The Deliverable 3.3 is authored by Jacint Jordana (UPF-IBEI), Elisabeth de Vega (IBEI), and Adam Holesch (IBEI), and released in December 2025.
The report focuses on the global governance of anti-corruption policies and the rising weaponisation of cross-border undue influence within a fragmented international arena. Its primary objective is to systematically map and classify the diverse actors involved in these efforts, ranging from formal intergovernmental organisations to informal networks and civil society groups.
The report examines the evolution of corruption from a domestic issue to a global challenge, analysing policy dimensions such as cross-border enforcement and the persecution of global corruption sources. A key aim is to assess critical governance challenges, including the scarcity of effective preventive instruments and the “securitisation” of anti-corruption, where tools like sanctions are increasingly used for geopolitical leverage rather than solely for integrity. Ultimately, it highlights the shift from cooperative multilateralism to a landscape defined by strategic competition.
The report provides a comprehensive analysis of the evolving global anti-corruption landscape, highlighting three key insights:
- The Weaponisation of Anti-Corruption: There has been a “strategic turn” in global governance where anti-corruption tools are increasingly securitised and used for geopolitical leverage rather than solely for integrity. Instruments such as sanctions, visa bans, and anti-money laundering (AML) lists are now central to foreign policy and national security strategies, often utilised to isolate rivals in a fragmented, multipolar world.
- The Shift from Multilateralism to Fragmentation: While a global consensus against corruption exists, the governance architecture has fractured into a complex web of formal institutions (e.g., UNCAC, OECD), informal networks (e.g., FATF), and private actors. This “regime complexity” has diluted central coordination, allowing strategic corruption to thrive in jurisdictional gaps while traditional multilateral cooperation weakens in favour of unilateral or bloc-based enforcement.
- The Prevention and Implementation Gap: Despite the proliferation of treaties and compliance mechanisms, actual enforcement remains uneven, and corruption indicators show little global improvement. The current framework lacks “fit-for-purpose” preventive instruments to tackle sophisticated cross-border undue influence (“strategic corruption”), resulting in a system that is often reactive and focused on formal box-ticking rather than measurable impact.
It also discusses sanctions, jurisdictional gaps, and the difference between strategic corruption and traditional bribery.
Sanctions
Sanctions are coercive, foreign-policy-driven instruments increasingly used within anti-corruption and undue-influence agendas. They are “attractive” because of their rapid deployment among coordinating states with common goals. Functionally, sanctions reshape the strategic environment but also embed governance risks: fairness concerns, selective application, politicisation, and erosion of multilateral rule-based cooperation.
Jurisdictional Gaps
The core gap is structural: fragmented governance frameworks plus uneven enforcement create exploitable jurisdictional and regulatory inconsistencies. Weak enforcement in one jurisdiction becomes an entry point for illicit flows affecting others, and strategic corruption benefits from loopholes and slow multilateral responses. The document characterises the system as one with overlapping mandates and inconsistent definitions/capacities, enabling actors to navigate, exploit, or manipulate regimes rather than being constrained. Two specific jurisdictional weak points are emphasised: Beneficial ownership and asset-tracing hampered by an uneven landscape of cross-border interoperability and verification. Cross-border legal cooperation and recovery with slow and burdensome mutual legal assistance.
Strategic corruption and traditional bribery
“Strategic corruption” is presented as a state-led or state-enabled approach where corrupt practices are deployed overseas to advance foreign-policy and geopolitical objectives. Traditional bribery is treated as a discrete corruption risk typically addressed through established anti-bribery and integrity instruments. Traditional bribery is framed as an act-level integrity breach within governance or business transactions. Strategic corruption thrives where coordination is weak across jurisdictions and enforcement is slow, exploiting fragmented legal jurisdictions and opaque financial structures; traditional bribery controls presume more standardised compliance and enforcement pathways.
Conclusions
The global anti-corruption governance system has evolved into a dense web of treaties, standards and monitoring mechanisms, spanning hard law and soft law, supporting stronger detection and deterrence, and a broad normative shift on foreign bribery, undue influence, offshore secrecy and transnational integrity risks. At the same time, fragmentation and uneven enforcement remain structural weaknesses. Jurisdictional gaps and inconsistent application allow actors to exploit loopholes as implementation lag behind and weak enforcement in one jurisdiction creates entry points for cross-border illicit flows affecting others.
Despite decades of initiatives, there is still a limited visible impact, partly attributable to the focus on formal compliance and difficulties in measuring covert flows, lobbying influence and foreign influence networks.
The report calls for a rigorous re-examination of the toolset, underlying norms, and coordination mechanisms, with tighter collaboration between key states and multilateral organisations in areas where cross-border effectiveness depends on system control and interoperability.
The agenda should be centred around:
- Stronger measurement and evaluation
- Data-driven detection capacity
- New cross-border instruments designed for robustness against manipulation
- A reinforced role for civil society, investigative journalism and transnational advocacy networks in demanding transparency and holding states accountable for anti-corruption claims.
The document presents the current tension as a driver of possible institutional renewal: contested and uneven, with potential to yield governance arrangements better adapted to strategic corruption and cross-border undue influence.