financial loss, forgery, conspiracy to defraud and money laundering. They were sentenced to varying prison terms between five to 12 years. The recovered properties were confiscated and forfeited to the complaint bank.\n\nThe accused were also ordered to compensate the complainant bank severally and jointly in an amount of USD 1,250,000,000. They appealed to the Court of Appeal, which appeal is yet to be fixed for hearing.\n\nLessons learned\n---------------\n\n### A prosecution-led strategy ensured meticulous investigation and correct procedures\n\nAs soon as the case was reported, the police quickly realised that it was essential to seek the advice of prosecutors from the onset. The Serwamba case, therefore, became a prosecution-led investigation case.\n\nThroughout the investigation, regular case management meetings were held between the police investigation team and prosecutors. At the meetings, evidence gathered would be reviewed, new investigation leads identified, and further investigation actions agreed upon. On occasion, police detectives would consult prosecutors by mobile phone calls for urgent advice.\n\nThe decision to adopt a prosecution-led investigation strategy ensured that the case was meticulously investigated; gathering all the relevant evidence while quickly discarding irrelevant information. It also ensured that police detectives did not ignore crucial legal procedures like securing search warrants and restraining orders against recovered properties.\n\n### A parallel investigation strategy enabled more targeted investigations into predicate offences and stolen assets\n\nAnother critical decision was to adopt a parallel investigation strategy. The investigation team was divided into two teams:\n\n*   One team was tasked to focus on investigating the predicate offences like embezzlement, causing financial loss and forgery.  \n*   The second team was tasked to simultaneously conduct a financial investigation with a view to following the money to identify the proceeds of crime for seizure and restraint.\n\nThis strategy was crucial to the recovery of a decent amount of illicit assets, and ultimately securing the money laundering conviction.\n\n### Having a large prosecution team helped to overcome challenges of long timescales and vast documentation\n\nBecause of their intricate nature, money laundering cases are bound to involve a vast quantity of documents and require a long time to prosecute. The Serwamba case took us at least two years to prosecute. It involved seven accused persons and about 10 defence lawyers. \n\nBecause the court had many other cases to try, it was inevitable that there were several adjournments. Even small details like determining hearing dates were problematic. During the hearing, the prosecution had to deal with an array of objections from the defence team.\n\nIn order to ensure that the prosecution did not become overwhelmed, we realised we needed to have a sizeable prosecution team. Accordingly, three prosecutors were assigned to handle this case. This also helped ensure continuity in case one of the prosecutors became unavailable.\n\n### The evidence of accomplices acting as prosecution witnesses was crucial\n\nCriminals will go to great lengths to prevent law enforcement authorities from recovering their illicit wealth. Inevitably, money laundering schemes involve a large number of conspirators. It is essential, therefore, for the prosecution to win over some of the conspirators to its side to achieve success.\n\nIn the Serwamba case, the prosecution made an informal agreement not to prosecute two of the participants on condition that they would testify as prosecution witnesses. The two accomplices had appeared in the WhatsApp video while posing with bundles of US dollar bills. They had also helped one of the prime suspects in identifying assets like vehicles and land for purchase.\n\nShortly before the trial, the prosecution also agreed to drop the charges against three other suspects on condition that they would testify against their co-conspirators. The use of accomplices was fundamental to the successful outcome of the case.\n\nThe use of accomplice evidence inevitably meets stiff resistance from defence lawyers. In the Serwamba case, the defence team ferociously attacked the credibility of the accomplice witnesses and contended that they were giving false testimony to avoid being prosecuted. However, it is up to the presiding judge to determine the reliability and relevance of the evidence of an accomplice.\n\n### Informal cooperation was valuable where formal mutual legal assistance (MLA) was not possible\n\nThe Serwamba case had a transnational dimension, considering that the money was withdrawn from accounts belonging to Southern Sudanese citizens, and domiciled in the Equity Bank Juba branch. It was necessary to interview the two account holders and some of the key staff at the Juba branch.\n\nThrough police-to-police cooperation, the assistance of the Southern Sudan Police was sought to record statements of the account holders. Although the two account holders confirmed that money had been fraudulently withdrawn from their accounts, they declined to record statements. Nevertheless, the Southern Sudan Police recorded statements from two bank employees at the Juba branch.\n\nDuring the trial, the testimony of these bank staffers could not be secured through formal MLA as neither Southern Sudan nor Uganda had any regulations or the technological capacity to allow video link testimonies at the time. (Uganda has since passed regulations to allow video link witness testimonies, and acquired the necessary technology in some of its courts.)\n\nFortunately, Equity Bank, using its resources, met the cost of flying the two bank employees to Kampala to testify during the trial. There is no doubt that in future cases, both informal and formal MLA will be critical.\n\nHow we overcame the challenges of asset management\n--------------------------------------------------\n\nIn most developing countries, asset management of proceeds of crime will be a significant challenge to the criminal justice system. In the Serwamba case, three major types of assets were recovered, namely cash, vehicles and land. Here is what we did and what we learned.\n\n### Cash\n\nUGX 255,000,000 (about USD 73,000) was recovered in a closet in the house of a brother of the main suspect, Serwamba. As soon as this recovery was made, the lead investigating officer contacted the prosecution on how to keep this exhibit. The fear was that it was too tempting to keep such a large amount of cash within the police station as poorly paid police officers could easily steal it.\n\nIt was decided that the money would be kept in a specially provided vault at the Bank of Uganda. In this case, the money was not only a recovered asset but also an exhibit. The money was photographed and kept in the same bag in which it had been recovered. The chain of custody was proved by producing all the correspondence concerning the storage of the money in the Central Bank. \n\nBased on this experience, we believe that if countries do not yet have guidelines concerning the safe custody of large amounts of cash recovered in money laundering cases, they should consider drafting them.\n\n### Vehicles\n\nFour motor vehicles were recovered in the Serwamba case. The storage of these vehicles was a challenge, as the police do not have a warehouse for that purpose. Consequently, the cars were driven to the Anti-Corruption Court parking yard where they spent about one and a half years.\n\nThe prosecution at some point contemplated selling the vehicles and keeping the proceeds on an escrow account pending the finding of the court. However, the cars were at the same time exhibits which needed to be produced before the court. There was also the risk of being sued by the accused persons if they were acquitted. Ultimately, the vehicles were forfeited to the complainant Bank, but their value had depreciated substantially.\n\nThis demonstrates that countries should consider establishing asset management facilities like warehouses where recovered properties such as vehicles can be safely stored. It is also advisable to adopt asset management guidelines, which may, among others, provide for the sale of such items before the conclusion of the trial to avoid their depreciation.\n\n### Land\n\nThe two pieces of land that were recovered in the Serwamba case were easier to manage since they were undeveloped. The prosecution secured restraint orders against the said plots and proceeded to place caveats on their titles. The plots were eventually confiscated and forfeited to the complainant Bank.\n\nHowever, managing other real estate properties like farms, commercial buildings, homes etc. is more challenging. Again, it is advisable for African countries to adopt guidelines to streamline their management.\n\n### Commingled assets\n\nOne of the vehicles in the Serwamba case had been imported at approximately UGX 16,000,000 (about USD 4,600) before the crime was committed. Serwamba then used UGX 8,000,000 (about USD 2,300) of the proceeds of crime to clear taxes for the vehicle, thus raising the complex issue of commingled assets.\n\nThe prosecution took the approach that the entire vehicle amounted to proceeds of crime while the defence argued that only the UGX 8,000,000 used to clear taxes on the vehicle was recoverable. The court, in this case, treated the entire car as proceeds of crime and ordered its confiscation.\n\nHow to handle commingled assets will depend on the facts of each case and the laws of each country in this regard.\n\nWider considerations for money laundering cases in Africa\n---------------------------------------------------------\n\n### Witness protection\n\nIn the Sewamba case, the prosecution had to rely on about five accomplices as prosecution witnesses. However, Uganda does not have a witness protection law or programme. The arrangement with these accomplices was therefore based on a “gentleman’s agreement”. The security of such witnesses is potentially at risk before and after the trial.\n\nThe use of accomplices as prosecution witnesses inevitably continues to be a common feature in money laundering prosecutions in Africa. However, only a few countries on the continent have witness protection laws and fully-fledged witness protection programmes.\n\nIf witness protection measures do not yet exist in a country, policy makers in that country should consider establishing them. Witness prosecution is an essential requirement for the successful prosecution of money laundering cases. \n\n### Digital forensics\n\nThe majority of money laundering cases inevitably make use of digital devices like mobile phones and laptops. The Serwamba case, for instance, involved a WhatsApp video with some of the conspirators posing with the recently stolen bundles of US dollars. It also involved a forged email purportedly sent by the Juba branch manager to Serwamba indicating that the two account holders were to make transactions in Kampala.\n\nThese aspects of the evidence were not subjected to digital forensics analysis. The digital forensics capacity of most African countries is still very low. It is important that African countries enhance their digital forensics capacity, as this will be an essential aspect in the successful prosecution of money laundering cases.\n\n### Regulation of cash purchases\n\nIn many African countries, it is still possible to purchase expensive commercial buildings or vehicles using cash. In the Serwamba case, the suspects paid for the plots of land and vehicles in cash. The use of cash to purchase such assets makes the investigation more complicated since it is difficult to follow the money trail.\n\nPolicy makers should consider establishing laws that require the purchase of assets like real estate and vehicles to be made through bank payments. Accordingly, the due diligence conducted by financial institutions before accepting such cash to be banked would be the first layer of protection.\n\nCriminals would therefore find it more difficult to launder their ill-gotten money, and following up the proceeds of crime would be easier.\n\n### Financial investigations training\n\nMoney laundering is still a relatively new concept to many stakeholders in the criminal justice system in Africa, an observation borne out during numerous ICAR training workshops. Moreover, effective financial investigations require the involvement of detectives with a broad skillset and the necessary training in financial investigations.\n\nTraining police detectives, prosecutors and judicial officers in asset recovery and financial investigations should be a recurrent activity.\n\nFind out more\n-------------\n\n*   View the full court judgement in the case of _[Uganda v Serwamba David Musoke and 6 Others](https:\u002F\u002Fulii.org\u002Fug\u002Fjudgment\u002Fhc-criminal-division\u002F2017\u002F100)_.\n*   View the [Ugandan Anti-Money Laundering Act 2013](https:\u002F\u002Fulii.org\u002Fsystem\u002Ffiles\u002Flegislation\u002Fact\u002F2013\u002F2013\u002FThe-Anti-money-Laundering-Act-2013.pdf).\n*   Find out more about the work of the [International Centre for Asset Recovery](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery) and the [ICAR training team](https:\u002F\u002Fwww.baselgovernance.org\u002Fasset-recovery\u002Ftraining-programmes), of which Tom Walugembe is now a member.","2020-05-27","breaking-new-ground-prosecuting-the-first-money-laundering-case-in-uganda-1754","Breaking new ground: prosecuting the first money laundering case in Uganda","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F590cac34-405f-4b4f-8e1e-e900e0b11558?width=1000&height=650&format=webp&quality=80",[226],7419,[203,150],[17],[],1754,[203,156],[17],[234],1230,[],[162],[],"2022-05-26T22:54:56.000Z","2026-05-29T22:21:52.000Z",[],"\u002Fresources\u002Fnews\u002Fbreaking-new-ground-prosecuting-the-first-money-laundering-case-in-uganda-1754",{"id":243,"body":244,"status":6,"type":10,"date":245,"slug":246,"title":247,"image":248,"countries":249,"topic":250,"activity":251,"tags":252,"nid":253,"topics":254,"activities":255,"authors":256,"images":258,"websites":259,"area":22,"programme":22,"language":22,"translations":260,"translation_of":22,"user_created":38,"date_created":261,"user_updated":39,"date_updated":262,"content":263,"link":264},10128,"_A version of this blog post initially appeared in the Summer 2015 edition of [Ethical Boardroom Magazine.](https:\u002F\u002Fethicalboardroom.com\u002F)_\n\nMany companies recognise the importance of high-level management commitment in the development and implementation of an effective compliance programme, as evidenced by the repeated emphasis on establishing the ‘tone from the top’. Without clear demonstration of CEO and board-level dedication to promoting a culture of integrity within the firm, the statements and procedures communicated in a code of conduct or internal policies will bear little resonance among employees, external stakeholders – or law enforcement and regulatory agencies, in the case of a breach.\n\nDespite the widespread and increasing enactment of anti-corruption compliance and ethics programmes however, firms continue to face corruption challenges that can severely hamper their operations in certain markets.  It is in this context that anti-corruption Collective Action has emerged. By working with competitors and other stakeholders in civil society, government or even other industries, Collective Action takes compliance and ethical business practices beyond a firm’s own internal policies and procedures, and instead seeks to raise standards among all market participants.\n\nForward-thinking CEOs and boards are encouraged to adopt this clear shift towards business driven integrity. For, as in the case of an anti-corruption compliance programme, strong leadership is a vital component towards the success of Collective Action.\n\nAnti-corruption Collective Action\n---------------------------------\n\nDefined variously as a “catch-all term for industry standards, multi-stakeholder initiatives, and public-private partnerships,” or as “a collaborative and sustained process of cooperation amongst stakeholders (that) increases the impact and credibility of individual action, brings vulnerable individual players into an alliance of like-minded organisations and levels the playing field between competitors,” Collective Action initiatives can be sector-specific or multi-sector based, and can involve participants beyond the private sector. They may be differentiated by the level of enforcement applied to the commitments made by the firms involved, whether it be a signed declaration committing all stakeholders to operate free of corruption, or more complex varieties which include ethics boards, external monitors or mechanisms for sanctioning non-compliance.\n\nA number of Collective Action initiatives have taken shape over the past two decades, and across a number of sectors, including banking, energy and transportation, extractive industries, aerospace and defence, as well as multi-sector initiatives. Civl society representative Transparency International has long supported Collective Action through its Integrity Pacts, a tool developed to improve transparency and preven corruption in public procurement. The B20 recommendations from Los Cabos in 2012 highlighted the importance of Collective Action and encouraged business involvement. The recommendations led to the creation of this B20 Collective Action Hub.\n\nAlthough there is no ‘one-size-fits-all’ approach, several elements have been observed that contribute to the successful establishment and operation of a Collective Action initiative. Facilitators from civil society can support the initial creation of an initiative, which, as a business-driven undertaking, should be led by companies. This is often easier when taken up by a leading player within the industry, though it is not essential. The involvement of facilitators also mitigates anti-trust issues and enables a neutral basis from which to identify issues of common interest. Allowing time for companies to develop trust and understanding are also important to the success of an initiative.\n\nUnderscoring all of these elements is the support of senior leadership, as this will bolster the chances of success and exemplifies business-driven integrity.\n\nThe importance of top-level commitment\n--------------------------------------\n\nSenior management is attuned to the company’s reputation risks and business goals and has the power to command support for driving a Collective Action initiative. In practice the General Counsel, Chief Compliance Officer and the CEO are likely to be the decision makers when it comes to initiating or joining a Collective Action as they know where the firm’s corruption risks lie. Having decided to pursue Collective Action, senior management must then delegate suitably experienced and senior persons to represent the company at the discussions to develop the Collective Action. By establishing a clearly articulated vision of where anti-corruption Collective Action fits within the company, its anti-corruption compliance and in relation to its competitors and business environment, management is on a good path towards contributing to the initiative’s success.\n\nAppointing the right people to represent the company and to sit opposite peer companies and competitors will contribute to the initiative’s chances for success and show management’s clear commitment to the initiative, both internally as well as to the other companies represented. \n\nEqually, the representatives of the participating companies will be empowered by the knowledge that their efforts have the complete support of top management. This is critical due to the length of time required to develop consensus and build trust. Should the participants during the course of the discussions have doubts as to the internal reasoning behind or commitment of their firms’ engagement, this could create hurdles that hinder its effectiveness or lead to its breaking down. \n\nIn sum, top management commitment is very important to the firm’s involvement in the Collective Action initiative, thus contributing to its potential for real impact.\n\nAs a facilitator and incubator of Collective Action initiatives, the Basel Institute on Governance has witnessed how senior management commitment influences the contours, direction, and ultimately success, of a Collective Action.\n\nIn 2004, under the World Economic Forum (WEF) and in partnership with Transparency International, the Basel Institute served as a founder of the [Partnering Against Corruption Initiative (PACI)](https:\u002F\u002Fwww.weforum.org\u002Fcommunities\u002Fpartnering-against-corruption-initiative), which brought together CEOs from engineering and construction, mining and metals, and the energy sector. This initiative of today nearly 100 companies is a leading global voice on anti-corruption and transparency. Further bolstering its CEO-driven agenda, PACI has recently established the PACI Vanguard, a CEO community from within WEF and PACI members which aims to further direct the PACI strategy through sustained and high level business-government engagement with particular emphasis on anti-corruption Collective Action.\n\nIn an industry sector example, one group of companies to whom the Basel Institute has served as a facilitator demonstrates how the support of top management has been critical to the progress made by the companies involved. In this initiative, the representatives at the table themselves come from the highest levels of compliance and legal areas within their respective firms.\n\nAt times during the discussions, the representatives have stressed to their counterparts that the work that they as a group are doing to develop the Collective Action, is fully supported by their respective CEOs, with whom the representatives have direct contact. This has allayed concerns that have arisen and contributed to the trust between the parties. Conversely, a different industry group is represented by more junior level compliance personnel who continually have to revert to their managers, thus hindering the discussions and hampering progress towards any common goals.      \n\nMoving forward\n--------------\n\nWith enforcement actions against companies engaging in bribery continuing to increase, top management is becoming more aware that it makes business sense to work with other stakeholders to remove corruption from the business environment. This relationship between top management, the tone from the top and Collective Action is further reinforced by government authorities.\n\nThe UK Ministry of Justice’s [Guidance](https:\u002F\u002Fwww.justice.gov.uk\u002Fdownloads\u002Flegislation\u002Fbribery-act-2010-guidance.pdf) on the 2010 UK Bribery Act makes explicit reference to this in Principle 2 entitled “Top-level commitment,” section 2.3: “Internal and external communication of the commitment to zero tolerance to bribery,” whereby it states that demonstrations of this commitment can include reference to an organisation’s engagement in collective action against bribery.\n\nCollective Action should remain at the forefront for CEOs and boards looking beyond risk mitigation and towards improving the overall business environment and levelling the playing field. Their commitment and leadership role will play a key part in the chances for success of these endeavours.","2015-11-30","building-alliances-to-tackle-corruption-267","Building alliances to tackle corruption","\u002Fpics\u002Fimg-placeholder.png",[],[204,180],[17],[],267,[204,180],[17],[257],1311,[],[162,204],[],"2022-05-26T22:59:03.000Z","2025-08-31T23:14:59.000Z",[],"\u002Fresources\u002Fnews\u002Fbuilding-alliances-to-tackle-corruption-267",{"id":266,"body":267,"status":6,"type":10,"date":268,"slug":269,"title":270,"image":271,"countries":272,"topic":273,"activity":274,"tags":275,"nid":276,"topics":277,"activities":278,"authors":279,"images":280,"websites":22,"area":22,"programme":22,"language":23,"translations":281,"translation_of":22,"user_created":38,"date_created":282,"user_updated":135,"date_updated":283,"content":284,"link":285},10582,"_A breakout session at the [9th Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002F9crc) focused on blockchain intelligence standards and interoperability – an issue that is becoming ever more critical for all who seek to prevent and combat the illicit use of virtual assets for financial crime._\n\n_Breakout leader [Bernhard Haslhofer](https:\u002F\u002Fbernhardhaslhofer.info\u002F) of the Complexity Science Hub Vienna explains the challenge below, and why the breakout represents a promising step towards the co-development of open standards in this domain._\n\nThe absence of standardisation and interoperability among blockchain intelligence tools has emerged as a critical challenge for all stakeholders working on preventing and countering financial crime.\n\nIncompatibilities manifest across multiple dimensions: data formats vary between platforms, identical concepts are described using different terminologies, computational methods such as address clustering follow divergent approaches, and user interfaces lack consistency.\n\nConsequently, problems include:\n\n*   Investigators work with isolated tool ecosystems with no systematic mechanisms for connecting investigations across platforms. This hinders inter-agency and cross-border cooperation.\n*   Prosecutors face problems demonstrating the reliability, admissibility and validity of blockchain evidence in court, in the absence of court-proof forensic procedures and standardised methods (in contrast to DNA analysis, for example).\n*   Judges in court proceedings involving blockchain intelligence currently rely on case-by-case testimonies from tool providers or expert witnesses. This creates resource-intensive judicial processes and lacks consistent interpretation across cases.\n*   Regulators and supervisors for anti-money laundering and counter financing of terrorism (AML\u002FCFT) use inconsistent blockchain intelligence methodologies and typologies to monitor for suspicious transaction patterns and conduct risk profiling.\n*   Training and certification are also at stake. The field lacks independent qualification standards, allowing unqualified practitioners to operate in the field and undermining professional credibility across the domain.\n\nThis situation reflects a typical pattern in emerging technology domains. Historical parallels exist across industries. For example, electrical systems evolved from incompatible regional standards to interoperable networks through adapter technology. Word processing software transitioned from proprietary formats to systems supporting cross-platform document exchange, without capitalising on the strengths of individual tools.\n\nAs blockchain intelligence transitions from an emerging field to an established professional domain, adopting similar standardisation approaches becomes necessary to ensure long-term viability and effectiveness.\n\n### A promising step towards collaboration\n\nAt the 2025 9th Global Conference on Criminal Finances and Cryptoassets organised by Europol, the Basel Institute on Governance and UNODC, we convened a workshop on creating harmonised standards for blockchain intelligence. The session assembled expertise from multiple domains: existing standardisation initiatives by INTERPOL and the [Global Coalition to Fight Financial Crime](https:\u002F\u002Fwww.gcffc.org\u002F), legal scholarship and practice, and operational perspectives from both analytics providers and cryptocurrency exchanges.\n\nIn addition to participants from legal and academic backgrounds, we had strong industry representation including blockchain analytics firms and cryptoasset exchanges. This ensured technical feasibility considerations informed the discussion.\n\nThe workshop addressed four critical components:\n\n*   Defining the technical scope by identifying specific components and processes requiring standardisation across blockchain intelligence tools and workflows.\n*   Outlining the legal and regulatory framework, including jurisdictional considerations, data handling protocols and compliance requirements.\n*   Mapping stakeholders whose participation is essential for standard adoption and implementation.\n*   Developing a concrete implementation pathway from initial agreement through pilot implementation to deployed, operational and open standards.\n\n### Technical scope\n\nThe discussion identified interoperability challenges across multiple technical layers. Immediate opportunities include:\n\n*   standardised data formats for attribution tags enabling third-party dataset integration;\n*   unified terminologies to eliminate semantic conflicts across platforms; and\n*   standardised investigation formats allowing transaction graph sharing without exposing proprietary attribution data.\n\nThese standards would provide direct operational benefits while respecting competitive boundaries between tool providers. For criminal prosecutions or asset recovery proceedings, they would also support the documentation of attribution tag provenance with a clear chain of custody and evidence classification.\n\nAddress clustering on UTXO chains such as Bitcoin presents greater complexity. Applied computational methods such as address clustering must provide transparent justification for grouping addresses into single entities. Yet experts noted significant variation in clustering results across tools and limited external verification capabilities. Providers meanwhile emphasised that computational methods constitute intellectual property, though accessible for regulatory scrutiny.\n\nParticipants agreed that initial standardisation efforts should prioritise readily implementable solutions, with any framework accounting for economic incentives that protect proprietary intelligence from competitors.\n\n> ### What would standards look like?\n> \n> Open standards for blockchain intelligence would be technical in nature but practical in impact. Examples of successful open standards in other domains include:\n> \n> *   [IETF RFC standards](https:\u002F\u002Fwww.ietf.org\u002Fprocess\u002Frfcs\u002F) describing internet technologies, protocols, and procedures\n> *   [W3C Web Standards](https:\u002F\u002Fwww.w3.org\u002Fstandards) ensuring a consistent and harmonious digitally connected world. They are implemented in browsers, blogs, search engines, and other software that power our experience on the web.\n> *   [STIX and TAXII](https:\u002F\u002Foasis-open.github.io\u002Fcti-documentation\u002F) are industry standards for sharing cyber threat intelligence.\n\n### Stakeholder participation and incentives\n\nThe successful development and implementation of standards require engagement from at least three stakeholder groups:\n\n*   Blockchain intelligence providers must contribute to the standardisation process and implement them within their platforms.\n*   User communities, including law enforcement agencies, financial regulators, cryptocurrency exchanges and financial institutions, must articulate operational needs and validation criteria.\n*   Technical experts provide methodological guidance to ensure standards are robust, implementable, and account for current capabilities as well as future scalability.\n\nIncentive structures differ across stakeholders. Tool providers benefit from meeting expressed user requirements. Establishing technically grounded standards through bottom-up consensus would also pre-empt potentially impractical top-down regulatory mandates.\n\nUsers gain operational autonomy and reduced vendor lock-in. This enables investigative continuity across platforms and organisational flexibility in tool selection, as well as enhanced reliability and sharing of blockchain intelligence data.\n\n### Next steps and learn more\n\nParticipants agreed that continued discussion must translate into concrete action, prioritising readily implementable solutions while considering incentive structures across all stakeholder groups. Follow-up steps will be announced in due course. Meanwhile:\n\n*   See the joint press release from the [9th Global Conference on Criminal Finances and Cryptoassets](https:\u002F\u002Fbaselgovernance.org\u002Fnews\u002Fglobal-experts-advance-joint-fight-against-crypto-enabled-crime), including links to recordings from public sessions.\n*   Read a Q&A with Vincent Danjean, Head of INTERPOL’s Cyberspace and New Technologies Laboratory, on efforts to enhance the [quality of blockchain intelligence](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fsmarter-blockchain-investigations-insights-interpol).\n*   Learn more about the [concept and use of blockchain intelligence](https:\u002F\u002Fbaselgovernance.org\u002Fblog\u002Fsetting-global-standards-blockchain-intelligence-idea-reality) and why professional standards are needed.\n*   Need the basics? Check out the Basel Institute's [introductory courses on blockchain: crypto investigation and AML compliance](https:\u002F\u002Fbaselgovernance.org\u002Fcrypto-aml-training).","2025-11-24","developing-blockchain-intelligence-standards-and-interoperability-a-critical-need-to-fight-financial-crime-in-the-digital-age-2879","Developing blockchain intelligence standards and interoperability: a critical need to fight financial crime in the digital age","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F0abcdf39-2cbe-462b-a1b2-74fbe836dc7c?width=1000&height=650&format=webp&quality=80",[],[150],[17,89],[],2879,[156],[17,89],[],[],[],"2025-11-24T11:01:40.000Z","2026-05-29T22:22:38.000Z",[],"\u002Fresources\u002Fnews\u002Fdeveloping-blockchain-intelligence-standards-and-interoperability-a-critical-need-to-fight-financial-crime-in-the-digital-age-2879",{"id":287,"body":288,"status":6,"type":142,"date":289,"slug":290,"title":291,"image":292,"countries":293,"topic":295,"activity":296,"tags":297,"nid":298,"topics":299,"activities":300,"authors":301,"images":302,"websites":303,"area":22,"programme":22,"language":22,"translations":304,"translation_of":22,"user_created":38,"date_created":305,"user_updated":135,"date_updated":306,"content":307,"link":308},10094,"Experts from ICAR delivered a 4-day training workshop on Operational Analysis to the Peruvian Financial Intelligence Unit (FIU) in Lima from 6 to 9 June 2016 with the aim to strengthen the FIU's analytical and operational capacities in financial investigations.\n\nThe training involved in a first instance the EGMONT [Operational Analysis course as an e-learning experience](https:\u002F\u002Fwww.baselgovernance.org\u002Felearning\u002Fcourses\u002Foperational-analysis) developed by the Institute's IT E-learning Specialists, which was regularly interspersed with a hands-on and interactive group exercise approach. While the former e-learning focused on best-practises in financial investigations, the latter subsequently emphasised country-specific operational elements relevant to Peru embedded in a potentially real money-laundering case scenario. The training integrated Peru's AML\u002FCFT and criminal frameworks with the aim to create stronger awareness of both, as well as to strengthen collaboration and cooperation between all concerned law enforcement authorities and the FIU.\n\n27 participants attended the training, mainly from the Operational Analysis Department of the FIU Peru. Most participants found the training very useful as it addressed “exactly what they have been doing in their everyday work”. \n\nThe training is part of a 5-year cooperation agreement signed between Superintendencia de Banca, Seguros y AFP (SBS) Peru and the Basel Institute aimed at supporting the strengthening of the capacity of the SBS to fight corruption, money laundering and other financial crimes. The funding for this specific training programme was provided by the State Secretariat for Economic Affairs (SECO).","2016-06-15","operational-analysis-training-for-the-financial-intelligence-unit-in-peru-289","Operational Analysis training for the Financial Intelligence Unit in Peru","https:\u002F\u002Fbg24.baselgovernance.org\u002Fcms\u002Fapi\u002Fassets\u002F57017434-4067-4e19-ad61-58429bf4cd9b?width=1000&height=650&format=webp&quality=80",[294],7644,[150],[152],[],289,[156,157],[152],[],[],[162],[],"2022-05-26T22:58:51.000Z","2026-06-06T09:17:38.000Z",[],"\u002Fresources\u002Fnews\u002Foperational-analysis-training-for-the-financial-intelligence-unit-in-peru-289",{"left":310,"top":310,"width":311,"height":311,"rotate":310,"vFlip":312,"hFlip":312,"body":313},0,20,false,"\u003Cpath fill=\"currentColor\" fill-rule=\"evenodd\" d=\"M17 10a.75.75 0 0 1-.75.75H5.612l4.158 3.96a.75.75 0 1 1-1.04 1.08l-5.5-5.25a.75.75 0 0 1 0-1.08l5.5-5.25a.75.75 0 1 1 1.04 1.08L5.612 9.25H16.25A.75.75 0 0 1 17 10\" clip-rule=\"evenodd\"\u002F>",1780868848065]