ILP together with our key partners REDRESS and Spotlight on Corruption jointly implemented a two-year programme aiming to give effect to the UK's corruption sanctions regime, thereby removing impunity for grand corruption. The programme ran from 2021 until 2023 with support from the Open Society Foundation (OSF). The three programme partners also collaborated with the UK Anti-Corruption Coalition Sanctions (UKACC) Working Group.
The programme's ultimate objective was to strengthen the use of the UK’s anti-corruption sanctions mechanism, deter the conduct of kleptocrats, and help challenge the UK being used as ‘the world’s laundromat’ for the proceeds of corruption.
The UK Global Anti-Corruption Sanctions regime (GACS) came into effect in April 2021 and this programme started work soon after, in November 2021. The outcomes of the programme are therefore still emerging, yet it has already seen some positive results. For example, this programme, in collaboration with civil society partners, has contributed to 10% of all UK designations to date.
In the countries where corruption is taking place, the trainings and workshops have created a community in which NGOs are better able to campaign on these issues, whilst lawyers and government officials are now also more aware of these tools against corruption. In the programme period, 32 trainings on how to use the sanctions regimes were held with 68 participating organisations and 464 people in attendance. This mentoring support was particularly appreciated, and participants have fed back that they would like longer, more in-depth training over several days to further strengthen their capacity and deepen their understanding. Participants have also requested that trainings be provided to all actors in the ecosystem of anti-corruption efforts, including enablers of corruption such as banks and real estate entities.
The programme was found to have reignited the spark in local NGOs to continue the fight against corruption. ILP’s pro bono legal support was found to bring considerable value to the programme, contributing essential knowledge and experience, whilst also providing connections with and insights from government officials, particularly in the UK.
The evaluation also identified challenges in this area of work, including the fact that sanctions are a foreign policy tool, and therefore can be subject to ‘diplomatic interference’ when it comes to designations. It also takes time to build sufficient momentum, capacity, and political will to designate more sanctions. That said, the UK regime is still in its infancy, which provides hope for the future.
It is clear that there is a real ambition to continue this work and a need to provide further pro bono legal support to those seeking to use and understand the sanctions regimes. The evaluation makes various recommendations so that the programme can deliver more impact in phase two, building on the consortium’s legal expertise, advocacy, research and strong working relationships with policy makers and other government officials.
Please read more in the Programme Evaluation Report, available for download below.