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Abstract
This chapter delves into the geopolitics of state capture, a systemic corruption phenomenon that has become embedded in global capital markets. It examines how elites instrumentalise state institutions to extract rents and launder proceeds through transnational professional enablers, notably financial institutions. The chapter also explores how state capture transcends self-serving corruption, with countries like China and Russia using it as a tool for hybrid warfare and grey-zone tactics. The text provides a proof-of-concept for a theoretically-driven comparative approach to state capture, drawing on case studies of the Eastern European Laundromat and the Zuma administration in South Africa. It also conceptualises the failures of legal and regulatory regimes through a global state capture lens and expands upon nascent research on state capture as a political modality. The chapter concludes that state capture is not merely an outcome but a dynamic and strategic mode of governance with significant geopolitical implications.
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Abstract
This chapter explores the geopolitical implications of systemic corruption by way of state capture. No longer a mere byproduct of weak governance, illicit gains from state capture have become an instrument of geopolitical leverage that large authoritarian states such as Russia and China use to project power and influence. State capture characterises a system where private interests collude to shape laws, policies, and regulations for their personal benefit by subverting public institutions. State capture endures due to systemic failures in domestic and international legal regimes and is exacerbated by economic globalisation, which enables transnational illicit financial flows associated with state capture. Case studies of South Africa under Jacob Zuma and the Eastern European Laundromat illustrate how financial institutions, corporate service providers, and public relations firms broker illicit influence. These professional enablers exploit legal asymmetries and regulatory gaps to launder wealth, obscure ownership, and legitimise corrupt regimes. The chapter reframes state capture as a political modality: a dynamic, transnational instrument of geopolitical competition that capitalises on an architecture of global finance and governance whose inadequate and inconsistent regulatory frameworks, notably FATF’s gatekeeper model, foster rampant non-compliance.
The term State Capture was popularised by a series of working papers from the World Bank and European Bank for Reconstruction and Development. The papers described patterns of systemic corruption intent on weakening post-Soviet states’ legal and regulatory frameworks. Private interests captured and colluded with public officials, extracting rents by manipulating state power. Rather than an epiphenomenon, systemic corruption has now become a design feature embedded in global capital markets. Elites instrumentalise the institutions of the state to capture large swaths of a country’s economy—a phenomenon known as political capitalism—the proceeds of which they then launder by way of transnational professional enablers, notably financial institutions. However, the manifestation of state capture transcends self-serving transnational corruption. Countries such as China and Russia launder a significant portion of corrupt proceeds transnationally to fund insidious forms of conflict against which the West has proven unable to defend itself: hybrid warfare and grey-zone tactics such as dis- and misinformation, foreign interference, subversion, subterfuge and sabotage, etc. This chapter draws attention to the professional enablers and architects of transnational corruption that are embedded in global capital markets, and deficiencies in regulation and governance. Transparency regimes that are supposedly a vector to minimise the reach of autocrats and kleptocrats into democratic society are not having their intended effect. Instead, they are actually being leveraged by democracy’s geopolitical adversaries as intermediaries of subversion.
Economic globalisation, especially embedded global capital markets, and the resulting growth and interdependence of transnational financial flows has had a multiplier effect on systemic corruption and state capture.1 Globalisation intensifies and enables the process of state capture by making large sums more mobile to move across jurisdictions. As a result, state capture and associated laundering has scaled up. The shift from regional to transnational illicit flows is made possible by the emergence of a class of transnational professional enablers within the illicit transnational political economy. Professional enablers obfuscate illicit flows by way of information operations that leverage financial intermediaries and global markets to facilitating systemic corruption under the guise of legitimate business dealings.
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This chapter analyses how globalisation has transformed state capture into a transnational phenomenon, with professional intermediaries operating as systemic brokers of illicit influence. Transnational refers to geographic spillovers of domestic corruption that are complemented by global networks of professionals outside the captured jurisdiction who are responsible for its construction, brokerage, and reproduction—primarily within finance. Economic globalisation, especially the embeddedness of global capital markets to which Saskia Sassen alerted us two decades ago, has radically altered the processes and mechanisms of corruption. This renders certain states, their institutions, and underlying structures, particularly susceptible to capture. Transnational professional enablers largely eschew legal and regulatory frameworks, which undermines the efficacy of efforts to contain state capture. Legal fragmentation and jurisdictional differences give rise to criminogenic asymmetry in the form of weak, under-resourced, and spotty regulation and enforcement whose vulnerabilities are subject to systematic exploitation at scale.
2 Background, Methods, and Data
Both economics/public administration (EPA) and scholarship on the Illicit International Political economy (IIPE) contribute to a better understanding of state capture.2 EPA has largely focused on issues of bureaucratic efficiency, regulatory quality, and administrative constraints that allow or inhibit corruption. However, this scholarship tends to overlook the structural components of state capture in favour of routine corruption practices (i.e., bribery, embezzlement). Conversely, IIPE has little specific research on state capture beyond policy-oriented research.3 Scholarship on IIPE and state capture tends not to account for mobility. It restricts analyses to territorial boundaries of the state. Such analyses interpret transnational phenomena through a state-centric lens.4 This is manifest in the prevalence of single-country case studies of state capture informed by EPA, whereas comparative studies remain rare.5 Nonetheless, IIPE provides a framework to understanding how capture is enabled, sustained, and amplified through globalisation. State captors do not act in isolation; they are embedded in a broader ecosystem of financial crime and exploit the pathways of this ecosystem.
This chapter makes three contributions to the state of knowledge. First, it identifies and discusses the various overlapping roles of the class of professional intermediaries who provide the necessary infrastructure for state captors to operate across jurisdictions. This chapter offers a proof-of-concept for a theoretically-driven comparative approach to state capture that draws on two case studies: the Eastern European Laundromat and the Zuma administration in South Africa. These cases are supplemented with intergovernmental reports—primarily from the Financial Action Task Force (FATF). In doing so, the chapter’s secondary contribution is to conceptualise the failures of legal and regulatory regimes through a global state capture. It aims to reconcile the literature’s conventional ontology of territory with a transnational epistemology of mobility. Its third contribution—while limited in scope—expands upon nascent research on state capture as a political modality. Capture is therefore not simply a static condition or legal aberration, but a dynamic and strategic mode of governance with significant geopolitical implications.
3 State Capture: An Overview
3.1 Conceptualising State Capture
State capture describes the illicit influence and control of core functions of society and the state—its legislation, administration, and oversight—by private actors. Captors are diverse, internal and external to the state. They include political parties, individuals, local or foreign elites, organised criminal groups, as well as multinational corporations or even entire economic sectors. These associates double as gatekeepers and deal makers operating outside the rules and oversight that constrain formal government roles: the justice system is captured by the leader’s loyalists; checks and balances are weakened or ignored; moral and ethical frameworks erode; oligarchs become richer and more powerful than institutions of the state. Such systematisation and intent set state capture apart from incompetent legislation or regulation. Other forms of grand corruption can be randomised and opportunistic. By contrast, state capture is directed towards core state institutions and functions to reorganise the nature of interactions in favour of its captors.6 Moreover, it is an intentional and collusive project of elite factions against the public sphere with the aim of conflating political or economic actors.7 This enmeshing of public and private interests creates power to control and distribute both political and economic resources within and outside captors’ factions.
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3.2 Mechanisms of Capturing the State
State capture is not a monolithic process, but an amalgam of interlocking sub-processes that target different pillars of governance. Three different logics inform state capture.8Statutory capture influences the texts and structure of legal regimes and regulatory requirements, most often via the exertion of influence over policymakers. Examples include captors’ undue influence over independent regulatory assessments or consultations, the modification or amendment of bills and parliamentary procedures, and the abuse of emergency procedures or filibusters. Administrative capture restructures the implementation of policy. The public service and its bureaucracy are subverted to misallocate state resources in budgeting and procurement, alongside practices of nepotism, cronyism, bribery, intimidation, and coercion.9 Lastly, capture of accountability ecosystems interferes in the function and independence of the judiciary, prosecutor offices, and other oversight mechanisms. These include arbitrary judicial proceedings, the delay of due process, and packing courts and oversight bodies to create a culture of impunity for captors, with the aim of legitimising their power and frustrating efforts to impede them.
Capture is not guaranteed. The experience of South Africa teaches us that failure to subvert and capture administrative institutions—not just the bureaucracy but also the judiciary—can precipitate the subsequent prosecution of captors. With sufficient autonomy, public legitimacy, and resources, legal institutions, and civil society can pursue successful, transparent inquiries into misconduct.10 Additionally, these three overarching categories subsume several distinct processes. The capture of accountability ecosystems includes forms of media capture, in which actors co-opt or control independent media and information capture, which involves monopolising and distorting alternative information channels. The purpose of such capture is to silence civil society and manipulate or undermine information channels such as bureaus of statistics or digital platforms.11 Similarly, these distinct subprocesses often span overarching categories. For example, capture of electoral systems operates at the administrative and legislative level. Captors may target and manipulate electoral reform along with administrative institutions and staffers to entrench incumbents and patronage politics.12
State capture, then, is a differentiated process driven by diverse mechanisms. Captors subvert pillars of governance to suppress the state, its core functions, and the provision of public goods for private and corrupt ends by way of a host of disaggregated mechanisms. Actual mechanisms of state capture are a function of the composition of elite coalitions, their interests, and their ambitions.
3.3 Containing State Capture
At both the domestic and international level, enforcement actions against state capture are a function of two strands of legislation: anti-money laundering and counter-terrorist financing (AML/CTF), and anti-corruption. These are supplemented by both multilateral and unilateral sanction regimes. Transnational legal regimes focus on norm diffusion via policy expertise and authority by way of intergovernmental institutions such as the Organisation for Economic Co-operation and Development (OECD), FATF or United Nations (UN). Domestic regimes internalise these global standards and norms, adapt them to their own circumstances, and develop domestic tools to buttress regimes. In an ideal world, domestic translations and the development of novel tools in turn inform and push forward international standards in a mutually-reinforcing regulatory system.
On the one hand, international bodies such as the FATF institutionalise normative regimes to constrain state capture through AML/CTF legislation and regulations. By way of the 40 Recommendations and the process of black- and grey-listing non-compliant jurisdictions, the FATF leverages transaction costs and access to the global banking system.13 By design, the FATF regime affords states ambit to implement and manage domestic AML/CTF frameworks. However, that ambit is limited to the FATF’s risk-based approach. By design, it leaves little leeway to implement the framework, or elements thereof. FATF’s framework for compliant AML/CTF legislation applies a “gatekeeper model” of privatised financial supervision by firms on their own clients.14 As a result, domestic legislation demonstrably convergences around key principles of AML/CFT and anti-corruption. Actual implementation and compliance, however, varies greatly, in both intent and effect.15
On the other hand, anti-corruption legislation is fragmented across international jurisdiction. The United States’ Foreign Corrupt Practices Act (FCPA) provided the original model for anti-corruption legislation that was subsequently emulated across jurisdictions including Canada, the UK, and Mexico.16 Implementation and application, however, are subject to political whims. Faced with superpower competition from geopolitical rivals, for instance, the Trump administration appears to believe that constraints imposed by the FCPA disadvantages the US in geopolitical competition. Passed in 1977 in the wake of the Watergate scandal, the FCPA criminalises corrupt offers, payments, or promises of to foreign officials by firms of US origin, or whose funds flow through US institutions. The legislation’s reach is extraterritorial insofar as it allows the US to levy broad sanctions, including on non-US entities. These laws are coupled with a host of individual pieces of legislation on civil forfeiture and asset recovery related to the proceeds of corruption or crime, such as the US global Magnitsky Act (2012) or the UK’s Proceeds of Crime Act (2002).17
In parallel, states supplement existing legislation with novel forms of domestic enforcement. These often manifest as subdepartments of existing government agencies, or sanctions packages. The strongest examples are the US’s inter-agency Anti-Kleptocracy initiatives which are embedded in authorities such as the Security and Exchange Commission (SEC) or Department of Justice (DoJ).18 More recently, the EU has sought to establish the EU anti-corruption network of experts and civil society, with the backing of its new Anti-Money Laundering Authority (EU AMLA).19 This decentralised supranational approach to monitor compliance and investigate corruption is largely untested as the legislation only entered into force in 2025.
In addition, states have pursued several regional and international conventions—most importantly the OECD Anti-Bribery Convention (1999) and United Nations Convention Against Corruption (2003)—to establish and promote common legal standards and mutual legal assistance across jurisdictions. Importantly, legislative reform of both AML/CTF and anti-corruption regulation tends to follow significant disruption to the existing equilibrium such as corruption scandals (e.g. 1MDB in Malaysia) and violent mass-casualty events (e.g. 9/11). That is, states tend to be reactive, rather than proactive, in managing both state capture and institutional corruption.
3.4 The Economic Globalisation of State Capture
Prior to the most recent wave of economic globalisation, state capture was largely confined within national borders with regional spillover effects on investment, migration, and political cooperation.20 Owing to economic globalisation, state capture now operates across jurisdictions and capitalises on criminogenic asymmetries of integrated financial markets. As a result, state captors and their impact have gone transnational.
Tailored professional services are modular, marketed and sold as part of broader services utilised by everyday corporations. The technical expertise that underpins modern finance, banking, and real estate facilitates access to the global economy. Mid-twentieth century authoritarian regimes—such as Franco or Stalin—relied primarily on domestic banking systems and state patronage networks, constrained by capital controls and centralised economies. Conversely, modern counterparts exploit transnational financial infrastructures and regulatory arbitrage to externalise influence and obscure accountability. In a study of 150 cases of grand corruption, 128 involved offshore corporate vehicles, with over half using anonymous shell companies to obscure ownership and launder illicit wealth.21 Ergo, Western entities are complicit in modern state capture. Hubs in Manhattan and London serve as critical financial chokepoints that allow captors to weaponise the same systems of interdependence that fuel the global economy.22
Economic globalisation of state capture in globally embedded capital markets has precipitated a qualitative shift: no longer solely an instrument of domestic regime consolidation, state capture is increasingly repurposed as an instrument of geostrategic transnational elite coordination and leverage. Capture is not merely an outcome but a political modality: a flexible mode of governance that encompasses a spectrum of behaviours from more subtle patron-clientelism to realigning institutions for corrupt ends. This modality is adaptive and scalar: often oriented inward to preserve power, outward it functions as a mechanism of geopolitical power projection. Authoritarian and hybrid regimes, particularly China and Russia, deploy capture to monitor and control diasporas, neutralise regime critics, malign influence, foreign interference, and entrench spheres of influence.
The PRC’s crackdown on capital outflows under the guise of “anti-corruption” precipitated a massive underground banking network: wealthy mainland Chinese citizens needed a vector to move wealth to the West—to fund their children’s education, to purchase real estate assets, etc. At the same time, drug cartels needed to pay for precursor chemicals manufactured in China (and, increasingly, now across South-East Asia). The result was a low-cost and real-time reconciliation of transactions by way of an Informal Value Transfer System (IVTS). Networks use a variety of tools to move value over borders: cash collector networks, grey market gaming, South-East Asia scam centres and so on. They are enabled by professional intermediaries, Financial Institutions (FIs), Corporate and Legal Service Providers (CLSPs), and Public Relations (PR) firms serve as corporate avatars for the world’s largest IVTS. To the extent that the PRC has weaponised laundering for state purposes, organisations such as the United Front Work Department (UFWD) can hide their transfers in the larger noise of that IVTS system. These professional intermediaries that launder funds by embedding them in global capital markets to render them legible as legitimate market or governance activity are the subject of the next section.
4 Professional Intermediaries
Professional intermediaries are network enablers of state capture, functioning as core nodes that connect financial edges. Previous research from IIPE has largely viewed such intermediaries as passive enablers or unwitting participants in state capture. This is echoed in the FATFs approach to enforcement, which privatises enforcement through a risk-based gatekeeping model. The FATF model presumes that professional actors are a positive force for change. Instead, this chapter posits the professions as active architects within a transnational ecosystem of corruption.
Professional actors are the brokers of global capital markets: they link edges of disparate domestic nodes into a network of transnational flows.23 Their positionality within the transnational legal-financial infrastructure, and within the FATF’s privatised approach to enforcement, endows them with networked power as brokers of information, market access, and regulatory evasion.24 Expertise and professional connections make them brokers within networks of corruption; they provide captors with the financial services and reputational resources.25 As transnational brokers, professional intermediaries provide legitimacy and global access, and make it possible to reproduce and scale state capture at the global level. The FATF identifies four sectors as gatekeepers of corruption: law, accounting, real estate, and trust and company service providers.26
This chapter’s functionalist approach conceptualises three professional groups that are responsible for the brokerage and intermediation of state capture: FIs, CLSPs, and PR firms. Research seldom addresses internal variation of these actors beyond their sectoral or professional boundaries. However, as our Venn Diagram illustrates (Fig. 1), there are no clearly discrete capabilities or roles. Rather, professional intermediaries share several core functions, whilst maintaining exclusive competency over key strategic areas owing to their professional communities and expertise. The result is a competitive market for the provision of corrupt financial services for state captors, which bear a striking resemblance to their existing corporate services, such as aggressive tax avoidance or corporate structuring.
Fig. 1
Venn diagram of overlapping services provided by professional intermediaries
CLSPs and FIs jointly afford access to the global market. They act as primary conduits and architects for money laundering, malicious compliance with due diligence and Know Your Customer (KYC) rules, and regulatory arbitrage. Their fee-for-service model (usually a percentage of the total amount involved, driven by a risk premium) structures transactions and firm ownership to minimise exposure to taxation and financial surveillance. That allows captors to subvert the institutions designed to monitor and prosecute corruption. CLSPs and PR firms also launder reputation and perform crisis management. Clean audits of mismanaged or highly irregular firms legitimise illicit transactions and offshore vehicles, while external assessments of SOEs insulate against independent government agencies. Strategic litigation and public relations campaigns offer additional layers of defence: they provide legal cover and launder the reputation of Politically Exposed Persons (PEPs).27
Collectively, each professional group shares four overlapping functions that facilitate state capture: (1) brokerage of networks, information, and deals between captors and the global financial system; (2) transnational legitimation of state captors and their behaviour; (3) provision of market access; and (4) evasion of financial surveillance and sanctions. However, how their discrete and shared actions generate a shared coherent transnational group is poorly understood. The sociology of professions could afford insights into the roles of professional cultures, institutional autonomy, and embeddedness to help identify variation and continuity in enablers’ behaviour and motivations.
Empirically, the growing centrality of professional intermediaries is evidenced by FCPA enforcement data, which reinforce the importance of financial intermediaries, brokers, and shell companies.28 Figure 2 illustrates the increased prosecution of such intermediaries, whilst Fig. 3 shows the distribution of chosen intermediaries and their preferred vehicles. The prominence of consultants/brokers and opaque shell companies suggests that both FIs and CLSPs feature prominently in state capture. FATF enforcement trends likewise indicate a marked increase in professional service providers’ involvement in illicit transactions, as well as their active role in constructing and marketing corrupt schemes to potential clients. A report by the FATF and the Egmont Group of Financial Intelligence Units (FIU) situates professional intermediaries on a “continuum” of responsibility: innocent, negligent, or complicit.”29 In their analysis of 150 cases, a third of all intermediaries were complicitly involved, having “designed the scheme themselves and promoted it to potential clients.”30 The complexity and sophistication of schemes disclosed in the LuxLeaks, Panama Papers, and Pandora Papers bolsters the shift of intermediaries from peripheral enablers to indispensable brokers.31
Fig. 2
FCPA enforcement data (1977–2025) by third-party intermediaries
The FATF observes how professional intermediaries exploit fragile legal regimes and regulatory asymmetries for profit.32 Professional intermediaries provide the instruments and services necessary to facilitate state capture by way of bespoke “packages” with few questions asked of clients.33 That raises questions about the appropriate balance to strike between individual freedoms in capitalist society and protection of the public interest. The FATF finds accounting professionals the most likely to be wilfully complicit, with legal professionals more likely to be unwitting or wilfully blind.
In sum, professional intermediaries and their industries support globalised “institutional corruption” within the state system.34 Their centrality within the finance system, coupled with expertise and professional networks, render them transnational service providers for a globally oriented cadre of autocrats and oligarchs. Far from an epiphenomenon, the ecosystem of transnational brokers is an emergent and central feature of state capture. Case in point are two detailed case studies of South Africa and Europe that follow: the Zuma regime and the Eastern European Laundromat.
4.1 Jacob Zuma’s Administration, South Africa, 2008–2018
Between 2008 and 2018, former South African President Jacob Zuma’s administration facilitated the capture of the South African state in collusion with private actors, multinational corporations, FIs, CLSPs, and PR firms.35 Networks embedded within the African National Congress, state-owned enterprises (SOEs), and private sector entities orchestrated the diversion of an estimated 3.7 billion USD from public coffers. The global financial crisis of 2008 galvanised corruption across BRICS countries insofar as financial intermediaries were nonetheless looking to capitalise on institutional failure. Large banks had taken on too much risk. Although governments bailed them out, institutions and individuals compensated for their losses by enabling corruption to bolster flagging profits.
Zuma and his associates—most notably the Gupta business dynasty—used complex beneficial ownership structures in the UAE, Hong Kong, the UK, and South Africa to launder and obscure the proceeds of procurement fraud. In 2014 transport firm Transnet procured 1064 locomotives where initial budgets were inflated by 1.116 billion USD, with 295 million USD diverted in kickbacks to Gupta intermediaries.36 At the power company Eskom, more than 650 million USD in contracts were awarded to Gupta firms in rigged tender processes over 3 years.37 Parallel schemes at South African Airways and the Passenger Rail Agency of South Africa (PRASA) saw billions lost to inflated leases, consultancy fees, and phantom projects.38 Simultaneously, Zuma manipulated appointments to critical patronage positions. His administration weakened oversight mechanisms, replacing at least 28 senior executives and board members across SOEs—including within the prosecution service, federal police, and tax authorities.39
The Gupta enterprise relied on FIs and their international networks to launder proceeds from corrupt contracts. Some schemes were simple: stolen funds were transferred directly into offshore accounts in the UAE or laundered through singular shell companies such as JJ Trading FZE and Century General Trading FZE to the UAE.40 More sophisticated international networks routed money through complex transaction networks using global banks such as HSBC’s Hong Kong branch. An internal HSBC investigation uncovered 92 companies that received payments from accounts held by Tequesta, Regiments Asia, and Morningstar.41 Accounts still active in late 2016 had received 50,339 payments worth 234 million USD. These 60 accounts made onward payments to 5576 further beneficiaries, of which 55 were also paid by Regiments Asia, Tequesta, and Morningstar. The total value of 211 million USD across 32,653 transactions is likely a fraction of the picture at HSBC alone.42
An additional 251 million USD was laundered between 2007 and 2017 across 20 Gupta-linked front companies that held accounts at the Indian Bank of Baroda.43 Baroda leveraged correspondence networks at South African Nedbank. Both shirked responsibility for reporting suspicious transaction by skirting KYC obligations.44 Baroda’s closure in 2017 precipitated the unravelling of the money laundering network. Notably, prominent South African Standard Bank and ABSA debanked Gupta-linked accounts through which they had processed over 95 million USD in suspicious transactions linked to Gupta-owned Sahara Computers between 2012 and 2016.45 FIs thus find themselves at the centre of state capture: providing market access, laundering proceeds, and engaging in broad corporate negligence.
KPMG earned 1.3 million USD from the Gupta-linked Sahara Group. They had served as the auditors for Gupta-linked companies from 2003 to 2018. KPMG issued clean external audits of Gupta firms and provided standard services, including corporate structuring and aggressive tax avoidance.46 In 2015 KPMG falsely accused SARS officials of operating an illegal investigative unit pursuing Zuma and his partners.47 Likewise, Bain & Co. SA partnered with the Zuma administration to advise on the restructuring of the South African economy and “Profound Strategy Refresh” at the SARS.48 Bain received 9.15 million USD in irregular contracts over 27 months. In short, consulting, law, and accounting firms legitimised corrupt procurement relationships and phantom transactions while weakening judicial enforcement mechanisms.
CLSPs such as the Gupta-affiliated Regiments Capital provided “financial advisory services” to state-owned entities, earning 62 million USD in excess profits from Transnet.49 PwC, Bain & Co., and Deloitte were found to have circumvented procurement rules and inflated prices to obtain contracts.50 Additionally, firms engaged in outright bribery and conspired to both uphold and bury corruption. Whilst consulting for both Eskom and Transnet, McKinsey & Company received 85 million USD for bribes paid as fees to Zuma-linked entities, acting on privileged information and violating procurement laws.51 Gupta-linked firms—including Trillian Management Consulting, Islandsite Investments, and Oakbay Investments—acted as shell companies that structured illicit transactions as typical commercial interactions.52 Whereas FIs move the money and ensure that flagged transactions are overlooked and AML/CTF protocols are not implemented, CLSPs are the architects of financial secrecy. Together, they provide modular financial services to launder billions in corrupt proceeds as active agents of state capture.
Firms also acted as public relations and lobbying agents, coordinating reputation laundering campaigns, strategic philanthropy, and crisis management efforts to deflect scrutiny and co-opt Western policymakers. Bain & Co. coordinated a media campaign to support their restructuring of the SARS, emphasising modernisation and improved efficiency, aiming to garner public support and mitigate criticism.53 UK-based Bell Pottinger orchestrated a propaganda campaign to deflect scrutiny from Zuma and the Guptas. The firm coordinated a national influence operation through social media bots, fake news sites, and manipulated hashtags to discredit state capture allegations as a racially-biased conspiracy.54 Moreover, transnational law firms such as Dentons and Hogan Lovells were hired to perform strategic litigation in an effort to discredit or silence critics and defend captors from credible allegations of corruption.55 Together PR firms and CLSPs provide legal cover for captors through attacks on legal institutions and disinformation campaigns. Akin to FIs, they actively uphold state capture, provide spin for dictators and legitimise corruption before the eyes of the law.
4.2 Post-Soviet Capture and the Eastern European Laundromat
Unlike South Africa, where state capture has been extensively documented through public inquiries and legal proceedings, post-Soviet capture is more opaque.56 The ‘Eastern European Laundromat’ was a sprawling network of interconnected money laundering schemes that enabled the systematic extraction of illicit wealth from post-Soviet states. At the heart of this operation was the Danske Bank scandal, which exposed the scale and sophistication of financial intermediaries in laundering proceeds of state capture.
Between 2007 and 2015, Danske Bank’s Estonian branch was at the centre of one of the largest money-laundering scandals in history57. An estimated 228 billion USD in suspicious transactions flowed through its non-resident accounts.58 They ignored clear signs in favour of profits—in 2011, Danske Bank Estonia branch generated 11% of its parent company’s total profits, and only held 0.5% of Danske Bank’s assets.59 Importantly, the Estonian branches’ IT division, including its AML compliance regulations, lay outside Danske Banks Group-level infrastructure.60 Non-resident clients—many of whom were linked to illicit financial networks in Russia, Azerbaijan, Moldova, and other post-Soviet states—represented a significant amount of the branches’ profit.61
Key figures tied to accounts include members of the Aliyev ruling family of Azerbaijan, Russian secret service, and associates of Vladimir Putin (through companies linked to his cousin and friends).62 In December 2022, Danske Bank pleaded guilty to fraud in the United States and agreed to a 2 billion USD fine.63 In early 2024, Danish courts jailed two culprits who had helped launder billions through the bank. Their main branch ignored internal warning signs and concerns of external auditors as early as 2011. Multiple executives resigned in the wake of the scandal, including CEO Thomas Borgen.64 Danske was not alone. Other Nordic and Baltic banks were caught in similar scandals or tied to Danske Banks and faced heavy fines. Deutsche Bank and SwedBank were found to have handled large volumes of suspicious payments, misrepresented customer relations, and falsified documents to regulators.65
Danske Bank’s demise is one instance of a wider array of laundering schemes that feed into the Western financial system. The ‘Russian Laundromat’ systematically siphoned between 20 and 80 billion USD through falsified debt in UK shell companies certified by bribed Moldovan judges.66 Deutsche Bank similarly faced sanctions for its role in the ‘mirror-trading’ scandal which funnelled 10 billion USD in similar methods to Danske Bank.67 Weak AML controls, wilful blindness, along with outright complicity allowed billions to flows through accounts in Estonia, Latvia, and other entry points into the EU. Regulators levied record fines against Nordea and Skandinaviska Enskilda Banken and forced Latvia’s ABLV Bank and Trasta Komercbanka to close.68 As in South Africa, FIs in these cases are conduits for corrupt proceeds and turned a blind eye to the source of their profitable financial services. While at times negligent, FIs can be active enablers: they deliberately overlook internal warnings and stifle intervention by regulators.
While banks moved the money, an ecosystem of CLSPs obscured the network of suspicious transactions and undermined regulatory authorities. The methods described above allow funds to be routed into offshore shell companies’ accounts at Danske as debt to be transferred out as ostensibly legitimate (re)payments. Corporate formation agencies such as ComForm established hundreds of these shell companies, often with the same false declarations of nominee directors and locations, with a preference for opaque vehicles such as English limited partnerships.69 In many cases, employees at Danske Bank either brokered relationships between CLSPs and criminals, or established shell companies themselves in exchange for “consulting fees.”70 These were often controlled by anonymous offshore companies incorporated in the UK, Cyprus, the British Virgin Islands (BVI), and Seychelles. In one example, approximately 2.85 billion USD was funnelled through Danske Bank’s Estonian branch for the ‘Azerbaijani Laundromat’ between 2012 and 2014.71 This operation involved four UK-registered shell companies—Metastar Invest, Hilux Services, Polux Management, and LCM Alliance—whose accounts were held at Danske Bank Estonia.
Accounting firms and auditors from Ernst & Young and KPMG in Denmark reportedly knew of red flags and compliance failures at the Estonian branch but did not report them to authorities, whilst deliberately watering down internal reports at the behest of executives. Denmark’s Business Authority later alleged that Ernst & Young had violated AML provisions and failed to report to FIUs when it discovered suspicious information in Danske’s books, though state prosecutors have since dropped charges.72 By setting up opaque corporate vehicles, issuing clean audit opinions, or simply looking turning a blind eye, CLSPs provided the necessary infrastructure for offshore secrecy.
Putin’s People laundered billions out of Russia, with the aim of subverting security, prosperity, and democracy.73 Similarly, Azerbaijan’s laundromat not only concealed illicit wealth but financed a vast lobbying apparatus in Washington and Europe. Funds wired through the Azerbaijani Laundromat, including payments from shell firms Metastar and Hilux, were funnelled into Renaissance Associates, which hired Bob Lawrence & Associates (BL&A) to conduct influence operations in Azeri interests, whitewash its human rights record for investment, and cultivate political allies.74 U.S. lobby disclosures show BL&A received nearly 4.5 million USD in fees from 2006 to 2016, with 1.5 million USD flowing from 2012 to 2015, which matches funds siphoned off by the Azeri Laundromat.75 Over a decade, the firm arranged visits for Azeri officials, testified in Congress, and enlisted former U.S. officials to lobby for Baku, including on strategic energy projects. Simultaneously, Azerbaijan engaged in caviar diplomacy in Europe, using laundromat funds to sway members of the Parliamentary Assembly of the Council of Europe (PACE), some of whom later faced corruption probes for accepting bribes in exchange for blocking human rights resolutions.76 This campaign influence, orchestrated through PR firms and lobbying intermediaries, demonstrates how laundered capital was converted into political capital to suppress criticism and advance state interests abroad.
5 Transnational Professional Intermediaries as Network Brokers
As shown in our case studies, professional intermediaries are a crucial component of contemporary state capture. Without them, mechanisms of corruption in Eastern Europe and South Africa would be impossible to maintain. However, they were also crucial in undermining regulatory and legal frameworks meant to detect such forms of corruption. They act as brokers within international financial networks in circumventing financial surveillance, rather than just as gatekeepers or enablers. In this way, FIs, CLSPs, and PR agencies are the architects and salespeople of institutional corruption, brokering, and legitimation of transnational networks. In the following section, we explore the consequences of these activities across three interrelated areas: compliance, accountability, and enforcement.
5.1 Professional Intermediaries and (Non)Compliance
Professional intermediaries show a brazen disregard for compliance and corporate good governance in the cases. With an obligation to act in the public good, they have an incentive to maximise utility. HSBCs Johannesburg branch had internally flagged transactions and accounts which were forwarded to executives. At Baroda, managers voided SARs on transactions including inter-company loans and government contracts with “no apparent legal or commercial purpose” to firms with “few employees.”77 After closing Gupta-linked accounts in 2016, Nedbank maintained its correspondent banking relationship with Baroda, allowing the laundering network to persist.78 Deutsche Bank held meetings as early as 2011 on the volume of suspicious transactions from Danske Bank. Evidently, the FATF’s privatised risk-based approach of compliance monitoring failed due to a powerful admixture of incentives in the global corporate industry.
Profits incentivised executives to overlook serious breaches in AML regulations. HSBCs London headquarters dismissed its Johannesburg branches internal warnings. By 2014, Danske Bank had received warnings from a European bank but declined to investigate on the grounds that “there were legitimate reasons for former Soviet businesses and individuals to use non-resident banks.”79 Ergoinvest had been flagged by Deutsche Bank’s automated AML protocols but similarly never investigated, which precipitated the ‘2023 Mirror-Trading Scandal’.80
Utility-maximising behaviour is magnified by quarterly pressures for positive financial outlooks. Firms know the sheer scale of the corporate industry makes them replaceable. In both Eskom and Danske Bank, accounting and consulting firms identified clear breaches of internal corporate governance and abuse of procurement systems but watered down criticisms and recommendations due to political and financial pressure.
Even following disastrous scandals, firms continuously fail to enforce corporate governance standards. HSBC Johannesburg received 530,000 USD fine in 2024 for failure to perform KYC and due diligence.81 Standard Bank similarly received 725,000 USD in fines in 2025.82 SwedBank received another 89 million USD fine for failures in internal controls and AML protocols in 2023.83 Ergo, institutional corruption is a product marketed and sold by a transnational industry of financial professionals that provides the modular architecture for state capture on a global level. While individual firms—such as Bell Pottinger, Danske Bank Estonia, or KPMG South Africa—may face closure or reduced investments, these industries offer illicit corporate services à la carte to autocrats while failing to enforce corporate governance standards.
Evidence of this thriving industry can be found in the continued prosperity of corporate formation agencies. A 2022 investigation found that just five UK-based formation agencies specialising in ex-Soviet clientele created thousands of shell companies registered to a mere handful of addresses in England and Wales. Some 28% of all English LPs formed in 2017 were set up by these five shops. Aforementioned ComForm has created at least 211 anonymous shells since 2014, almost 70% of which after the 2017 Scottish limited partnership reforms.84
5.2 Professional Accountability
States do not hold professional intermediaries to account. On the one hand, regulators use a soft touch, fearing damage to their financial sectors. On the other hand, state capture is characterised by uneven regulation and prosecution.
First, embedded capital markets are a source of economic vitality. They incentivise lax enforcement and soft intervention over harsh public punishment. Danish regulators approached Danske Bank quietly about ring-fenced IT systems and failures in their AML/CTF protocols. Repeated warnings and the threat of fines led to Danske winding down non-resident accounts, but only after it became clear that reputational risk and international pressure outweighed the benefits of regulatory forbearance.85 In the case of South Africa, captive regulatory systems stifled actual enforcement.
Second, the global gap between states’ compliance declarations and actual practices is substantial. Across 112 assessed jurisdictions, the FATF’s Recommendations 24 and 25 on beneficial ownership transparency average just 47% on technical compliance and 22% on effectiveness, with nearly half (44%) scoring zero on effectiveness under Immediate Outcome 5.86 Inherent conflicts-of-interest ensure that the FATFs existing privatised “gatekeeper model” fails due to perverse incentives at the firm and state-level. The World Bank observes that compliance officers know “any due diligence system can be beaten.”87 More stringent legislation is likely to be frustrated by “pressure groups or other lobbies” content to “prevent the passage of such legislation.”88 Additionally, there are 73 countries outside the FATF’s network who are at least somewhat non-compliant. Due diligence is thus easily circumvented, and enforcement gaps are the rule, rather than the exception.
Professional intermediaries are monitored as both FIs and designated non-financial business and professions (DNFBPs). While the average rate of compliance for so-called gatekeeper regulations is 74%, four countries (US, South Korea, China, Australia) are 5% or less.89 FIs generally have a clear understanding of the risks they face and have implemented more effective risk mitigation measures.90 In contrast, the non-financial sector, including DNFBs, generally have a poor understanding of risk, which they struggle to mitigate.
Legislation tends to be highly general and lacking in specificity regarding crimes of grand corruption. Laws focus primarily on AML/CTF compliance protocols. There are professional intermediaries not covered by these areas of legislation owing to legal fragmentation as well as gaps in compliance and effectiveness.91 For example, consultancies may be partially covered by regulation, but their diverse services and global reach allows them to operate in areas not fully addressed by DNFBP legislation. Another legal grey zone persists between public political lobbying and private diplomacy, which enables largely unregulated foreign influence as exemplified by BL&A’s ability to circumvent the United States’ Foreign Agents Registration Act (FARA) while advancing Azerbaijan’s interests. This is a challenge for regulators, as intermediaries form a coherent class of professionals who share roles and functions in capturing the state.
To an outsider, this lack of specificity might seem reasonable. State capture commonly involves bribery, kickbacks, and the laundering of illicit proceeds, which falls to prosecution services. New legislation and legal regimes are expensive to develop while externalising them globally poses a challenge. Ambiguity likewise allows for a degree of norm localisation in the implementation of AML/CTF legislation. The current approach reflects a classic problem in financial crime: regulators graft new or emergent threats onto existing legislation, rather than developing distinct purpose-built tools.
5.3 Enforcement: Weak and Politicised
Finally, enforcement is characterised by a high degree of unilateralism, especially on the part of the US. In recent years, executives have been held to account through criminal charges, such as McKinsey’s Vikas Sagar.92 However, the broad trend of enforcement data shows a preference for Deferred Prosecutions Agreements (DPAs) and plea bargains, as well as civil actions. DPAs (30.43%) and plea agreements (65.03%) make up a majority of actions from the US DoJ.93 Half of the enforcement actions of the SEC are consent agreements (48.17%) and DPAs (1.83%).94 These favour transnational firms: they can field legal armies with considerable financial resources; they can credibly threaten capital flight; and they generally enjoy special relationships with regulators.
With the advent of the second Trump Administration, the era of the FCPA and anti-kleptocracy initiatives may be coming to an end. As of February 2025, agency-based Anti-Kleptocracy initiatives have been dismantled, while the FCPA and FARA are being rescinded.95 This reflects a long-held Republican opinion that anti-corruption legislation “impedes foreign policy objectives” and harms the “economic competitiveness” of US firms, as corruption is a “routine business practice in other nations.”96 It likewise highlights the continued and deeply politicised role of anti-corruption enforcement: Western states seem to prosecute and sanction state capture when it is in their self-interest.
5.4 Implications
Reforms that address transparency, the uneven regulatory terrain, the ‘gatekeeper model’, and enforcement challenges can curtail state capture.
First, states and firms must commit to transparency. As an example, foreign lobbying must be both documented and highly regulated. Adherence to FATF guidelines—particularly beneficial ownership transparency—is essential. However, transparency is limited in its effectiveness if not paired with robust monitoring and enforcement. In the case of beneficial ownership, verification of registries and public access are crucial and often lacking.97
Second, legislators need to even the uneven terrain of regulation by expanding existing regulatory frameworks, such as reporting requirements, to include actors currently on the periphery, such as DNFBPs. Harmonisation needs to reduce gaps across FATF member states. Operations of professional intermediaries should be regulated and not subject to differential treatment. Additionally, AML/CTF legislation needs to be strengthened through targeted legal provisions that specifically address the ‘duty of care’ that professional intermediaries have, to the public good.
Third, states and the FATF secretariat should explore alternatives to the ‘gatekeeper model.’ The experiment of self-regulation in AML/CTF has seen transnational criminal activity proliferate, while placing extraordinary financial burdens on both states and minor or moderate corporate actors. One option is to establish a reward program for financial crime bounty hunters similar to that of hacking bounty programs.98 The aim is to eliminate perverse incentives that drive the logic of firms in a competitive market.
Finally, states must deter firms and their agents with criminal and financial sanctions. Principal executives and their agents should face criminal sanctions for breaches, including of the aforenoted professional duties of care. Tepid financial penalties and restrictions on professional misconduct are insufficient. Absent credible deterrence, firms will internalise corruption and financial penalties as a cost of doing business. The current shifting political climate makes enforcement all the more important. As the case of South Africa shows, developing states lack the resources and political clout necessary to investigate, prosecute, and sanction state capture on their own.99 The vacuum created by the Trump Administration can only be buffeted through international cooperation. By way of the newly fashioned AMLA and an eventual capital-markets union, both the UK and the EU can play a vital role in shaping anti-corruption enforcement to address regulatory arbitrage and enforcement gaps.
6 State Capture as Political Modality
A recent report by the Office of the Director of National Intelligence underscores a pivotal transformation in China’s governance under Xi Jinping: corruption is no longer merely a vehicle for private enrichment but has become a strategic tool of centralised statecraft.100 Prior to the Xi regime, kleptocracy largely centred on elite self-enrichment, facilitated through offshore networks and opaque jurisdictions designed to protect families and assets from political risk.101 Under Xi Jinping, corruption has been repurposed as a mechanism of centralised control and a vehicle for geopolitical ambition. Xi’s sweeping anti-corruption campaigns, despite targeting ideological impurity and high-level corruption, have left forms of systemic graft intact within upper party and military ranks. This signals a shift: from diffuse personal gain to centralised, regime-serving capture. China’s model may now mirror the post-Soviet configuration yet distinguishes itself through its global orientation and strategic deployment—corruption as a modality of international power projection.
China’s case reflects a shift in how corruption manifests: as a geostrategic instrumental rather than purely for private gain. In South Africa, under Jacob Zuma, the machinery of capture was driven by domestic rent extraction and political survival, enabled by global intermediaries who laundered wealth and reputations across jurisdictions. In contrast, post-Soviet elites institutionalised capture into the core of the state itself. They leverage transnational laundromats to channel billions into Western financial systems in service of elite patronage, lobbying, and geopolitical leverage. China may reflect an emergent synthesis of these trajectories: that is, an evolution from the South African to the post-Soviet model.
Together, these cases demonstrate that transnational state capture is no longer—or never was—an aberration or symptom of weak governance. It is an adaptive and intentional strategy; a form of strategic corruption that thrives in an increasingly interdependent, multipolar world. As liberal norms recede, and institutional corruption is reconfigured as a tool of foreign policy, states and elites are increasingly weaponising corruption to navigate and exploit geopolitical ambition.
At the heart of this evolution lies an ecosystem of professional enablers: financial institutions, legal and corporate service providers, public relations firms, and lobbyists. They design the infrastructure of capture, sustaining elite influence while maintaining a façade of compliance and legality. This ecosystem of enablers is not merely an epiphenomenon of state capture, but its very crux.
However, the global legal response remains ill-equipped. Globally, AML/CTF regimes have promoted compliance-based enforcement models, which outsource oversight to financial institutions without confronting the professional intermediaries at the centre of these networks. These systems tolerate illicit flows, provided they are substantiated by ‘compliant’ paperwork. Meanwhile, multilateral frameworks focus on individual actors rather than the networks that sustain and operationalise capture.
The selective and politicised nature of enforcement exacerbates this problem. Western states often deploy anti-corruption measures as instruments of foreign policy. They ignore illicit wealth in their own financial centres while selectively targeting inconvenient foreign actors.102 This uneven system of accountability allows professional enablers to operate with impunity. Nowhere is this clearer than in the United States’ recent retreat from its historical role as a global anti-corruption watchdog. The dismantling of agency-based Anti-Kleptocracy initiatives and the weakening of FCPA and FARA enforcement under the current administration reflects a strategic de-prioritisation of corruption as a normative concern. Consistent enforcement is giving way to geopolitical expediency, where corruption is punished not for what it is, but for who wields it. Whether recent shifts in US posture are a function of a sense by the Trump administration that these rules are hamstringing the US in an era of geopolitical rivalry, or whether Trump’s entourage intends to capture US institutions for private financial gain, or both, remains to be seen. Ambiguity on this matter illustrates the extent to which is this not just a technical or legal topic, but a political and architectural challenge. The shift to transnational state capture means having to confront not just illicit transactions or corrupt individuals, but global systems that enable and legitimise them. Without addressing this embedded infrastructure of complicity, anti-corruption efforts will remain performative and embolden state capture as a potent tool of geopolitical subversion.
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Nicholas Donaldson
is a Junior Lecturer at Leiden University’s Institute for Security and Global Affairs and a graduate researcher with Queen’s University’s Institute of Intergovernmental Relations, where he leads a project on transnational state capture. He is also a Junior Research Fellow at The Hague Journal of Diplomacy and previously worked at ISGA on ERC-funded projects related to counter-terrorism , global economic governance, and quantitative foreign policy analysis.
Christian Leuprecht
is an award-winning professor at the Royal Military College of Canada, director of the Institute of Intergovernmental Relations at Queen’s University, Editor-in-Chief of the Canadian Military Journal and Adjunct Research Professor at the Australian Graduate School of Policing and Security. He is the recipient of RMC’s Cowan Prize for Excellent in Research and an elected member of the College of New Scholars of the Royal Society of Canada.
For this area of research, please see the World Bank publications on state capture, most prominently Hellman et al. (2000a, b); de Willebois et al. (2011) as well as recent research by Kaufmann (2024) and Dávid-Barrett (2023).
FATF (2024), pp. 11–16. FATFs definition is wide ranging, including casinos, lawyers, notaries and other independent legal practitioners and accountants, trust and company service providers, real estate agents, dealers in precious metals and dealers in precious stones.
This concept is explored further in the chapter “Corrupt Elites and Godfathers in Nigeria: Structural Impunity and the Undermining of Accountability” by Harvey and van Duyne (2025) in this book.
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