GRECO ¦ Anti-Corruption Trends, Challenges and Good Practices in Europe & the USA

GRECO’s 2025 review shows corruption risks still concentrated at the top

GRECO’s 26th General Activity Report makes one point very clear: corruption prevention is still not where it needs to be in Europe and the United States. The Council of Europe’s anti-corruption monitor found some progress in 2025, but also a pattern that matters directly for financial crime professionals: reforms are moving more slowly at the top of government than in law enforcement, and too many safeguards remain incomplete.

For banks, compliance teams, investigators and corporate risk officers, that matters because the highest corruption risks often begin with weak controls around public decision-making, lobbying, gifts, conflicts of interest, asset disclosure and post-employment restrictions. When those controls are thin, the chance of bribery, trading in influence, hidden beneficial interests and related financial crime rises.

What GRECO found in 2025

The report covers 48 members and shows continued monitoring across Europe, Kazakhstan and the United States. GRECO adopted 30 evaluation and compliance reports in 2025 and says the overall picture remains mixed. It also notes that political polarisation, nationalism and populist pressure are making anti-corruption reform harder in some countries.

A key message is that integrity cannot be treated as a formality. GRECO says democracy is at risk without a strong culture of integrity and effective safeguards. That is not just a governance warning, it is a financial crime warning. Weak integrity systems create openings for concealed influence, procurement distortion, illicit enrichment and abuse of office.

Bastian Schwind-Wagner _Follow

"GRECO’s 2025 report shows that anti-corruption reform is still uneven across Europe and the United States. Progress is visible in some law enforcement systems, but top executive functions remain a major weak point, especially on conflicts of interest, lobbying transparency, asset declarations, and enforcement.

Weak integrity controls at the public sector level create real exposure to bribery, fraud, and hidden influence. Strong due diligence, better transparency checks, and closer monitoring of politically exposed relationships remain essential."

Top executive functions remain the weak spot

GRECO’s 5th Evaluation Round focuses on persons with top executive functions in central government and on law enforcement agencies. This is where the report becomes especially relevant for financial crime readers.

The findings on top executive functions are troubling. GRECO says implementation of its recommendations remains overall unsatisfactory, with wide differences between countries. More than one third of the recommendations for top executives remained unimplemented, while 41% were only partly implemented and only 22% were fully implemented.

In practical terms, that means many governments still lack strong systems for handling conflicts of interest, gifts, transparency around contacts with lobbyists and third parties, public consultation, asset and interest declarations, and post-employment rules. GRECO also found that oversight and enforcement are often weak or not fully operational.

Why this matters for bribery and corruption risk

These weaknesses are not abstract. They are the conditions that allow bribery schemes and influence-peddling to operate in plain sight.

If ministers, advisers and other top officials do not have clear and public rules on gifts, outside interests and lobbying contacts, it becomes harder to detect whether a business relationship is legitimate or a disguised payoff. If asset declarations are not checked properly, unexplained wealth can go unnoticed. If post-employment restrictions are vague or unenforced, revolving-door risk grows. If codes of conduct exist only on paper, then enforcement becomes optional.

For companies in regulated sectors, this is especially important. The report reinforces the need for stronger due diligence on politically exposed persons, advisers, intermediaries and public-sector counterparties, not only in cross-border business but also in domestic dealings.

Law enforcement performed better – but gaps remain

GRECO’s findings for law enforcement agencies are more encouraging, though still far from perfect. It says implementation in this area is more advanced than for central government, with 35% of recommendations fully implemented and 37% partly implemented.

That said, the report still points to persistent concerns around recruitment, career progression, integrity checks, operational independence, outside activities, post-employment restrictions, financial disclosure and internal oversight. In anti-corruption terms, law enforcement is both a shield and a risk area. When recruitment and promotion are not merit-based, or when internal control is weak, corruption can spread inside the very institutions meant to prevent it.

GRECO also highlights the importance of whistleblower protection in law enforcement. That is particularly relevant for fraud and corruption detection because hidden misconduct often comes to light only when employees feel safe reporting it. Where reporting channels are unclear or retaliation fears remain high, financial crime risk increases.

Access to information is still a practical problem

Another recurring issue is access to information. GRECO says delays, overuse of exceptions, weak proactive transparency and low public awareness remain common. For financial crime purposes, that is not a minor administrative issue. Access to public information is often what allows journalists, civil society, investigators and compliance teams to identify unusual procurement awards, hidden ownership links, conflicts of interest and lobbying patterns.

If public records are hard to obtain or incomplete, red flags are easier to miss. That means transparency failures can directly affect fraud detection, sanctions screening, third-party due diligence and transaction monitoring.

Good practices are spreading, but unevenly

The report does not only list problems. It also points to useful examples of good practice. Cyprus introduced a centralized e-consultation platform and published registers for political advisers. Germany created an executive footprint in the law-making process. Portugal has a confidential advice unit for government members. Spain involves civil society in transparency oversight. Iceland strengthened merit-based recruitment and integrity checks in policing. Romania improved public information on donations and sponsorships. The United Kingdom’s National Crime Agency introduced a confidential reporting tool for misconduct and corruption.

These examples matter because they show what effective anti-corruption controls look like in practice: clear rules, real oversight, traceable decisions, protected reporting and public visibility.

The business and compliance takeaway

For financial institutions and corporate compliance teams, GRECO’s report is another reminder that public-sector corruption risk is still a major part of financial crime risk. The usual control themes remain central: enhanced due diligence on politically exposed persons, scrutiny of intermediaries and consultants, monitoring for gifts and hospitality risk, checks on beneficial ownership, and careful review of procurement-related payments and advisory mandates.

The report also supports a broader point. Compliance programs should not treat corruption risk as limited to obvious bribery cases. Weak transparency, poor declarations, vague lobbying rules and ineffective sanctions often create the environment in which fraud, laundering, kickbacks and hidden influence thrive.

The bottom line

GRECO’s 2025 activity report shows progress, but not enough progress where it matters most. Law enforcement is improving faster than central government, yet both areas still contain serious gaps. The message for the financial crime community is simple: corruption prevention remains a live control issue, not a compliance box-ticking exercise.

When integrity systems are weak at the top, the risks do not stay in politics. They spill into procurement, contracting, enforcement, licensing, investigations and financial flows. That is why GRECO’s findings should be read not only as a public-sector governance report, but as a signal to anyone responsible for detecting and preventing financial crime.

Dive deeper

• Council of Europe’s GRECO ¦ Government leaders must lead by example in combating corruption and promoting integrity ¦ Link