From Sanctions to Investigations

Legislative, policy and practical tools to investigate the origins of sanctioned assets

Effectively addressing illicit financial flows depends on anti-corruption investigations and asset recovery. Our report, From Sanctions to Investigations, provides an examination of the intersection of sanctions and anti-corruption investigations, and highlights the critical legal and policy frameworks that govern this process.

Asset Recovery: A multidimensional approach
Asset recovery, which includes the freezing, seizure, forfeiture and confiscation of assets, is a central tool in the fight against corruption. This report provides a much needed link in the discussion between sanctions and anti-corruption investigations and asset recovery.

Russian Sanctions: A case study
The Russian invasion of Ukraine has highlighted the importance of effective sanctions and the recovery of illicit assets. Our analysis highlights the innovative responses and political resolve that have emerged in this context, providing insights into asset recovery mechanisms that can go beyond current discussions and look at other sanctions regimes, particularly anti-corruption sanctions.

Comparing legal frameworks
By analysing the legislative approaches of eight key jurisdictions, the report highlights the diversity of asset recovery strategies and the potential for harmonisation of legal tools. This comparative analysis is essential for policymakers to understand the diversity of approaches and the importance of international cooperation in asset recovery.

Challenges in asset recovery
The report also identifies the challenges governments face in moving from asset freezing sanctions to asset recovery, drawing lessons from the Arab Spring and Russian sanctions. It highlights the need for innovative policies and practices to effectively trace and recover assets.

In sum
This report demonstrates the need for policymakers to assess and strengthen the tools available for asset recovery in the context of sanctions. It invites a thorough consideration of anti-corruption strategies with a view to strengthening measures against illicit financial flows.


From Sanctions to Investigations: Legislative, policy and practical tools to investigate the origins of sanctioned assets

The full report contains a discussion on importance of linking the imposition of sanctions to the opening of investigations into the origins of sanctioned wealth. It also includes detailed description of the situation across eight jurisdictions (Canada, France, Germany, Italy, Spain, Switzerland, the UK and the US) and a look into cross-border initiatives.

Download the full report here.


From Sanctions to Investigations: Policy brief and recommendations.

This policy brief builds on the full report and offers detailed recommendations for enhancing the effectiveness of investigations into sanctioned assets. It also provides an overview of how asset freezing sanctions are linked to investigations and asset recovery, examples of approaches to investigate the origins of sanctioned assets and how sanctioning jurisdictions can open investigations.

Download the brief and recommendations here.

Country summaries

Beneath you can find summaries of the findings from each jurisdiction assessed during the report.

Canada Country Briefing

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France Country Briefing

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Germany Country Briefing

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Italy Country Briefing

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Spain Country Briefing

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Switzerland Country Briefing

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UK Country Briefing

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USA Country Briefing

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Country overview table

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Further reading


Sanctions Watch
Our sanctions watch website collects information on individuals sanctioned for corruption across the world and 6 different regimes: Canadian sanctions under the Freezing Assets of Corrupt Foreign Officials Act and the Justice for Victims of Corrupt Foreign Officials Act; EU misappropriation sanctions (Ukraine, Tunisia); Swiss asset freezing sanctions under the Foreign Illicit Assets Act (Ukraine); UK sanctions under the Global Anti-Corruption Sanctions Regulations; and US sanctions under the Global Magnitsky Human Rights Accountability Act.


Russian Escape Investigations
Between autumn 2022 and June 2023 CiFAR and European Investigative Collaborations, with the support of OCCRP and thanks to IJ4EU and NED, coordinated investigations into how far sanctions applied against Russian individuals following the invasion of Ukraine were being effectively implemented in Europe. The investigations, published by Mediapart (France), Info Libre (Spain), and Domani (Italy), showed that it is likely sanctions are being evaded in several cases through the transferring of assets to family members. It also demonstrated that there are high levels of discrepancy between European countries in how assets are publicly reported – making it harder for civil society to do its role. Because of this, our investigations for the first time painted a picture of the EUR 3 billion in assets currently frozen in Italy and Spain.