The document examines the experience of nine EU member states (France, Germany, Ireland, Italy, Latvia, Lithuania, Portugal, Slovenia and Spain) and analyses the barriers and good practices that affect the initiation, conduct and conclusion of complex transnational corruption investigations and related money-laundering offences. The report is based on a combination of desk research, survey data and in-depth interviews with law enforcement and prosecutorial authorities.

For the purpose of the study, the authors assessed countries against the following criteria:

– Phase 1: Preparedness to investigate

1. Authority responsible for investigating corruption
   • prioritisation of corruption-related money laundering cases,
   • availability of specialised expertise,
   • effective synergies with other authorities,
   • organisational resilience (avoiding a “single point of failure”, protection against political pressure),

2. Financial resources
   • adequate budget dedicated to corruption and related money laundering,
   • separate budget for special functions (travel, IT, etc.),
   • budget transparency,

3. Human resources
   • sufficient staffing and proper allocation of workload,
   • competitive salaries to attract and retain specialists,
   • continuous training adjusted to emerging risks (e.g., crypto-asset analysis, forensic accounting),

4. Tools and technology
   • capacity to process large datasets,
   • advanced analytics and data-mining capabilities,
   • interoperability of information systems across agencies.

– Phase 2: Discovering a corruption case

1. Sources of detection
   • reports and complaints,
   • financial intelligence,
   • referrals from national authorities (parliamentary inquiries, audit, ombudsman),
   • media reporting,
   • leaks (e.g., Panama Papers),
   • whistleblowers,
   • spontaneous exchange of information with foreign authorities,
   • proprietary leads arising from investigative activity,
   • proactive investigations based on public data (e.g., bulk corporate ownership information).

– Phase 3: Triggering the investigation

1. Decision to initiate an investigation
   • discretion: legality principle vs. opportunity principle,
   • prioritisation based on KPIs reflecting the seriousness of cases.

– Phase 4: Navigating the investigation

1. Powers to obtain domestic information
   • authority to compel disclosure of information and production of documents directly (without prior court approval),
   • power to search premises and seize objects/evidence,
   • authority to compel explanations or testimony,
   • use of special investigative techniques (wiretapping, surveillance, undercover operations, etc.),

2. Cooperation with national authorities and the private sector
   • clear legal and procedural frameworks (data sharing, admissibility of witness statements, etc.),
   • effective communication channels,

3. Cooperation with foreign authorities
   • timely responses and access to foreign data,
   • availability and quality of foreign datasets,
   • mechanisms to overcome legal incompatibilities,
   • tools to address language barriers,
   • reliable trust-based working relationships,
   • strategies to manage political sensitivities (e.g., cases involving foreign elites).

– Phase 5: Closing the investigation

1. Limitations on pre-trial investigations
   • existence of time limits with justified extensions (e.g., when a suspect absconds or mutual legal assistance is pending) to balance thoroughness and efficiency,

2. Statutes of limitation
   • sufficiently long limitation periods,
   • late triggering point (from discovery rather than from commission of the offence),
   • suspension of limitation periods during appeals or procedural delays.

According to TI’s analysis, although the national systems of the assessed countries differ, in practice they face a common set of obstacles that undermine their ability to effectively detect, investigate and prosecute corruption and laundering of its proceeds. These barriers include in particular:

• lack of incentives to pursue complex cases – KPI frameworks favour case counts and fast closure, pushing authorities toward small, easily resolvable cases instead of high-level corruption involving politically exposed persons whose influence, immunity and political sensitivity may deter enforcement;
• pre-trial time limits and statutes of limitation – short limits on investigations (6–24 months) force premature closure, while brief limitation periods often do not pause when international requests are pending, resulting in cases expiring before evidence is obtained;
• reactive rather than proactive investigations – most cases arise only after journalists, whistleblowers or leaks expose wrongdoing; investigative systems are structured around responding to external triggers rather than conducting proactive, data-driven detection (e.g., scanning ownership registers for red flags);
• data gaps and restricted access to information – despite beneficial ownership registers, bank account registers and expanding rules on crypto-asset disclosures, investigators still face issues such as incomplete datasets, case-by-case access only, absence of data for certain asset classes, and strict confidentiality and professional secrecy rules;
• ineffective international cooperation – despite new EU cooperation tools, cross-border collaboration remains slow, fragmented and often dependent on informal personal networks;
• limitations on operational capacity – corruption is not consistently prioritised; resources are often redirected to other tasks, while complex cross-border investigations are expensive, lengthy and difficult to conclude; this is exacerbated by staffing shortages, high turnover, insufficient competencies and outdated technology.

The authors additionally provide several recommendations to improve the organisation of cross-border corruption and money-laundering investigations:

• Expand proactive enforcement – grant authorities mandates and tools for non-case-bound, risk-based analytics of assets and financial data; clarify legislation; ensure the availability of modern systems for detecting “red flags.” Some countries already have successful examples of such an approach: for example, Lithuania has established the specialised “Expert Valley” centre, which provides training in working with large datasets and OSINT tools, while in Spain the Anti-Money Laundering Registry Centre (CRAB) has access to the commercial register, real estate register and movable property register and uses a model enabling proactive detection of anomalies in the relevant data.
• Ensure full access to asset-related data – grant enforcement authorities machine-readable, bulk datasets at a minimum for legal entities, arrangements and the assets they hold; move toward creating a pan-European asset register. Italy offers an illustrative example: the Guardia di Finanza’s Dorsale Informatica system, integrating more than 200 databases, enables rapid mapping of assets and connections between companies and individuals.
• Eliminate legal uncertainty around confidentiality and evidentiary handling – publish clarifications on permissible use of data in investigations and establish transparent protocols for handling anonymous reports and leaks. There are already relevant examples within the EU: for instance, in Germany material from large leaks is used as orienting information, provided that it is subsequently verified through official channels, enabling authorities to initiate inquiries without risking violations of procedural rules.
• Reward outcomes rather than volume – revise KPI systems to support investigation of complex, high-risk cases. An example is Latvia, where the Corruption Prevention and Combating Bureau (KNAB) managed to reallocate resources and eliminate a years-long backlog of unresolved cases, after which the system became more focused on prioritised, complex investigations rather than on “speed” indicators.
• “Stop the clock” for complex investigations – adjust the statute of limitations and ensure suspension of limitation periods while international legal assistance and extradition requests are pending. In countries where such an option exists – for example, in Italy – this enables investigators to continue complex transnational inquiries without fear of premature termination due to bureaucratic delays abroad.
• Make corruption a priority – include corruption among priority offences and allocate multi-year budgets. In Lithuania and Latvia, dedicated budget lines for anti-corruption bodies ensure predictable financing and resilience of investigations, including expensive expert analyses and cross-border work.
• Publish data on resources and capacities – the authorities should collect and publish annual data on staffing, finances, outcomes, asset freezing and recovery, as well as the duration of investigations. This practice already exists in a number of EU countries and enables society and parliamentary oversight to evaluate how consistently the state implements its anti-corruption commitments.