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Transparency International Liaison Office to the European Union

TI EU

Transparency International EU promotes integrity and fights corruption within European Union institutions and laws.

Lobbying Activity

Meeting with Giuseppe Lupo (Member of the European Parliament, Shadow rapporteur)

20 Jan 2026 · EP Discharge 2024

Meeting with Daniel Freund (Member of the European Parliament) and European Environmental Bureau and

14 Jan 2026 · Attack against civil society

Meeting with Daniel Freund (Member of the European Parliament)

8 Dec 2025 · Next EU Budget, EU Tool Conditionality, Control of EU Money

Meeting with Cristina Guarda (Member of the European Parliament)

20 Nov 2025 · Conflict of interest in the EU policy making

Meeting with Daniel Freund (Member of the European Parliament)

18 Nov 2025 · Closing speech at Conference on Strengthening Enforcement against Cross-Border Corruption and Financial Crime

Meeting with Raquel García Hermida-Van Der Walle (Member of the European Parliament, Rapporteur)

18 Nov 2025 · Enforcement against cross-border corruption

Meeting with Daniel Freund (Member of the European Parliament) and European Environmental Bureau and

17 Nov 2025 · CONT Scrutiny Working Group

Meeting with Erik Marquardt (Member of the European Parliament) and European Environmental Bureau and

17 Nov 2025 · CONT Scrutiny Working Group

Meeting with Piotr Serafin (Commissioner) and

10 Nov 2025 · Implementation and Simplification Dialogue on the Review of the EU Anti-Fraud Architecture

Meeting with Dirk Gotink (Member of the European Parliament) and European Environmental Bureau

4 Nov 2025 · CONT SWG

Meeting with Alex Agius Saliba (Member of the European Parliament, Shadow rapporteur) and Civil Society Europe

23 Oct 2025 · Transparency of Third Country Representation Directive

Meeting with Daniel Freund (Member of the European Parliament) and Amnesty International Limited and

17 Oct 2025 · NGO-Workshop

Meeting with Jutta Paulus (Member of the European Parliament) and Amnesty International Limited and

17 Oct 2025 · Europagruppe Grüne: Austausch mit NGOs

Meeting with Erik Marquardt (Member of the European Parliament) and European Environmental Bureau

16 Oct 2025 · NGO scrutiny

Meeting with Daniel Freund (Member of the European Parliament) and ClientEarth AISBL and LobbyControl

15 Oct 2025 · Speaker at Cross-Party Event on "Transparency of the EU Legislative process"

Meeting with José Cepeda (Member of the European Parliament)

23 Sept 2025 · DCAM priorities

Meeting with Alex Agius Saliba (Member of the European Parliament, Shadow rapporteur) and Civil Society Europe

19 Sept 2025 · Transparency of Third Country Representation Directive

Meeting with Alex Agius Saliba (Member of the European Parliament, Shadow rapporteur) and Civil Society Europe

8 Sept 2025 · Transparency of Third Country Representation Directive

Amnesty International urges EU to safeguard European civic space

5 Sept 2025
Topic — A new framework to strengthen engagement and support for European civil society actors.
Message — Amnesty International calls for systematic impact assessments to ensure EU policies support civic space. They propose a fast-track monitoring mechanism and emergency support for organizations under attack. They also request a binding agreement to formalize civil dialogue in policy making.123
Why — This would secure long-term funding and legal safeguards for their advocacy and partners.45
Impact — Member States restricting civic space would face swifter legal consequences and increased oversight.67
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Meeting with Daniel Freund (Member of the European Parliament)

27 Aug 2025 · Austausch zu Ethikbehörde

Meeting with Daniel Freund (Member of the European Parliament)

27 Aug 2025 · NGO funding

Meeting with Daniel Freund (Member of the European Parliament)

17 Jul 2025 · NGO Funding

Response to Anti-racism Strategy

8 Jul 2025

The EU Anti-Racism Strategy, building on the current Anti-Racism Action Plan, could be a decisive moment for advancing racial justice, provided that civil society organisations, particularly those led by racialized communities, are empowered with the platform to shape and implement this strategy. It is imperative to ensure that the most marginalised voices are heard and their concerns addressed. While developing this strategy, we also urge you to work closely with those developing other relevant strategies, such as those on Gender Equality, on LGBTIQ and on Civil Society, in order to ensure a truly intersectional approach. Amnesty International stands with a wide range of civil society organisations, including the European Network against Racism, in calling for the re-imagining of racial justice. We call on European leaders to rise to the challenge and confront the tide of authoritarianism and racial justice to create a Europe grounded in human rights and dignity. A better world is possible, one that embraces care, justice, and safety for all, especially those at the margins. It is a world fit to address both past and present social and climate injustices. In response to fragmented policies and an overfocus on criminalisation and securitisation, we call for a shift from punitive policies to those that prevent harm and repair the damage already done. Only by embracing an intersectional and restorative approach, guided by the lived experience of those most affected, can we uproot the systems of racism. The following priorities must be central to this strategy: - A renewed intersectional anti-discrimination framework that also safeguards the rights of people on the move; - A legal ban on racial discrimination in law enforcement and migration control; - A focus on equality and fundamental rights within the Rule of Law Framework, with a sharp focus on racial discrimination, asylum rights, and the rights to protest and free expression; - A redirection of funding towards social provision and community services, with strict non-discrimination conditions attached to the allocation of funds; - Strong, inclusive participatory models for designing anti-racism policies, ensuring the voices of marginalised communities lead the way; - Ensuring that all equality strategies, the anti-poverty strategy and the European Pillar of Social Rights address the needs and protection of racialized groups, including migrants. Please see file attached for our full submission.
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Meeting with Daniel Freund (Member of the European Parliament)

8 Jul 2025 · NGO Funding

Meeting with Michael Mcnamara (Member of the European Parliament)

3 Jul 2025 · Transparency of interest representation carried out on behalf of third countries

Meeting with Damien Carême (Member of the European Parliament)

30 Jun 2025 · EoV EU list of High-risk Third Countries - Money laundering

Meeting with Rasmus Nordqvist (Member of the European Parliament) and Amnesty International Limited

27 Jun 2025 · Rule of law

Meeting with Jonás Fernández (Member of the European Parliament)

25 Jun 2025 · Delegated Regulation on list of high-risk third countries

Meeting with Hana Jalloul Muro (Member of the European Parliament, Committee chair)

3 Jun 2025 · UAE money laundering de-listing

Meeting with Raquel García Hermida-Van Der Walle (Member of the European Parliament, Rapporteur)

3 Jun 2025 · Anti-corruption directive

Meeting with Fabio De Masi (Member of the European Parliament) and Tax Justice Network and The Daphne Caruana Galizia Foundation

20 May 2025 · Preparatory meeting FISC mission to Abu Dhabi and Dubai

Meeting with Daniel Freund (Member of the European Parliament)

13 May 2025 · Malta EU citizenship

Meeting with Daniel Freund (Member of the European Parliament)

23 Apr 2025 · Future cooperation

Meeting with Katarina Barley (Member of the European Parliament)

22 Apr 2025 · Transparenz, Einflußnahme durch Drittstaaten

Meeting with Alex Agius Saliba (Member of the European Parliament, Shadow rapporteur)

22 Apr 2025 · Transparency of Third Country Interest Representation

Meeting with Pierre Jouvet (Member of the European Parliament, Shadow rapporteur)

2 Apr 2025 · marchés publics

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

1 Apr 2025 · Combating Corruption

Meeting with Daniel Freund (Member of the European Parliament)

26 Mar 2025 · Event Anti-Corruption Intergroup: Impact of Corruption and RoL in Enlargement Countries

Meeting with Mathieu Bousquet (Acting Deputy Director-General Enlargement and Eastern Neighbourhood)

25 Mar 2025 · Exchange of views on the EU’s enlargement policy and gradual integration.

Meeting with Raquel García Hermida-Van Der Walle (Member of the European Parliament, Rapporteur)

14 Mar 2025 · Anti-corruption Directive

Meeting with Adina Vălean (Member of the European Parliament, Rapporteur)

11 Mar 2025 · third countries' interests representation

Meeting with Daniel Freund (Member of the European Parliament) and Corporate Europe Observatory and

10 Mar 2025 · Exchange on Lobby Transparency Priorities

Meeting with Alex Agius Saliba (Member of the European Parliament, Shadow rapporteur)

10 Mar 2025 · Transparency of Third Country Interest Representation

Meeting with Olga Panagopoulou (Cabinet of Commissioner Piotr Serafin) and European Environmental Bureau and

4 Mar 2025 · Presentation of the views of Civil Society Europe on the issue of funding of NGOs, following the concerns raised in the EP CONT Committee in the context of the annual discharge procedure.

Meeting with Daniel Freund (Member of the European Parliament) and Centre for European Policy Studies

3 Mar 2025 · CEPS lab "An ethical oversight framework fit for Article 2"

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič), Sofia Asteriadi (Cabinet of Commissioner Maroš Šefčovič), Maria Olivan Aviles (Head of Unit Secretariat-General) and

24 Feb 2025 · Introductory meeting / transparency and ethics

Meeting with Maria Grapini (Member of the European Parliament)

20 Feb 2025 · Lupta împotriva corupției

Meeting with Daniel Freund (Member of the European Parliament) and European Environmental Bureau and

18 Feb 2025 · NGO funding & transparency

Meeting with Riho Terras (Member of the European Parliament, Rapporteur)

17 Feb 2025 · transparency

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

11 Feb 2025 · Commission discharge

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

27 Nov 2024 · Transparency policy

Meeting with Chloé Ridel (Member of the European Parliament, Shadow rapporteur)

19 Nov 2024 · Combatting corruption

Meeting with Daniel Freund (Member of the European Parliament) and Amnesty International Limited and

16 Oct 2024 · Cooperation on LIBE related matters

Meeting with Tineke Strik (Member of the European Parliament) and Amnesty International Limited and

16 Oct 2024 · LIBE Civil Society Meeting

Meeting with Raquel García Hermida-Van Der Walle (Member of the European Parliament, Rapporteur)

15 Oct 2024 · Anti-corruption

Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

11 Oct 2024 · General presentation on transparency

Meeting with Sergey Lagodinsky (Member of the European Parliament) and Delivery Hero SE

2 Oct 2024 · Exchange of views Start of the new mandate

Meeting with Nikola Minchev (Member of the European Parliament)

18 Jul 2024 · Meeting

Meeting with Johannes Noack (Cabinet of Commissioner Johannes Hahn)

4 Jul 2024 · Rule of Law situation in Hungary

Meeting with Antoine Kasel (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

4 Jul 2024 · Sovereignity law

Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Joachim Herrmann (Cabinet of Commissioner Didier Reynders)

4 Jul 2024 · Rule of Law in Hungary

Meeting with Věra Jourová (Vice-President) and

4 Jul 2024 · Sovereignty law

Meeting with Tineke Strik (Member of the European Parliament) and Amnesty International Limited and Helsinki Foundation for Human Rights

3 Jul 2024 · RoL Hungary Event

Meeting with Daniel Freund (Member of the European Parliament)

20 Jun 2024 · International Anti-Corruption Conference (IACC)

Meeting with Alexandra Geese (Member of the European Parliament, Shadow rapporteur) and Civil Society Europe and Forum Civique Européen

16 Apr 2024 · Defence of Democracy Package

Meeting with Alexandra Geese (Member of the European Parliament)

21 Mar 2024 · Defence of Democracy: transparency of (3rd country) interest representation

Meeting with Daniel Freund (Member of the European Parliament)

13 Mar 2024 · Rule of Law in Hungary

Meeting with Daniel Freund (Member of the European Parliament) and European Policy Centre and

1 Feb 2024 · The Rule of Law ahead of the EU elections

Meeting with Rasmus Andresen (Member of the European Parliament) and Deutscher Gewerkschaftsbund and

15 Dec 2023 · socio economic situation

Meeting with Daniel Freund (Member of the European Parliament) and LobbyControl and The Good Lobby

12 Dec 2023 · Ethics Body and Defense of Democracy Package

Meeting with Eider Gardiazabal Rubial (Member of the European Parliament, Rapporteur)

22 Nov 2023 · Meeting with Transparency International *Ukraine about Ukraine Facility

Meeting with Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

20 Oct 2023 · rule of law in Hungary

Meeting with Alice Brokelind (Cabinet of Commissioner Ylva Johansson)

20 Oct 2023 · Rule of Law in Hungary

Meeting with Katarina Barley (Member of the European Parliament)

10 Oct 2023 · Interinstitutional Ethics Body

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

4 Oct 2023 · Financial Regulation

Meeting with Maria Luisa Cabral (Cabinet of President Ursula von der Leyen)

26 Sept 2023 · Defence of Democracy Package

Meeting with Johannes Noack (Cabinet of Commissioner Johannes Hahn)

22 Sept 2023 · Meeting to discuss the conditionality mechanism

Meeting with Jeroen Lenaers (Member of the European Parliament)

21 Sept 2023 · Rule of Law Hungary

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

20 Sept 2023 · Discharge of the European Parliament

Meeting with Raphaël Glucksmann (Member of the European Parliament) and Civil Society Europe and European Partnership for Democracy

20 Sept 2023 · Ingérences étrangères, défense de la démocratie

Meeting with Damian Boeselager (Member of the European Parliament, Shadow rapporteur) and Corporate Europe Observatory

11 Sept 2023 · Rules of Procedure

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Amnesty International Limited and

7 Sept 2023 · Situation in Hungary

Response to Evaluation of Directive 2018/1673 (criminalisation of money laundering)

24 Aug 2023

Transparency International EU (TI EU) welcomes the opportunity to provide feedback on the evaluation of Directive 2018/1673 on combating money laundering by criminal law. As a leading organisation in the fight against illicit financial flows and corruption, we would like to present the following feedback to support the continuous improvement of this important initiative: 1. Ensuring accessible beneficial ownership data: Ensuring accessible beneficial ownership data gains utmost importance within the context of this criminal law directive. It plays a pivotal role in our collective efforts to combat money laundering and effectively prosecute offenders. Easy access to other member states' beneficial ownership information by national authorities is hereby essential. TI EU further advocates for accessible beneficial ownership registers, enabling civil society and investigative journalists to actively participate in the fight against money laundering and its predicate offences. This transparency empowers them to expose illicit activities, hold wrongdoers accountable, and contribute to revealing money laundering operations. This Directive presents a valuable opportunity to strengthen the partnership between civil society and regulatory authorities, reinforcing the fight against illicit financial flows with greater cross-border cooperation and the involvement of a more diverse range of stakeholders. 2. Criminal prosecution of professional enablers: Enablers are key players in facilitating the movement and concealment of illicit funds. Despite their crucial role, the prosecution of enablers is often lacking or inadequate. Enablers can include a broad range of non-financial sector professionals such as lawyers, accountants, notaries, real estate agents, private wealth managers, and traders in precious metals among others. Holding these facilitators accountable through more criminal prosecution will serve as a powerful deterrent. The Directive should better close the gap between the criminalisation of money laundering offenses and the prosecution of those who enable these crimes. 3. Strengthening oversight of self-regulatory bodies: In certain member states, oversight mechanisms have shown shortcomings, leading to a tendency to conceal issues rather than promoting increased prosecutions within their own profession. Consequently, the scarcity of enabler prosecutions raises concerns about the efficacy of self-regulatory bodies in combating money laundering. 4. Extend the catalogue of predicate-offences: Evasion of foreign currency controls should be recognised as a predicate offence, encompassing deliberate actions by individuals or entities engaging in financial transactions to evade currency controls imposed by foreign jurisdictions, curbing an important avenue used by criminals to move illicit funds discreetly across borders. Additionally, to address the issue of concealing funds, the Directive should explicitly include activities aimed at hiding the true source or nature of illegally obtained money or proceeds from unlawful activities, whether through knowing participation in such financial transactions or through attempts to hide or disguise the proceeds' nature, location, source, ownership, or control. Furthermore, tipping off should be added as a predicate offence, serving as a stronger deterrent against potential suspects obstructing investigations or tampering with evidence. 5. Criminal prosecution based on asset origin: To strengthen the fight against money laundering, it is crucial to consider cases where specific criminal activities cannot be proven, but the criminal origin of assets is evident. Introducing well-defined non-conviction-based confiscation, in conjunction with asset recovery, will enable authorities to target the ill-gotten gains of criminals more effectively. This approach ensures that criminals cannot evade accountability solely due to the challenge of proving individual offenses.
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Meeting with Simona Constantin (Cabinet of Vice-President Věra Jourová) and Civil Society Europe and

28 Jul 2023 · Defence of Democracy

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Amnesty International Limited and

14 Jul 2023 · Situation in Hungary

Transparency International EU urges mandatory beneficial ownership reporting

7 Jul 2023
Topic — This consultation defines sustainability reporting standards for companies to disclose environmental and social impacts.
Message — Transparency International EU strongly urges for the re-inclusion of beneficial ownership information in the final reporting standards. They argue transparent ownership is crucial for identifying the true owners and decision-makers behind corporations.12
Why — Public disclosure provides the organization with free, accessible data for its anti-corruption investigations.34
Impact — Secretive entities and corrupt networks lose their ability to hide control of business operations.5
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Meeting with Věra Jourová (Vice-President) and

6 Jul 2023 · Defence of Democracy

Meeting with Daniel Freund (Member of the European Parliament) and Heinrich Böll Stiftung e.V. and

26 Jun 2023 · Treaty reform

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Civil Society Europe

26 May 2023 · EU Foreign Interference Directive

Meeting with Simona Constantin (Cabinet of Vice-President Věra Jourová), Wojtek Talko (Cabinet of Vice-President Věra Jourová)

24 May 2023 · Media policy and Defence of Democracy

Meeting with Sergey Lagodinsky (Member of the European Parliament)

27 Apr 2023 · Defence of Democracy Package

Meeting with Sophia In 'T Veld (Member of the European Parliament, Rapporteur)

24 Apr 2023 · Directive definition criminal offences and penalties for the violation of Union restrictive measures

Meeting with Didier Reynders (Commissioner) and

24 Apr 2023 · Defence of democracy

Meeting with Saskia Bricmont (Member of the European Parliament, Shadow rapporteur) and Norwegian Refugee Council Europe and CiFAR - Civil Forum for Asset Recovery e.V.

19 Apr 2023 · Points de vue sur la directive sanctions

Response to Recommendation on covert interference from third countries

13 Apr 2023

The European Commission's recently announced Defence of Democracy Package demonstrates the European Union's commitment to democracy, transparency, and integrity and we welcome the Unions efforts to create a dedicated instrument for protecting our democratic societies. With unprecedented challenges and threats, it is more crucial than ever that the Union remains vigilant and proactive. It is in this spirit that TI EU would like to highlight some of its concerns. As part of the announced Package and call for evidence, the Commission is proposing the introduction of a new legal instrument (Directive) to introduce common transparency and accountability standards for interest representation directed or paid from outside the EU (). The Directive appears akin to a 'Foreign Agents Act', despite its aims to strengthen transparency and accountability. Several aspects of the proposal make it problematic. Firstly, a Directive leaves Member States significant leeway for abuse, especially for those with worrisome rule of law issues and who have already acted to curb civil society at the domestic level. Indeed, the European Commission took Hungary to court over a law on the foreign funding of NGOsand won the case. Hungary had passed a law requiring NGOs receiving foreign funding to designate themselves as organisations supported from abroad. Secondly, the EU should not forget that HR/VP Josep Borrell has condemned Georgias foreign agents law as incompatible with EU values as well as detrimental to civil society and the media. Thirdly, the proposed Directive risks undermining the EUs own external efforts towards strengthening civil society in third countries, because it mimics laws the EU itself has opposed elsewhere. While we support efforts to strengthen transparency and anti-corruption legislation, a Directive similar to a Foreign Agents Act effectively externalises corruption threats to the EU, ignoring the fact that breaches to the EUs political integrity system stemmed from a lax internal ethics framework. We believe that it is equally important to address internal threats to democracy, such as undue interest representation as a domestic form of interference. The European Commission should therefore pursue an EU Interest Representatives Act instead of this Directive. Such an Act should cover all interest representatives in the Unionfrom civil society to business associationsbased on the EU transparency register, using Article 114 TEU as appropriate legal basis. Indeed, the transparency register already serves as a positive example of interest representative regulation harmonisation at EU level, thereby counterbalancing any internal market distortions in placing minimal burdens on interest representatives themselves. Without an Impact Assessment, we believe that the Commission does not fully appreciate the risks of this proposal, contravening the Commissions Better Regulation Agenda and the principle of do no significant harm. Staff working documents cannot substitute for a thorough exercise of an Impact Assessment and the Commissions pursuit of the proposal despite its past action against Hungary suggests it has not learnt from experience or evidence. Given the proposals potential for civil society damage, we question the proposals necessity and proportionality. To determine if the proposed Directive is necessary and proportionate to what is currently a very undefined goal, an Impact Assessment is imperative. The assessment should cover alternative, holistic, and horizontal approaches to both internal and external funding of the Union as proposed above. Foreign and domestic interference can be exercised by anyone with ill intentions through any entity, and recent events in Hungary and Georgia have emphasises the unacceptable dangers associated with such laws. Considering this proposals negative impact on civil society, it is crucial to ensure that the EUs efforts to protect democracy will in fact not undermine it.
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Meeting with Viola Von Cramon-Taubadel (Member of the European Parliament, Shadow rapporteur) and Committee to Protect Journalists

30 Mar 2023 · SLAPPs

Meeting with Damian Boeselager (Member of the European Parliament)

27 Mar 2023 · Rules of Procedure

Meeting with Daniel Freund (Member of the European Parliament) and Corporate Europe Observatory and LobbyControl

27 Mar 2023 · Reform of rules of procedure (EP)

Meeting with Pascal Durand (Member of the European Parliament)

20 Mar 2023 · Transparency Register - APA Meeting

Meeting with Věra Jourová (Vice-President) and European Youth Forum and

17 Mar 2023 · Defence of democracy package

Meeting with Pedro Marques (Member of the European Parliament, Shadow rapporteur)

17 Mar 2023 · AMLA

Meeting with Alvaro De Elera (Cabinet of Vice-President Věra Jourová), Eduard Hulicius (Cabinet of Vice-President Věra Jourová)

10 Mar 2023 · Ethics Body

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

22 Feb 2023 · Transparency on recipients of EU funds (staff level)

Response to EU rules on fighting against corruption

17 Feb 2023

1) Remark concerning the legal basis The chosen legal basis for EU action in the field of the fight against corruption is Article 83 of the TFEU, which concerns criminal matters. While corruption should indeed be treated as a serious crime, accompanied by appropriate sanctions, we would like to highlight that only Article 83 TFEU as a legal basis can be very limiting. Hence, we would propose a dual legal basis, Article 83 and 114 TFEU on the establishment of the internal market, as combatting fraud and corruption pose serious criminal, economic and financial threats, and must be combatted holistically across different policy areas. 2) TI priorities in the upcoming EU initiative on strengthening the fight against corruption Legislative and operational barriers As a legislative matter, Member States need to create a level playing field when it comes to criminalising embezzlement, illicit enrichment, influence trading, abuse of functions, obstruction of justice, revolving doors, and illicit party financing, as well as corresponding sanctions. Since enablers play decisive roles in grand corruption schemes, criminalising activities that aid or abet corruption also need to become a top priority. Furthermore, we propose to enlarge the scope of corruption offences and make illicit enrichment a new and well-defined crime under any new instrument. To ensure the right level of prioritisation and a good understanding of risks, law enforcement agencies (LEAs) and judicial authorities must have adequate capacities to fight corruption decisively. This includes increased financial and human resources, training, and expertise of staff, including for high-ranking officials such as ministers or prosecutors. To take out the profit from corruption, it is imperative that authorities have adequate resources to seize and confiscate all proceeds and instrumentalities of corruption, not only those related to organised crime. A reversed burden of proof shall hereby increase the effectiveness of confiscations related to illicit enrichment cases. In absence of such a provision, the effectiveness of confiscation measures could be hampered by allegations of perpetrators that the property targeted by competent authorities for confiscation does not result from illicit activity. Prevention efforts A serious attempt must be made by the EU to target the enablers that allow criminals and kleptocrats to thrive, by clearly defining what qualifies as enabler of corruption and sanctions for them. The EU must make it financially and reputationally unattractive to service criminals and kleptocrats across Member States. Financial and asset declarations shall be put in place in all Member States for high-ranking officials, MPs, and other PEPs, and shall also include relevant information on their immediate family members. After the verification of the data, declarations shall be included in an anti-corruption data base and shall be publicly available in a machine-readable format. Furthermore, authorities should enhance coordination, cooperation, and information exchange among the various authorities tackling corruption, organised crime, and money laundering. A regular exchange of information must occur between law enforcement, FIUs, asset recovery offices, and anti-corruption agencies as well as coordination and cooperation with authorities in other EU Member States and third countries. For the effective prevention of corruption, Member States shall put in place specific services on ethics and integrity. In order for public administration staff to identify and report threats effectively, they should have access to specific trainings, services, and points of advice, including high-ranking officials. Lastly, dedicated anti-corruption measures must surely not be viewed in isolation. A successful anti-corruption framework must treat all corruption-related offences independently of organised crime and not merely as a facilitating or compounding factor.
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Response to New Agenda for Latin America and the Caribbean

9 Feb 2023

The EU should address chronic human rights concerns, including poverty, inequality, corruption, insecurity, and environmental degradation while protecting democracy. Longstanding failure to address these concerns has been used by some to justify policies that restrict or disregard rights and has driven millions of people to flee their homes. 1. Uphold fundamental rights and prevent democratic backsliding During 2022, some elections took place in a context of political violence and challenges to independent electoral institutions, including candidates who proposed undermining rights and democratic guarantees. In some cases, including Venezuela, Guatemala and El Salvador, limited or non-existing safeguards for the right to participate in public affairs, non-independence of the judiciary or other issues raise concerns about the fairness of the electoral process. In Cuba, Nicaragua, and Venezuela, repressive governments committed systematic abuses. A critical task is to strengthen democracy and helping bolster the capacity of independent institutions, such as electoral authorities and ombudspersons office, to perform their tasks. The EUs agenda should: Reinforce democratic principles such as judicial independence, transparency, free speech, and other basic freedoms; Work with Latin Americas democratically elected leaders to press for transitions to democracy; Seek to jointly work in multilateral fora to defend human rights consistently, including condemning abuses by governments, regardless of their ideology. 2. Address poverty and inequality and ensure international protection for people on the move In Latin America, about a third of the population live in poverty. Structural racism is a serious problem. Poverty and inequality disproportionately affect women, children, and Indigenous people. Many people are on the move escaping violence, repression, and poverty. Many are denied the chance to seek protection or encounter obstacles on their journey. The EUs agenda should: Contribute to addressing poverty, inequality and structural racism in Latin America, in ways that are sustainable and ensure respect for rights. Promote a coordinated regional response to migration. Commit to globally uphold the right to seeking international protection and recognize that millions of people forced to flee their homes face abuses during their journey. 3. Address climate change and the increased biodiversity loss Deforestation, degradation and fires are pushing the Amazon rainforest toward a tipping point. In combination with fossil fuel operations, it is a major source of greenhouse gas emissions. This is devastating biodiversity and livelihoods and is accompanied by violence against defenders. An important driver is the production of agricultural commodities destined for export. The EUs agenda should: Embrace a strategy consistent with the goal of keeping global warming under 1.5°C and with the protection of primary forests and other natural carbon sinks; Commit to legislations restricting the import of agricultural commodities linked to deforestation and rights abuses and requiring private enterprises in Europe to address their contribution to environmental degradation and climate change; Support protection measures to Indigenous and environmental defenders and end impunity for violence and intimidation against them. 4. Support rights-respecting strategies to address crime and violence LAC has the highest regional annual homicide rate in the world. Failure to address violence by gangs, criminals and armed groups has resulted in increased abuses in several countries. In others, iron fist policies have resulted in widespread human rights violations. The EUs agenda should: Promote and support sustainable and rights-respecting security policies, focusing criminal investigations on leaders of gangs or armed groups and preventing recruitment by improving access to education, work and other opportunities.
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Meeting with Daniel Freund (Member of the European Parliament) and LobbyControl and The Good Lobby

1 Feb 2023 · EU Ethics Body

Meeting with Kathleen Van Brempt (Member of the European Parliament) and Antwerp World Diamond Centre

1 Feb 2023 · European sanctions targeting Russian diamonds & enhancing traceability and due diligence in the diamond industry

Meeting with Sergey Lagodinsky (Member of the European Parliament, Rapporteur for opinion) and CiFAR - Civil Forum for Asset Recovery e.V.

31 Jan 2023 · Asset Recovery and Confiscation Directive

Meeting with Karen Melchior (Member of the European Parliament)

31 Jan 2023 · Intergroup on possible action on transparency and anti-corruption in EU Institutions

Meeting with Ernest Urtasun (Member of the European Parliament)

30 Jan 2023 · Plenary debate on the Need for urgent update of the EU list of high-risk third countries for anti-money laundering and terrorist financing purposes

Meeting with Eduard Hulicius (Cabinet of Vice-President Věra Jourová)

27 Jan 2023 · Ethics and transparency

Meeting with Marcel Kolaja (Member of the European Parliament, Shadow rapporteur for opinion) and Frank Bold Society and NFNZ – Nadační fond nezávislé žurnalistiky

27 Jan 2023 · discussion about provisions of the Media Freedom Act

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

27 Jan 2023 · Lobby transparency (staff-level)

Meeting with Ramona Strugariu (Member of the European Parliament, Rapporteur for opinion) and Committee to Protect Journalists and

26 Jan 2023 · Anti-SLAPP Directive

Meeting with Dragoş Pîslaru (Member of the European Parliament, Rapporteur) and K-Monitor Közhasznú Egyesület

23 Jan 2023 · Transparency provisions in the RRF and REPowerEU Regulations

Meeting with Daniel Freund (Member of the European Parliament)

10 Jan 2023 · Transparency, financial transparency and anti-corruption

Meeting with Daniel Freund (Member of the European Parliament)

21 Dec 2022 · Transparence in EU politics

Meeting with Stéphane Séjourné (Member of the European Parliament)

13 Dec 2022 · Ethics and transparency (Equipe)

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

8 Dec 2022 · 2022 Commission Rule of Law Report (staff-level)

Meeting with Ramona Strugariu (Member of the European Parliament)

2 Dec 2022 · Anti-corruption

Meeting with Pedro Marques (Member of the European Parliament, Shadow rapporteur)

25 Nov 2022 · AMLA

Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Rapporteur)

15 Nov 2022 · Meeting with stakeholders

Meeting with Saskia Bricmont (Member of the European Parliament)

10 Nov 2022 · Meeting - Transparency International EU- sanctioning Russian diamond import

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

9 Nov 2022 · Revision of the Financial Regulation (staff-level)

Meeting with Daniel Freund (Member of the European Parliament)

9 Nov 2022 · Rule of Law Conditionality (staff-level)

Meeting with Daniel Freund (Member of the European Parliament, Shadow rapporteur)

7 Sept 2022 · Corruption and transparency in the European Parliament (staff-level)

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Amnesty International Limited and

7 Sept 2022 · Situation in Hungary

Transparency International demands full disclosure of beneficial owners

20 Jun 2022
Topic — The European Commission is defining high-value datasets for the Open Data Directive.
Message — Transparency International calls for including full company ownership and beneficial owner data in high-value datasets. They argue current proposals provide only basic information, failing to combat corruption or money laundering.12
Why — Access to this data enables the organization to investigate corruption and monitor financial crimes effectively.3
Impact — Corrupt individuals and money launderers lose the anonymity used to hide illegal financial activities.45
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Response to Standard forms for procurement notices

7 Mar 2019

Timo Pesonen Director-General Directorate-General Internal Market, Industry, Entrepreneurship and SMEs (GROW) European Commission Berlin, 8th March 2019 Object: Response to public consultation by the European Commission on draft Implementing Regulation establishing standard forms for the publication of notices in the field of public procurement Dear Mr. Pesonen, We thank you for the opportunity to provide feedback on the proposed update to the EU’s public procurement standard forms. Since 2015, together with eleven TI national chapters and three other civil society partners, we have been closely monitoring public procurement processes in eleven European Union Member States. Through this work we have identified gaps in beneficial ownership transparency as a major obstacle to ensuring clean public procurement. As such, we very much welcome the introduction of beneficial ownership transparency in public procurement processes and the willingness to better integrate beneficial ownership and public procurement databases. We also acknowledged other improvements such as the requirement to provide company identifiers to facilitate cross-referencing of databases as well as the obligation to provide disaggregated data on amounts bid. This should contribute to further increasing the transparency, accountability and effectiveness of public procurement processes. However, we would like to suggest a few recommendations for improvement to further align with new European standards on beneficial ownership transparency: The current proposal only requires the public authorities to collect the nationality of the beneficial owner. We urge the Commission to align public procurement requirements with European anti-money laundering standards by requiring the collection of comprehensive data on the beneficial owners of companies bidding for public contracts. As per new European beneficial ownership transparency rules, this information should consist of at least the name, the date of birth and the country of residence and nationality of the beneficial owner as well as the nature and extent of the beneficial interest held and contact details in accordance with data protection rules. Information on the beneficial owners of the bidders - consisting of at least their name, month and year of birth, country of residence and nationality as well as the nature and extent of the beneficial interest held - should be made publicly available. The current proposal puts the obligation to collect the information on public authorities. The information will be mainly accessed through the new public beneficial ownership registers. However, the registers do not include information on foreign companies operating in the EU. This constitutes a major loophole which raises particular concerns for bidding in strategic sectors. A more efficient way to ensure full coverage and the collection of comprehensive, accurate and updated data on beneficial owners would be to require bidders to supply the information and cross-check this information with the data held in public beneficial ownership registers. This would provide an additional means to verify beneficial ownership data. To the extent possible, the proposal should encourage the integration of public procurement databases within the ecosystem of existing national databases (e.g. business registers, beneficial ownership registers, tax registers, etc.) for example through the use of common company identifiers, integration on common platforms, etc. We hope you will consider these recommendations favourably and remain available should you have any question or need further clarification. Yours sincerely, Patricia Moreira Managing Director Transparency International Secretariat
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