How can governments respond to serious corruption when those responsible are beyond the reach of the law?

Weak institutions, political protection or limited law enforcement capacity can make it difficult to investigate or prosecute powerful individuals suspected of corruption. In response, some governments have turned to corruption sanctions.

Corruption sanctions allow governments to impose restrictions on people suspected of serious corruption even without a criminal conviction.

How can governments respond to serious corruption when those responsible are beyond the reach of the law? Some governments have turned to corruption sanctions to address this issue.

This Working Paper examines how corruption sanctions – tools that allow governments to impose asset freezes and travel bans on individuals suspected of corruption without any finding of guilt in a court – have evolved over the past decade, and offers recommendations for their more effective and legitimate use.

This Case Study describes how Kenya obtained crucial overseas intelligence in a corruption case through the International Anti-Corruption Coordination Centre, leading to the recovery of USD 1.8 million in assets for the Kenyan people.

Key points:

In an article published in the Fall 2025 issue of the Bulletin of the International Academy of Financial Crime Litigators, Andrew Dornbierer explores the revival of unexplained wealth orders (UWOs) in the United Kingdom.

Introduced in 2017 as a tool to combat the abuse of UK's markets to launder criminal proceeds, the UWO mechanism suffered a severe setback in 2020. After only a handful of attempts to use it, a decision by the High Court effectively left it sprawled on the canvas.

The UK is a global leader in its efforts to target foreign bribery. It is one of the only countries worldwide to use negotiated settlements such as deferred prosecution agreements (DPAs) to resolve cases and extract penalties from corporations that commit corruption abroad. The UK has also laudably committed to using the proceeds of DPAs in foreign bribery cases to compensate the victims of corruption, particularly in countries that suffer its worst effects.

This article arises from the work of the Basel Institute's Public Governance team on informal governance. It was produced by research partners at the ESCP Business School (Paris) and the EDC Paris Business School (Courbevoie), France.