Tackling Corruption in Environmental Crime and Climate Action: Gaps, Challenges and Best Practices 

The UNCAC Coalition’s Working Group on Environmental Crime and Corruption seeks to raise awareness among policy makers about the nexus between environmental crime and corruption, and its harmful impact on the environment, the climate, and human rights. The Working Group also promotes the adoption and effective implementation of robust policies and other measures by States to effectively prevent and combat these issues. The Working Group consists of over 230 civil society members worldwide and is chaired by the Wildlife Justice Commission. We would like to thank members of the Working Group on Environmental Crime and Corruption and other experts who have contributed to this compendium. 

Introduction

The UNCAC Coalition’s Environmental Crime and Corruption Working Group (WG ECC) calls on States Parties to prioritize preventing and addressing corruption that enables crimes that affect the environment (CAE) and undermines environmental and climate action as a central pillar of UNCAC implementation. It further urges States Parties to take decisive action at CoSP11 in this regard.

To support this aim, this compendium seeks to address existing knowledge gaps, provide evidence-based justification, and highlight relevant examples and good practices that can inform a strong CoSP resolution on preventing and combating corruption driving CAE, and impacting climate action.

A comprehensive review and deeper understanding of how UNCAC is implemented in relation to CAE and climate-related corruption is essential to ensure that commitments made at CoSP11 translate into meaningful action on the ground. This WG ECC compendium presents insights and feedback gathered from individual Working Group members, reflecting their experiences and observations across diverse national contexts. The views presented do not necessarily represent the official position of all WG members or of the UNCAC Coalition as a whole.

The recommendations put forward aim to build on CoSP resolution 8/12 (2019) on Preventing and combating corruption as it relates to crimes that have an impact on the environment, which marked an important milestone acknowledging the linkages between corruption and CAE. Since then, threats have intensified: organized crime groups have expanded their illegal environmental operations, and the scale of climate-related finance has grown significantly — bringing both new opportunities for protection and heightened risks of misuse. Gaps remain in key areas, including climate impacts, beneficial ownership transparency, oversight mechanisms for climate finance, procurement integrity and transparency, enforcement, international cooperation and civil society participation and protection. Moreover, relevant CoSP10 resolutions  — including those on public procurement (10/9), beneficial ownership (10/6), whistleblower protection (10/8), organized crime (10/5), and emergencies and crisis response and recovery (10/11) — should be explicitly applied to corruption driving CAE and impacting climate to strengthen prevention and enforcement efforts.

The table below presents two categories of examples:

• Gaps and challenges — instances where current frameworks reveal weaknesses, shortcomings, or insufficient implementation; and
• Good practices — examples of effective anti-corruption policies, measures, and initiatives demonstrating positive results.

All examples are based on verifiable information, referencing publicly available sources, authoritative publications, and documentation from the work of Working Group member organizations and other reputable entities. Hyperlinks to original sources are provided wherever possible.

Recommendations

We are presenting the following recommendations, which you can view in greater detail in the compendium below:

I. General

1. Recognize the United Nations Convention against Corruption (UNCAC) as a key framework for addressing corruption linked to CAE and climate action, integrity and anti-corruption in climate finance, and effectively implement anti-corruption frameworks to protect the environment and climate.

II. Preventative measures

2. Ensure integrity throughout the entire crime prevention and criminal justice system, including among customs and border control services and in bodies that award and oversee contracts, concessions, permits and licenses.

3. Assess and mitigate corruption risks across the environmental value chains.

4. Promote transparency and accountability of the management, allocation and use of climate finance funds, and of climate finance reporting, including ensuring effective public participation in monitoring climate finance use.

5. Promote integrity, transparency, accountability and effectiveness during the whole public procurement cycle including in the natural resources, waste and climate sectors, and among personnel responsible for procurement (including introducing conflict of interest measures).

6. Prevent the infiltration of organized criminal groups in procurement processes in the natural resources, waste and climate sectors.

7. Reform beneficial ownership laws to enable appropriate transparency of ownership of trusts and shell companies and ensure access to adequate, accurate and up-to-date beneficial ownership information of legal persons and arrangements, including on politically exposed persons, in the natural resources and waste sectors, in the climate financing sector and other relevant sectors.

8. Ensure that beneficial ownership information can be obtained or accessed rapidly and efficiently through a public central register that is accessible to all relevant stakeholders,  including domestic and foreign competent authorities, financial institutions, domestic public procurement authorities, civil society and the media.

9. Guarantee access to environmental information and open environmental databases, including free and widespread access to Earth observation satellite data of land use and environmental change.

10. Ensure conditions are present for the effective contribution of individuals and groups outside the public sector, including civil society, non-governmental organizations, community-based organizations, the private sector, academia, the media, environmental human rights defenders, whistleblowers, Indigenous Peoples and local communities, including the ability to operate independently and without fear of reprisal.

11. Enhance protection against unjustified treatment for all persons who expose or report corruption as it relates to CAE.

12. Establish and strengthen confidential complaint systems and protected internal reporting systems that are accessible, diversified and inclusive.

13. Enhance the transparency of technical and other forms of assistance by publishing comprehensive information on all projects and partners involved.

14. Adopt a rights-based approach by ensuring Free, Prior, and Informed Consent (FPIC) from communities and Indigenous Peoples before initiating projects that affect their environment, and actively involve them in the design, implementation, and monitoring of climate finance initiatives.

III. Criminalization and law enforcement

15. Address the convergence between corruption, CAE, and other serious crimes.

16. Strengthen inter-agency cooperation among environmental protection agencies, anti-corruption bodies, financial intelligence units, law enforcement, and agencies responsible for concessions, permits, or licences in the relevant sectors including natural resources and waste sectors.

17. Ensure these entities have adequate authority, independence, resources, and mandates to effectively carry out their responsibilities.

18. Recognize and treat CAE as predicate offences for money laundering, and incorporate them into FATF-compliant national risk assessments.

19. Strengthen regulatory and supervisory regimes for obligated subjects particularly susceptible to money-laundering.

20. Encourage states to implement best practice whistleblower programs, which include anonymity, enforcement and incentivization; and education to citizens about their rights regarding transnational whistleblowing.

IV. International Cooperation

21. Use the UNCAC to strengthen international cooperation to prevent and combat corruption related to CAE, including during emergencies and crises.

22. Expand the use of financial investigations, special investigative techniques, and joint investigations (including by concluding bilateral or multilateral agreements) to tackle corruption enabling CAE.

V. Asset recovery

23. Seize and confiscate proceeds of corruption linked to CAE, and use recovered assets transparently to restore the damage caused to the environment and to victims.

VI. Technical assistance and information exchange

24. Enhance technical assistance and capacity-building.

25. Promote the involvement of CSOs, both as providers and recipients of technical assistance and capacity-building, in training those in charge of investigating, and adjudicating CAE and corruption, and strengthening legislative and policy frameworks.

26. Collect good practices, lessons learned, challenges and data concerning the use of anti-corruption tools to address corruption as it relates to CAE and to help achieve environmental and climate protection goals; analyse this information to inform technical assistance.