The paper highlights the role of private-sector intermediaries in facilitating corruption and money laundering (ML).
The paper builds upon a previous TI study mapping the roles played by illicit finance enablers in the non-financial sector in Africa.
Key findings include:
➡️ Accountability gap: Accountability measures identified for only 19 of 103 enablers in the study’s dataset, with no public evidence of action in three quarters of cases;
➡️ Limited criminal enforcement: Criminal measures were rare, with most cases relying on ML charges that were often dismissed or discontinued;
➡️ Confirmed corruption without consequences: 11 cases were identified where underlying corruption was confirmed in court, but no action taken against enablers;
➡️ Reactive enforcement approach: Action more likely following journalistic exposure rather than systematic investigation; and
➡️ Operational challenges: High evidential thresholds and resourcing constraints hinder effective enforcement against enablers.
✅ Firms should reflect exposure to enabler risk in bribery and corruption (B&C) risk assessments, strengthen third-party due diligence and ensure controls effectively mitigate the risk of facilitating illicit financial activity.