Ji Won Park

Billions in corrupt assets, complex money trails, strings of shell companies and other spurious legal structures. These form the complex web of subterfuge in corruption cases, behind which hides the beneficial owner-the puppet master and beneficiary of it all. Linking the beneficial owner to the proceeds of corruption is notoriously hard. With sizeable wealth and resources on their side, they exploit transnational constructions that are hard to penetrate and stay aggressively ahead of the game. Nearly all cases of grand corruption have one thing in common. They rely on corporate vehicles - legal structures such as companies, foundations, and trusts-to conceal ownership and control of tainted assets. The Puppet Masters: How the Corrupt Use Legal Structures to Hide Stolen Assets and What to Do About It takes these corporate vehicles as its angle of investigation. It builds upon cases, interviews with investigators, corporate registries and financial institutions, as well as a “mystery shopping” exercise that provide factual evidence of a criminal practice. This approach is used to understand the nature of the problem and design policy recommendations to facilitate the investigative process by unravelling the complex world of corporate vehicles. This report is solidly built on step-by-step arguments and designed to deliver practical, applicable, and well substantiated recommendations. It is intended for use by policy makers in developing national legislation and regulation as well as international standard setters. It also provides helpful information for practitioners engaged in investigating corrupt officials and academics involved in the study of financial crime.

Over the past decade, countries have increasingly used settlements - that is, any procedure short of a full trial - to conclude foreign bribery cases and have imposed billions in monetary sanctions. There exists a gap in knowledge, however, regarding settlement practises around the world and the disposition of these monetary sanctions - notably through the lens of recovery of stolen assets. Left out of the Bargain, a study by the Stolen Asset Recovery Initiative (StAR), provides an overview of settlement practises by civil and common law countries that have been active in the fight against foreign bribery.