Spotlight on Corruption

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Susan Hawley | The FCPA Blog

Please present yourself

My name is Susan Hawley, and I am the Executive Director of Spotlight on Corruption, which I helped set up in 2019. I have worked in the anti-corruption field as a researcher and campaigner for over 20 years in various civil society organisations, including Corruption Watch and the Corner House.

What motivates you/inspires you to work in anti-corruption?

I believe that we would see a significant curbing of corruption globally if the UK effectively enforced its anti-corruption laws and properly resourced its law enforcement agencies. The benefits would be huge for lots of countries – to list a few: it would help build more accountable institutions, undermine kleptocracies, and significantly reduce poverty while increasing equality. It’s a struggle, but I am convinced the UK can do this, so that’s what motivates me above all.

What are your organization’s main goals?

Our mission is to end impunity for corruption both within the UK, as well as wherever the UK forms part of transnational corruption networks, through an emphasis on legal systems that work and effective enforcement of the law. In working to achieve this vision, we aim to ensure:

  1. The UK has a robust legislative framework for prosecuting and sanctioning corruption and financial crime.
  2. The UK has more proactive, properly resourced, transparent and effective enforcement of its anti-corruption laws.
  3. The UK government puts in place stronger anti-corruption measures to tackle corruption at home and abroad.

How does your organization operate?

We are a small, nimble anti-corruption organisation with a specific expertise in enforcement, operating with flexibility and agility based on strong understanding of our issues and political analysis. Our team is made up of lawyers, researchers and campaigners and we work closely in collaboration and coordination with other civil society actors to maximise and leverage influence.

We disseminate our research and recommendations through reports, detailed briefings, blogs and media commentary. We engage closely with law enforcement and experts in the legal and academic communities to test our recommendations. And we engage in advocacy, through briefings and engagement with government officials and parliamentarians. We brief journalists to help shape the narrative and get messages across to the public. And we work with parliamentarians to hold the government and law enforcement to account for implementation of laws and policies, by suggesting parliamentary questions, legislative amendments, and providing briefings and expert evidence for inquiries.

What are the biggest successes your organization has accomplished in the field of anti-corruption in the past years?

  1. Our work highlighting corruption-related risks around ‘golden visas’, including a widely cited report and an amendment in parliament to close the route, helped pressure the government into scrapping golden visas in February 2022.
  2. Since our launch in 2019, we’ve been closely monitoring some of the biggest corruption-related court cases in the UK courts, writing case studies to bring them to a wider audience and developing the case for policy and legislative reform to address weak enforcement and poor implementation of the law.
  3. The COVID pandemic has raised serious questions about the strength of the UK’s frameworks for upholding standards of integrity at home. As a result, we have focussed on ensuring that the highest standards of ethical conduct are upheld by those in power in the UK, including through providing expert evidence to parliamentary committees reviewing ethical standards, and developing an Integrity and Ethics Bill, in consultation with an expert working group, that would give the standards regulators more powers and independence.
  4. We led and coordinated NGO engagement with and input into policy formulation for the corruption sanctions regime which was launched in April 2021. Since Russia’s intensification of its invasion of Ukraine, we have worked to ensure sanctions are fully implemented and enforced. In May 2022, we worked with Redress and other members of the UK anti-corruption coalition (which our ED Susan Hawley co-chairs) to write a review of the UK’s anti-corruption sanctions, a year on since its launch.
  5. In January 2022, we published a report that evidenced the extent to which UK law enforcement agencies fighting corruption and other economic crime are critically under-resourced. We have gathered strong cross-party support among parliamentarians to significantly increase this resourcing and generate a step-change in how corruption is enforced by the UK authorities.

What are the key challenges specific to your local context that your organization has been facing?

After Russia escalated its invasion of Ukraine in February 2022, we received much more interest from parliamentarians and wider society in the UK’s role as a hub for dirty money from Russia. The challenge now is to maintain that momentum and turn this into real change, both legislatively in an upcoming Economic Crime Bill and culturally through a greater awareness of the UK’s role in transnational corruption, not only from Russia but from many places around the world.

We have also seen the UK’s standards of integrity at home come under severe strain. A big challenge for us is persuading parliamentarians and wider society that change is needed to safeguard the future integrity of the UK’s political institutions.

What can other organizations learn from you?

The most important thing for us is working collaboratively with other organisations, including Southern NGOs. For example we have worked closely with an NGO from Mozambique as part of our work monitoring a UK-based court case related to the “Tuna bond” scandal in Mozambique. We strongly believe that collaborative work and strategic coordination within civil society is essential to bring about change.

To what extent has your organization been involved in the UNCAC Review Mechanism?

In the past our Executive Director has helped lead civil society groups in the UK on their response to the latest UNCAC Review. We have also used the UNCAC Review in advocacy work to highlight its recommendations particularly on UK integrity reforms that it recommended.

Why is it important for you to be part of the UNCAC Coalition?

The UNCAC Coalition is a crucial forum for bringing together like-minded NGOs with a common agenda, and we are delighted to be a part of it. For us, the UNCAC Coalition is particularly valuable for helping us build stronger links with southern NGOs as part of our court monitoring work, with the aim of ensuring greater awareness of international cases in the UK courts and fostering collaboration in responding to these cases. This includes identifying ways to ensure greater representation of the harms caused by corruption and its impact on communities, including by advocating for relevant legislative reforms, and hearings where there might be scope to make interventions to raise the status of victims and the harm caused by corruption to ensure more accountable and transparent asset return.