The publication “Corruption Sanctions: What Governments Need to Know” examines how corruption sanctions regimes have evolved in recent years and what conditions are needed for their effective and legitimate use.

In the report, personal anti-corruption sanctions are understood as financial and travel restrictions that governments may impose on individuals suspected of corruption without any finding of guilt in a court. Such measures may include, in particular, asset freezes and travel bans.

As the publication notes, such sanctions have become one of the new tools of anti-corruption policy. They are used primarily in situations where individuals allegedly involved in serious corruption remain effectively beyond the reach of national law enforcement systems. In some cases, such measures may also be used to support investigations in other countries, for example by enabling the rapid freezing of alleged proceeds of corruption.

The key strengths of this tool are its flexibility and versatility. Personal sanctions can be applied based on a lower evidentiary threshold than in criminal or civil proceedings and do not always require proof of a geographical link between the sanctioning state and the alleged corrupt conduct. In addition, they can serve a range of objectives: disrupting corrupt activity, deterring potential wrongdoers and enablers, condemning corruption, facilitating asset recovery, and signalling support for another country’s law enforcement efforts.

At the same time, the report stresses that personal anti-corruption sanctions should not be seen as a simple substitute for criminal prosecution, asset confiscation or other traditional law enforcement measures. Their effectiveness depends on whether the state has a clear post-imposition strategy: what exactly the sanctions are intended to achieve, how long they should remain in place and how they relate to other available tools.

The paper pays particular attention to risks related to due process protections. Since sanctions regimes give governments broad discretion, including in decisions on imposing and lifting sanctions, the author points to the need for more transparent criteria, clear procedures for appeal and sufficient judicial oversight.

Based on the analysis, the publication sets out nine recommendations for governments. These include assessing the need to introduce personal anti-corruption sanctions, determining their place within the broader system of autonomous sanctions, balancing flexibility and accountability, publishing criteria for selecting high-priority targets, disclosing reasons for listing and delisting decisions, and establishing clear procedures for civil society organisations to submit information.