5 Appendix I

1. Research, analysis and knowledge-sharing on the impacts of corruption

Evidence-based policy is essential in the fight against corruption. Research and systematic collection of information on the causes and impacts of corruption and effective countermeasures form the foundation for targeted efforts and sustainable solutions. A solid knowledge base is crucial for raising public awareness, building societal resilience, and promoting open debate on ethical challenges and integrity in governance.

Norway emphasises the importance of knowledge sharing and supports research that reveals the societal costs of corruption and how various anti-corruption measures function in practice.

Cooperation with research institutions and civil society, both nationally and internationally, is undertaken to promote evidence-based approaches and make knowledge accessible across sectors.

Internationally, Norway advocates for stronger research and knowledge sharing to highlight the societal costs of corruption and identify which measures are most effective in prevention and enforcement.

2. Integrity in public administration

Integrity in the public sector is essential for promoting transparency, trust, and good governance. The social and economic interests of a country and society are safeguarded when public officials are recruited on the basis of professional competence and perform their duties in line with ethical principles and with integrity. Integrity in the public sector forms the basis for effective and just governance, which is essential for a well-functioning society.

Norway gives high priority to integrity in the public administration. The Civil Service Act regulates employment in the state and includes provisions on personnel management rules, recruitment (including public announcement of positions and the principle that the best qualified applicant should be offered the job) termination of the employment relationship, disciplinary measures, and procedural rules. The Civil Service Act also includes a prohibition on accepting gifts in connection with work, where such gifts are intended or likely to influence an employee’s official actions. The ethical guidelines for the public service aim to raise employees’ awareness of the importance of ethical conduct in service provision and the exercise of authority. They are based on values such as fairness, loyalty and honesty, and provide overall guidance rather than detailed rules. The guidelines are available on regjeringen.no. An e-learning course has also been developed featuring various ethical dilemmas. Separate guidelines have been developed for the ministries, entitled About the Relationship between Political Leadership and the Civil Service – Seven Duties for the Civil Service, which address ethical dilemmas in the relationship between a ministry’s political leadership and the civil service. The guidelines are supported by e-learning courses, podcasts, and a collection of dilemmas. The OECD’s recommendations on public integrity have been translated into Norwegian. The Norwegian Agency for Public and Financial Management (DFØ) monitors Norway’s compliance with these recommendations.

Norway has a comprehensive framework of legislation and rules that promotes transparency and prevents conflicts of interest. This includes the ethical guidelines for the public service, which apply to all government bodies, and guidelines for registering civil servants’ appointments and financial interests. The handbook for the political leadership clarifies the rules on conflicts of interest and situations that may undermine trust in a politician’s impartiality.

Internationally, Norway advocates for strengthening public integrity through robust administrative structures and institutions. Integrity and high ethical standards in public service delivery are essential for preventing corruption and ensuring that officials work for the public interest. This requires more than laws and structures – employees must be familiar with key ethical principles, be able to recognise ethical dilemmas, and have space for reflection and discussion in an open climate. Civil servants should have a fundamental right to express critical views about the state’s activities and other matters. It is also vital to ensure that public officials are able to report corrupt behaviour.

3. Transparency, integrity and inclusion in public decision-making processes

Transparency ensures that politicians and the public administration are held accountable for their decisions, and is essential for maintaining trust, enabling oversight, and strengthening citizen participation. Involving a variety of stakeholders in decision-making processes strengthens the legitimacy of the public administration, and it becomes easier to hold authorities accountable for their actions and priorities. This can lead to more informed decision-making and higher-quality, more effective public services.

The Freedom of Information Act gives everyone the right to access case documents, journals, and similar records from all entities covered by the Act. The law applies to all state bodies and municipal and county authorities, and as a general rule to all independent legal entities under their control. The purpose of the Act is to ensure that the public administration is open and transparent, thereby strengthening freedom of information and expression, democratic participation, individual legal protection, confidence in the public authorities and control by the public.

Norway considers it very important to ensure open decision-making processes through public consultations and inclusive cooperation. This helps to ensure that diverse perspectives are considered, thereby improving the quality of decisions and promoting democratic participation. Norway’s official instructions for planning and management of central government programmes and projects include requirements for consultation processes and states that those affected by an issue or proposed measures must be involved at an early stage of the process. Consultations must allow input from all stakeholders, ensuring transparency and safeguarding democratic rights in public policy formulation. Norwegian authorities cooperate with civil society organisations to ensure that decision-making processes are representative and inclusive. This cooperation helps to hold authorities accountable to citizens and strengthens trust between the public sector and the general public.

Through participation in the Open Government Partnership (OGP), Norway has committed to strengthening cooperation between citizens and public administration. This involves developing action plans in collaboration with civil society, including concrete measures to enhance transparency in the Norwegian public administration.

Internationally, Norway promotes transparency as a key instrument for strengthening trust between public administration and the population. Norway also emphasises the importance of inclusive decision-making processes to ensure fairness, equal treatment and sound resource management.

4. Corruption-free public procurement

The purpose of procurement rules is to ensure efficient and responsible use of public resources and high standards of integrity when a government purchases goods and services or undertakes construction projects. A system lacking transparency and competition is fertile ground for corruption. The UN estimates that up to 25% of the approximately USD 13 trillion that governments spend globally each year is lost to corruption. Without adequate oversight, public authorities risk entering into contracts with suppliers who cannot compete on quality or charge excessive prices. Lack of regulation may also lead to favoritism and allow personal gains by public officials.

Norway’s procurement framework consists of the Public Procurement Act and associated regulations. It ensures integrity through rules on impartiality, transparency, and procedures that prevent abuse of power and favoritism, including a ban on significant contract modifications after the procurement process is completed. Norway’s procurement legislation implements the EU procurement directives, which have been incorporated into the EEA Agreement. There are four main directives: Directive 2014/24/EU on public procurement; Directive 2014/25/EU on procurement by entities operating in the water, energy, transport, and postal services sectors; Directive 2014/23/EU on the award of concession contracts; and Directive 2009/81/EC on the coordination of procedures for the award of contracts in the fields of defence and security. Norway is a party to the WTO Agreement on Government Procurement, which aims to establish an effective multilateral framework for public procurement in free trade agreements, and to promote transparency and prevent corruption. Norway participates in OECD work on public procurement, which aims to share knowledge and identify best practices.

Norway seeks to strengthen international guidelines for the efficient, transparent and competitive use of public resources. Procurement processes must be regulated, transparent, and based on clear frameworks that promote integrity and trust in public spending. Furthermore, Norway advocates full transparency in public procurement, enabling relevant stakeholders to monitor the entire process from planning to implementation and monitoring. This strengthens competition, improves public services, and ensures efficient use of resources. Norway collaborates with organisations such as the Open Contracting Partnership and UNODC to improve procurement processes and reduce corruption risk in developing countries.

5. Transparency in public financial management

Lack of transparency or weak oversight of public finances may facilitate corruption. This may lead to financial losses, diminished trust in public authorities and poorer services for citizens.

General requirements for the national budget and accounts are set out in the appropriations regulations for the Storting (Norwegian parliament). All ministries and their subordinate agencies are involved in the preparation of the Government’s budget proposal, which is then scrutinised and adopted by the Storting. The Government’s budget proposal is published on its website, and the adopted budget is published on the website of the Storting.

Section 12 of the Regulations on financial management in the central government requires accounting that includes bookkeeping and mandatory financial reporting. The accounts must provide a basis for monitoring the use of appropriations and for analysing an entity’s activities.

Each central government agency (administrative body) must submit an annual report that includes a financial statement with explanatory notes. The annual report is published both on the agency’s website and on the website of the ministry responsible. In addition, monthly financial data from government agencies is publicly available on the portal statsregnskapet.no and as downloadable open data.

Government agencies must have internal controls to prevent irregularities such as embezzlement and corruption. The Office of the Auditor General audits all government agencies annually and issues audit reports that must be published on the agency’s website.

Agencies must notify the relevant ministry of any significant deviations from approved plans or allocation letters and propose corrective measures. Ministries must ensure that subordinate agencies have effective internal controls addressing objectives, resource use and compliance with legislation.

Internationally, Norway promotes greater transparency and to ensure integrity and accountability in matters related to public finances.

6. Transparency of ownership and ownership structures, including registers of beneficial owners

Transparency regarding ownership and beneficial ownership is essential for combating corruption. Ensuring that information about who actually owns and controls entities is available to authorities and other relevant stakeholders makes it harder for criminals to conceal illicit assets behind complex corporate structures and nominee arrangements. This reduces the risk of shell companies being used for money laundering, bribery, and other economic crime, while strengthening the rule of law and increasing trust in the business sector.

Transparency is a core value of Norwegian society. Norway’s Register of Beneficial Owners has recently been established to combat money laundering, terrorist financing and economic crime, and is managed by the Brønnøysund Register Centre. Companies and other legal entities were required to register information in the registry by 31 July 2025. The purpose is to provide information about who actually controls businesses. In addition to public authorities and entities subject to reporting obligations under the Anti-Money Laundering Act, the media, civil society organisations and academic institutions have access to the information. The ambition is to make the register as accessible as possible, while weighing this against the right to privacy and data protection requirements. In 2024, the EU adopted new anti-money laundering legislation, including updated requirements for access to beneficial ownership information. The new legislation is under scrutiny for incorporation into the EEA Agreement in Norway.

Internationally, Norway is promoting greater ownership transparency, with the aim of making beneficial ownership registers accessible to the widest possible range of stakeholders. Norway collaborates with UNODC and Open Ownership to support the establishment of beneficial ownership registers in various developing countries.

7. Transparency around the funding of political parties

Political parties and candidates require financial and other resources to organise, develop policies, and communicate their messages to voters. At the same time, uncontrolled or opaque financing may allow special interests to exert disproportionate or undue influence over political processes. Contributions and donations in the form of money, services or other economic benefits may create problematic ties between a party and its donors. This in turn increases the risk of corrupt quid pro quo arrangements. Furthermore, a lack of transparency may enable money laundering, allowing proceeds from criminal activities to be funnelled into political parties and political operations. In international anti-corruption efforts, transparency is considered to be the most effective tool for combating corruption and money laundering.

In Norway, the public’s right to access information on party funding is regulated by the Political Parties Act. The Act is based partly on the Council of Europe’s Recommendation 2003/4 on common rules against corruption in the funding of political parties and electoral campaigns, and GRECO’s recommendations to Norway to strengthen requirements for transparency, oversight, and control. The Political Parties Act contains clear rules on funding sources that it is prohibited for parties to accept contributions from. The same rules apply to affiliated party organisations, including entities directly or indirectly controlled by or otherwise linked to a party or party branch. Political parties and party branches are required to provide complete accounts annually, including the value of all monetary contributions and in-kind donations. Donations, sponsorships, and loans exceeding certain thresholds set out in the Act must be reported separately. Such disclosures must include the names and addresses of donors. The Political Parties Act also includes special reporting requirements for contributions received during a pre-election period. Statistics Norway (SSB) is responsible for receiving and publishing financial data, including information on donors, sponsors, and lenders. An independent body, the Political Parties Act Committee, has been established to oversee party financing and ensure compliance with legal obligations. Administrative sanctions, fines, or criminal sanctions may be imposed for violations of the funding provisions in the Act.

Internationally, Norway advocates for greater transparency in political funding to ensure public trust in politicians and political parties and to prevent corruption and abuse.

8. A corruption-free business sector and corruption prevention in the private sector

Corruption breeds corruption. It also distorts competition, which in turn harms businesses and the private sector. Projects that will have a less beneficial effect may be selected for implementation over more profitable and beneficial ones as a result of corrupt practices. In the international arena, Norwegian companies may encounter business and government representatives from countries where corruption is more prevalent, which can pose challenges for individual firms.

On the other hand, Norwegian companies operating in countries where corruption risk is high may generate positive ripple effects if they adhere firmly to an anti-corruption policy. It is important that companies clearly communicate their anti-corruption stance to subcontractors, subsidiaries, agents and other service providers, and that they have adequate control mechanisms to detect irregularities.

Preventing corruption in business requires awareness at the highest level in each company. Anti-corruption must be integrated into training systems, followed up in daily operations, and supported by robust control mechanisms to detect corruption. This may include procedures for financial management, auditing and internal control.

Norway is a party to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. The Convention’s 46 Parties are committed to criminalising bribery of public officials in international business and to ensuring effective, proportionate, and dissuasive criminal sanctions for violations. These obligations have been implemented in the Norwegian Penal Code. The prohibition against international bribery applies to civil servants and elected officials at all levels, employees of public agencies and state-owned enterprises, and representatives and staff of international organisations, and also applies to any contribution to violations.

The Convention also obliges states to establish corporate liability rules for corruption involving foreign public officials. Økokrim (National Authority for Investigating and Prosecuting Economic and Environmental Crime), in cooperation with the Director of Public Prosecutions, is developing guidelines for determining corporate penalties in corruption cases. These guidelines will include advice on the importance of preventive measures taken by companies, self-reporting, and cooperation with law enforcement. The guidelines are expected to be finalised in 2025. Since 2013, the Accounting Act has required certain large companies to report on anti-corruption efforts – previously as part of their corporate social responsibility disclosures, and since November 2024 as part of sustainability reporting.

Internationally, Norway promotes responsible business conduct through penal provisions on corporate corruption, including cross-border offences, and by requiring large companies to report on corporate responsibility and sustainability.

Norway calls on all countries to adopt and enforce legislation prohibiting foreign bribery.

9. Effective systems for the prevention and prosecution of money laundering

An effective system for preventing and prosecuting money laundering is essential to protect the economy and maintain trust in the financial sector. Without such a system, criminals can conceal proceeds from corruption and other crime and incorporate them into the legal economy, undermining the rule of law and weakening societal stability. A robust anti-money laundering regime helps ensure fair competition, strengthens investor and public confidence, and upholds Norway’s international commitments in the fight against financial crime.

Norway prevents and prosecutes money laundering through a robust legal framework, supervisory mechanisms, and close cooperation between public authorities and designated private entities (‘obliged entities’). The Anti-Money Laundering Act and its associated regulations are largely based on the EU’s Anti-Money Laundering Directive and the recommendations of the Financial Action Task Force (FATF). The legislation requires obliged entities to conduct risk assessments, establish procedures and systems for addressing risk, implement customer due diligence measures and report suspicious transactions. This strengthens the integrity of the financial system by preventing and detecting money laundering. Økokrim plays a central role in detecting, investigating, and sanctioning money laundering. Interagency cooperation and international partnerships ensure effective information exchange and enforcement. Norway’s Financial Intelligence Unit receives reports of suspicious transactions from entities subject to the Anti-Money Laundering Act and plays a key role in detecting money laundering and other economic crime. The supervisory authorities monitor compliance with the legislation by the obliged entities under their jurisdiction.

Internationally, Norway contributes to the development and enforcement of global anti-money laundering standards within FATF, with an emphasis on effective implementation of and compliance with existing standards.

10. Effective enforcement of anti-corruption legislation

Effective enforcement of anti-corruption legislation is essential for preventing and combating corruption, as it creates a real risk that offenders will incur sanctions. Clear rules on penalties and confiscation of illegal proceeds serve as a deterrent and reduce the incentive to engage in corrupt practices. When law enforcement authorities have sufficient resources and operate without undue influence, it is more likely that corruption will consistently be detected and sanctions applied. Lack of enforcement and impunity for corruption, on the other hand, have serious consequences for society. They foster a culture in which corruption can thrive without fear of consequences, encouraging those in power to exploit the system for personal gain. This undermines the rule of law, erodes trust in public institutions, and contributes to a vicious cycle in which corruption becomes the norm rather than the exception. Effective and consistent enforcement is therefore vital to uphold justice, strengthen democracy, and ensure sound economic development.

Norway has strict riles on corruption offences and its enforcement. ‘Corruption’ as used in Norwegian criminal law includes providing or accepting bribes in the form of money, gifts or services. The term is not entirely clear-cut, and in its broad sense also encompasses influencing how others conduct their work, known as trading in influence. Section 387 of the Penal Code sets out the penalties for corruption. To be liable for a penalty, a person must give, offer, demand, receive or accept an improper advantage in connection with the conduct of a position or office, or the performance of an assignment. A discretionary assessment is required to determine whether an improper advantage is involved and thus whether or not an act falls within the scope of the Penal Code.

Under the Norwegian Penal Code, any proceeds of a criminal act shall be confiscated.

Internationally, Norway contributes to technical assistance to strengthen independent oversight institutions, the work of the police and prosecuting authorities, protect those working on corruption cases, and support the exchange of information and knowledge to improve investigations. These efforts complement measures to prevent corruption. Norway also participates in international forums within the UN and OECD where concrete cases are discussed.

11. Independent, robust anti-corruption institutions, prosecuting authorities and courts

Effective institutions with clear mandates and adequate resources are essential for preventing, detecting, and prosecuting corruption. To carry out their work with integrity and credibility, these bodies must be protected from political interference. This applies in particular to prosecuting authorities, oversight and supervisory bodies, audit institutions, and the judiciary. It is especially important that prosecutors and courts operate independently, so that investigations and prosecutions can be conducted free from undue influence.

Norway has an independent judicial system that upholds legal safeguards. In Norway, the courts and the prosecuting authority are entirely separate, and both operate independently in the handling of individual cases.

The prosecuting authority leads investigations of criminal offences and decides whether to bring charges. The prosecuting authority presents cases in court and decides whether verdicts should be accepted or appealed. It also issues orders for the enforcement of final judgments.

The prosecution is part of the executive branch, see Article 3 of the Constitution. Section 55, first sentence, of the Criminal Procedure Act provides that the prosecuting authority is independent in the handling of individual criminal cases. No one may instruct the prosecution authorities in individual cases or overturn its prosecutorial decisions. However, the rule does not prevent judicial review of decisions made by the prosecuting authority, nor does it regulate the internal organisation and the ability to issue instructions within the prosecuting authority. Police prosecutors are independent when exercising their prosecutorial function. When they act as part of an administrative authority, the provision does not apply.

The Director of Public Prosecutions is a senior public official, but can be removed without any prior court jugdement. Other senior officials in the prosecuting authority, i.e. the Deputy Director of Public Prosecutions, chief public prosecutors, public prosecutors, chiefs of police and deputy chiefs of police, are senior officials who cannot be removed without any prior court jugdement. The Constitution ensures their independence from the King and the government through special protection against removal from office. This special protection is governed by the provisions on dismissal and transfer set out in Article 22 of the Constitution.

Employment protection for senior officials is particularly tied to the following points, which either follow directly from the Constitution or are understood to be derived from it:

• A senior official’s employment may only be ended through a special form of dismissal, not through resignation by the senior official or ordinary dismissal by the state.
• Senior officials with special employment protection can only be dismissed after legal proceedings brought by the King in Council and a court case. Senior officials without special employment protection may be dismissed administratively through a decision of the King in Council or by a court judgment.
• Senior officials with special employment protection may not be transferred against their will.
• Dismissal cannot be justified by circumstances related to the institution, and senior officials may not be dismissed because a position is abolished or there is significant reorganisation.

Judges appointed under the provisions of the Constitution cannot be dismissed or transferred against their will. They may only be removed following legal proceedings and a court ruling. Judges’ tenure protection is intended to safeguard their independence from political and administrative authorities, so that they are not dismissed as a result of unpopular decisions that the authorities or others disagree with. Norway has enshrined the independence of the courts in its Constitution. Article 95, second paragraph, of the Constitution provides that state authorities shall ensure the independence and impartiality of the courts and judges.

Internationally, Norway promotes the importance of independent courts and prosecuting authorities as a cornerstone of the rule of law. This means that investigation and prosecution of corruption cases must be conducted without undue influence from political or economic interests. Norway also advocates the importance of independent and robust anti-corruption institutions.

12. Holding professional facilitators accountable

Banks, lawyers, auditors, estate agents, accountants and other professionals play a crucial role in combating money laundering and other economic crime. Through customer due diligence under anti-money laundering legislation and by reporting suspicious transactions, they act as gatekeepers in the financial system. They have a legal obligation to comply with the Anti-Money Laundering Act and prevent misuse of their services for criminal purposes. Nevertheless, some actors abuse their positions to conceal illicit transactions and circumvent the legislation, which poses a significant challenge in the fight against corruption. The consequences of such complicity extend far beyond the specific offences by undermining trust in professions and institutions, weakening the rule of law and sustaining large-scale economic crime. Therefore, strict regulation, effective enforcement and ethical awareness among professional actors are essential to safeguard integrity in the financial and business sectors.

Norway has introduced a range of measures to hold professional facilitators accountable and prevent their involvement in corruption and economic crime. All the professionals mentioned above must meet requirements relating to licences, suitability assessments for individuals and personal authorisations, key functions and major owners, and supervision of regulatory compliance.

Internationally, Norway advocates that all countries regulate professions that may act as facilitators of economic crime in accordance with international standards. Furthermore, greater weight should be given to investigating and prosecuting professional facilitators involved in or enabling criminal activities related to illicit financial flows, including corruption.

13. Secure whistleblowing systems and protection of whistleblowers

Whistleblowers play a crucial role in combating corruption by exposing illegal and unethical acts that would otherwise remain hidden. Corruption often takes place in closed environments where abuse of power, bribery, and economic crime are concealed from the public. Without whistleblowers, many such cases would never be disclosed. Whistleblowing can expose hidden violations, prevent corruption, strengthen justice and accountability, and protect public funds and societal interests. Protection of whistleblowers is essential, as they often face retaliation, harassment or career-related consequences. Without adequate protection, fear of retaliation may prevent individuals from coming forward. Effective whistleblowing systems that ensure anonymity, confidentiality and protection from adverse consequences are essential. A strong legal framework for whistleblower protection ensures that individuals who report corruption are heard, protected and not subjected to unjust consequences.

The Working Environment Act contains provisions on whistleblowing in the workplace. Workplace whistleblowing involves an employee reporting an issue of concern at their own place of work. Employees always have the right to report such concerns internally and to public authorities. Employees may also report externally, for example to the media, if they act in good faith as regards the substance of the information disclosed, if the disclosure is in the public interest, and if the issue has already been reported through the organisation’s own channels, unless there is reason to believe that internal whistleblowing would not be appropriate. Enterprises that regularly employ at least five people are required to have internal whistleblowing procedures. When an issue of concern is reported, the employer must ensure that it is adequately investigated within a reasonable timeframe. The employer must also follow up the whistleblower and ensure that they have a fully satisfactory working environment. Retaliation against an employee who reports wrongdoing is prohibited.

Internationally, Norway promotes the importance of whistleblowing systems to prevent and detect corruption, and supports the development of effective legal standards that protect whistleblowers against negative sanctions.

14. Inclusive cooperation with civil society, media and other relevant stakeholders

Civil society organisations bring independent perspectives, local knowledge, and the ability to monitor and report on corruption in ways that often complement the work of government institutions. Independent media and investigative journalists play a critical role in the fight against corruption by revealing abuses of power, economic crime, and unethical conduct that might otherwise remain hidden. Through thorough investigation and public disclosure of corruption cases, they enhance both transparency and the accountability of both the government and the private sector.

Norway has a strong tradition of inclusive cooperation with civil society and support for a free press, and provides financial support to civil society organisations and independent media working for transparency and accountability.

Internationally, Norway works to ensure safe working conditions for journalists, civil society, and other actors so that they can detect, prevent, and combat corruption. Norway also seeks to uphold and strengthen standards that protect freedom of expression and press freedom, allowing civil society to operate freely and independently. Furthermore, Norway advocates that civil society should have a genuine voice in the design and implementation of anti-corruption measures, both nationally and in international forums such as the UN. In addition, Norway supports inclusive processes to ensure that civil society perspectives and experiences are incorporated into the development of international guidelines and anti-corruption measures, including in international evaluations. Norway has supported the UNCAC Coalition since its inception and also supports the International Consortium of Investigative Journalists.

15. Addressing secrecy jurisdictions and safe havens for corrupt actors and illicitly acquired assets

Secrecy jurisdictions or safe havens pose a challenge to international anti-corruption efforts because they help to conceal the identities of corrupt actors and their assets. These jurisdictions typically permit ownership secrecy or impose strict requirements on external authorities wishing to access information on ownership of companies, funds and bank accounts. This protects individuals who have acquired assets through corruption or other criminal activity. The use of secrecy jurisdictions also hampers investigation and prosecution, as they often restrict information sharing and cooperation with other countries. This makes it difficult for authorities to trace and confiscate the proceeds of corruption. A situation where there are opportunities to conceal assets is liable to encourage further corruption and undermine governance in both developing and established economies.

Transparency is a core value of Norwegian society. Norwegians generally have a high level of confidence in the authorities, and this is reflected in legislation and practices that promote openness regarding corporate structures, ownership and financial matters.

Norway works to promote effective international measures to reduce the number of jurisdictions that facilitate secrecy. Key instruments include information sharing on bank accounts and financial assets, increased beneficial ownership transparency, and effective implementation of FATF standards in all countries. In addition, continued support for investigative journalism and civil society will be crucial to uncover the use of such secrecy jurisdictions and their negative consequences, and thus contribute to reform.

16. Analysing and supporting the establishment of effective regional or international mechanisms to counter impunity when national systems do not work

In many countries, grand corruption goes unpunished because corrupt elites often control the legislative, executive and judicial branches. Major corruption cases are time-consuming, and investigations require significant resources and often involve multiple jurisdictions. There is a need for new investigative techniques, digital tools and specialised expertise. Cross-border corruption making use of complex corporate structures often involves elites in the political sphere, the public administration and the private sector.

Investigators are often subjected to pressure, threats, and interference in their work. Oversight bodies, investigators, prosecutors and judges must be guaranteed independence, resources, access to information and protection. A study by the U4 Anti-Corruption Resource Centre assessing UNCAC’s ability to address grand corruption concluded that the Convention’s provisions are only designed to deal with grand corruption to a limited degree. The study also highlights the need for more robust international commitments to support states in their efforts to prevent and combat grand corruption.

International mechanisms have proven crucial in countries with weak judicial systems. CICIG, established by the UN and Guatemala in 2007, is one of the most successful examples. The Commission investigated criminal networks, supported the prosecution service, and proposed reforms. CICIG contributed to over 120 court cases, uncovered extensive corruption within the government, and led to the president’s resignation in 2015. It enjoyed broad support from civil society and international actors but was dissolved in 2019 following political resistance. From civil society, a proposal has been launched to establish an international anti-corruption court.

Norway is supporting proposals to explore regional or international mechanisms or initiatives that can reduce problems related to impunity when national legal systems are unable or unwilling to ensure accountability. Norway will participate actively in relevant discussions on new mechanisms to counter impunity, and will consider supporting initiatives with the potential to strengthen the fight against impunity for grand corruption.

17. Making better use of the international anti-corruption framework, including strengthening UNCAC’s Implementation Review Mechanism and the active inclusion of developing countries

The UN Convention against Corruption (UNCAC) is a comprehensive global framework for preventing and combating corruption, and requires parties to strengthen anti-corruption measures at both national and international levels. The Implementation Review Mechanism (IRM) under the Convention is a peer review process and an important tool for assessing how countries are implementing the provisions of the convention. Through this mechanism, countries are regularly reviewed to identify implementation gaps and challenges, and to provide concrete recommendations for improvement. The mechanism also helps identify needs for technical assistance, so that states parties can receive necessary support to strengthen their anti-corruption efforts. The IRM promotes transparency and cooperation between states, which is essential for an effective global fight against corruption. Low-income countries rarely propose resolutions, and they tend to gain less of a hearing in CoSP negotiations and meetings of the IRM and other UNCAC subsidiary bodies

Norway ratified UNCAC in 2006, and has been reviewed twice under the Convention. The first review was in 2013, focusing on Chapter III (criminalisation and law enforcement) and Chapter IV (international cooperation). Norway was reviewed again in 2018 in the second cycle of reviews, this time focusing on Chapter II (preventive measures) and Chapter V (asset recovery).

Internationally, Norway is working to ensure that the Implementation Review Mechanism is maintained and strengthened by making it more transparent, inclusive and binding. This includes ensuring that the reviews involve civil society organisations and other relevant stakeholders, so that the review process is not solely a governmental matter but also reflects the broader interests of society. Norway also supports measures to increase public access to review reports and findings, so that recommendations can drive real change and accountability. For many years, Norway has been one of the largest financial contributors to technical assistance for developing countries, supporting implementation of convention and follow up recommendations in the reviews. This includes support for capacity building, legislative reforms and the establishment of institutions to strengthen anti-corruption efforts. Norway supports an initiative to ensure that low-income countries are enabled to propose resolutions and play an active part in their negotiation.

18. International legal cooperation

International legal cooperation is crucial in the fight against corruption, which often involves cross-border transactions, concealment of assets in multiple jurisdictions, and actors who operate in several jurisdictions. Without effective cooperation between countries, corrupt individuals and companies can exploit legal differences and loopholes to evade investigation and prosecution. International legal cooperation contributes to the development of norms and common standards.

To combat cross-border crime, Norway is party to several conventions and agreements that enable authorities to gather evidence and extradite individuals. Norway actively participates in various international forums for legal cooperation, including those under the Council of Europe and the United Nations. For corruption cases, the OECD Working Group on Bribery provides a useful operational platform and a meeting place for law enforcement and prosecuting authorities involved in these cases. Norway considers the 1959 European Convention on Mutual Assistance in Criminal Matters to be a key instrument in this field. This is a general convention on legal cooperation, not limited to a specific type of crime, contrary to the UNCAC, for example. UNCAC provides a framework for legal cooperation and extradition between state parties in corruption cases.

Internationally, Norway is working to strengthen mechanisms that encourage prosecution across borders. This involves playing an active part in the development and negotiation of new instruments in the field and ensuring the implentation and use of existing instruments.

19. Effective recovery of the proceeds of corruption from other countries

Returning the proceeds of corruption to the country of origin is important as a means of restoring economic justice, strengthening trust in the rule of law and returning assets to the population from whom they were stolen. When stolen assets are confiscated and responsibly returned, they can be used for social development, infrastructure and public services, rather than remaining in the hands of corrupt actors or in foreign jurisdictions.

However, there may be a risk that assets will be misused again after their return if the recipient country has problems with weak governance or corrupt authorities, or lacks mechanisms to ensure that the assets benefit the population.

Norway has systems in place to identify and return assets derived from corruption. Section 75 of the Penal Code states that confiscated proceeds of crime are as a general rule to be transferred to the state treasury. However, a court may decide that confiscated assets are to be used to cover compensation claims made by an injured party. The Ministry of Justice and Public Security has the authority to decide that confiscated assets are to be shared between the Norwegian state and one or more other states. In making such decisions, importance shall be attached to the costs incurred by these states, and in which countries adverse effects occurred and proceeds were acquired. Any division of assets must not result in a reduction of the compensation paid to the injured party. This provision is in accordance with Norway’s obligations under the UNCAC.

Internationally, Norway advocates effective asset recovery processes that take into account the importance of ensuring that returned assets benefit the population of the recipient country.