Blog by Professor Adina Dudau, Dr Denisse Rodriguez Olivari, Dr Georgios Kominis and Dr Alvise Favotto, Adam Smith Business School, University of Glasgow 

For decades, the fight against corruption has been paved with good intentions. Nevertheless, grand corruption persists, infiltrating financial systems and eroding the rule of law, as revealed in our Horizon-funded research on organisational integrity in five sectors at high risk of corruption. The proposed EU Anticorruption Directive seeks to change this, building on existing regulatory foundations related to crimes such as money laundering and the protection of whistleblowing, and addressing the gaps where theory and practice have catastrophically diverged.

A key shift is the harmonisation of core corruption offences such as bribery, trading in influence, and obstruction of justice across all Member States. This creates a baseline that ensures corrupt acts cannot slip through the cracks of national legislation. Introducing, for instance, a legal stipulation that companies (as ‘legal entities’) can be held criminally liable for corruption offences is a powerful deterrent, which is accompanied with severe fines based on their turnover. The directive learns from harrowing failures we recently analysed in our Integrity Management Work Package of BridgeGap, the largest Horizon Europe funded anti-corruption consortium.

One area of poor corporate practice we covered in our research is that of whistleblowing protection. Consider the Post Office Horizon scandal in the UK (the case began when the UK was a member of the EU), for instance. Subpostmasters, excluded from whistleblower protection due to their employment status, were powerless against a faulty IT system and many were wrongly prosecuted on that account. While the EU Anti-Corruption Directive will not apply to the UK, if it did, it would ensure that people like the UK Post Office subpostmasters (essentially self-employed franchises in the UK, rather than employees, which is why they were not covered by current legislation) are protected, moving regulation beyond a tick-box exercise to create a tangible safety net for those on the front lines, regardless of their employment status.

Similarly, in the infamous Novartis Hellas case, whistleblowers saw their protected status revoked and faced prosecution, which shows how legal safeguards can be insufficient in protecting those reporting cases of corruption. The proposed EU directive counters this by mandating support for cooperators in criminal proceedings, actively defending guardians of integrity instead of assuming the law alone will shield them.

Another area of EU anti-corruption scrutiny which we have also covered in our research is money laundering. In anti-money laundering (AML), the common wisdom has been to follow the money after the crime. The proposed EU directive, however, addresses the problem at its source: the enrichment that occurs both during and after the crime. This is referred to as “self-laundering” (i.e., when a corrupt official is not prosecuted for enjoying their own illicit proceeds) and is currently a loophole in existing AML rules. The directive seeks to criminalise it, directly targeting the financial incentive that fuels corruption. This closes a legal void exploited in complex schemes where offshore structures obscured the flow of illicit payments. In cases like the Belgian Operation Zero (“Clean Hands”), where offshore structures obscured bribe trails, this would allow prosecutors to target self-laundering by prosecuting the enjoyment of illicit proceeds, even when the underlying payment cannot be conclusively traced.

Finally, public procurement is another area of poor corporate practice, which stems from illicit connections with public sector organisations. In our research, we argue that public procurement is a critical juncture where public and private values converge, so it is highly vulnerable to systemic corruption. For example, in our Horizon Europe BridgeGap report, we describe infamous cases of firms (specifically in defence and healthcare) exploiting opaque and poorly supervised procurement processes to manipulate tender specifications and channel bribes to secure lucrative public contracts, both within and beyond Europe. While the new EU Anti-Corruption Directive may not prevent offences done outside Europe, it makes European ones more difficult as it introduces beneficial-ownership transparency, independent technical validation, and open-book rights non-negotiable in high-risk contracts.

The proposed directive thus represents a crucial evolution in the fight against corruption in the EU. It acknowledges that defeating corruption requires more than just a rulebook. It is sustained in a system that actively protects the vulnerable, dismantles the profit motive, and penalises complicity. It is a bold move from fighting corruption in theory to upholding integrity in practice. It is also why the final stretch of negotiations is hard: turning a comprehensive blueprint into EU law means aligning 27 legal systems, social norms and countless sectoral realities. Comprehensiveness can lead to conflicting priorities, but focusing on specific events can help drive policy action. Ultimately, however, these high-level commitments will stand or fall with what happens inside organisations.

Our report on organisational integrity systems analyses 5 such critical incidents from the 5 sectors identified by the EU Commission as being at high risk of corruption (defence, infrastructure, health, sports and finance) and shows how they can be used to drive implementable reforms. By addressing the disconnect between formal commitments and operational realities in organisations, the proposed EU directive has the potential to close critical integrity gaps identified across our case studies. Yet this is only half of the battle: organisations themselves can also do more to embed stronger boundary, diagnostic, and interactive integrity management systems and intermediaries can incentivise that in specific high-risk sectors.

Authors 

Professor Adina Dudau, Professor of Public Management (Management) at the Adam Smith Business School and Senior Fellow of the Centre for Public Policy, University of Glasgow

Dr Denisse Rodriguez Olivari, Research Associate at the Adam Smith Business School, University of Glasgow

Dr Georgios Kominis, Senior Lecturer (Accounting & Finance) at the Adam Smith Business School, University of Glasgow 

Dr Alvise Favotto, Senior Lecturer (Accounting & Finance) at the Adam Smith Business School, University of Glasgow

Funded by the European Union under the European Commission’s Horizon Europe Programme for Research and Innovation, Grant Agreement number 101132483 (Project: BridgeGap). Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or the granting authority, the European Commission. Neither the European Union nor the granting authority can be held responsible for them. 

First published: 25 November 2025

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