Anti-corruption survey underlines ongoing challenges facing legal profession

Ruth GreenTuesday 3 June 2025

Corruption remains a significant challenge for the legal sector, but a recent report indicates there’s growing awareness across the profession of both the risks it poses and the safeguarding tools available. In-House Perspective takes stock of the report’s findings.

The report was based on a survey of the legal profession conducted by the IBA Anti-Corruption Committee and the IBA Legal Policy & Research Unit (LPRU) in 2024 and published in March 2025 (the ‘2024 Report’). Entitled The impact of corruption on the legal profession: an updated global picture, it found that almost half of respondents observed an increase in levels of corruption over the last decade.

These findings follow a previous survey conducted in 2010. In the 2024 Report, 78 per cent of respondents said they were aware of the extraterritorial impact of anti-corruption and anti-money laundering laws outside of their home jurisdiction. This demonstrates a marked increase in the understanding possessed by lawyers of international anti-corruption laws and instruments over the past decade.

Nicola Bonucci, a Member of the IBA Anti-Corruption Committee Advisory Board, attributes this progress to several factors. He highlights the presence of state-of-the-art anti-corruption legislation in a number of countries, and a greater awareness within Bars.

He also says that the expectations of clients are important here – a point particularly relevant to the in-house sector and one that’s borne out in the survey data, says Bonucci, who’s a former Director of Legal Affairs at the Organisation for Economic Cooperation and Development (OECD). While respondents to the 2010 survey said that less than 25 per cent of clients needed them to demonstrate anti-corruption compliance, more than half of all of those who took part in the 2024 survey reported having been required by a client to certify compliance with anti-corruption laws and produce their organisation’s policy in this area.

Over three-quarters of the 2024 survey’s respondents, who span private practice, in-house and government legal departments globally, also indicated that their firm or organisation has a clear and specific anti-corruption policy.

The survey showed that aviation, public law, human rights, criminal and white collar/compliance presented the greatest corruption risk profiles. Nine in ten respondents from Africa and six in ten from Latin America said that corruption remains common or very common in their jurisdiction. While at least two-thirds of respondents globally said they had received anti-corruption training, specific instruction on beneficial ownership was distinctly lacking in all regions apart from Europe.

Sara Carnegie, Director of the LPRU, says that overall, these findings are encouraging and highlight the ongoing need for greater collaboration across the sector to tackle corruption. ‘In the current political environment and what’s happening in the US with their pause on FCPA [Foreign Corrupt Practices Act] enforcement, we’re not going to be seeing a robust enforcement playing field – quite the opposite,’ says Carnegie. ‘Structures are weakening. That will only diminish confidence in the system and in the countries which are already struggling in terms of their anti-corruption efforts.’

It’s important for the legal profession – both private practice and in-house counsel – to be leading by example, says Jenifer Swallow, former CEO of LawtechUK. ‘We as a profession need to be up to speed and we’re no longer going to be able to hide in the corner,’ she says.

Swallow says that, often, the nebulous concept of corruption can be quite ‘distancing’ for lawyers and there’s a tendency to minimise or even ignore low-level corruption. Swallow explains that when we think about scandals such as Enron, ‘these are absolutely devastating examples and there’s a huge scale. But we also need to look at the micro moments that happen in the day to day. Big scandals start with small things. If you don’t call misconduct and ethics issues out early, then they can creep and become normalised and you end up with a bigger problem’.

Both Swallow and Bonucci agree that compliance systems and procedures vary wildly depending on an organisation’s size and governance structure. However, this also presents external counsel with opportunities to engage with in-house legal teams on anti-corruption issues.

“The symbiosis between in-house counsel and external counsel and how that works is stuck in a historic paradigm


Jenifer Swallow
Former CEO, LawtechUK

‘The symbiosis between in-house counsel and external counsel and how that works is stuck in a historic paradigm,’ says Swallow. ‘Private practice lawyers need to build out their own governance infrastructure for independence and then, when they’ve done their homework, they can support and help in-house counsel with theirs.’

Bonucci cautions that external counsel’s approach – particularly for small and medium-sized enterprises (SMEs) – should be adapted to meet each specific organisation’s needs. ‘External lawyers can bring their experience in terms of compliance and policy setting,’ he says. ‘However, each assistance should be tailor-made: you cannot expect an SME to have the same compliance system as a large multinational, similarly even for two companies of the same size you will not develop the same anti-corruption policy if the business models of these two companies are radically different. The external lawyer needs to recognise this and provide assistance tailored to the needs of the company.’

In 2013, the IBA, the OECD and the UN Office on Drugs and Crime also undertook a global survey of in-house lawyers aimed at better understanding how businesses were managing the corruption risks posed by engaging external legal counsel.

George Artley, the LPRU’s Legal Manager, says there could be merit in undertaking a follow-up survey to examine the specific corruption risks and challenges facing the in-house profession today. ‘One of the plans is to focus on those sections of the profession that the report identifies as particularly at risk and look at what could be done,’ he says, ‘so certainly it could be worth repeating.’