Combating Corruption in the - Specialized Research AI at MIT

Combating Corruption in the
Twenty-First Century: New Approaches

Paul M. Heywood

Abstract: Despite the focus placed on combating corruption over the last quarter-century, practical results
have been disappointing. A small number of “success” stories cannot mask the fact that corruption con-
tinues to blight the lives of millions of citizens. This essay argues that part of the reason for the broad fail-
ure of anticorruption policies is that we have not specified clearly enough what we are seeking to address,
and have paid insufficient attention to changes in how and where different forms of corruption operate in
practice. Rather than sticking to unrealistic aspirations to “defeat” corruption, this essay argues that we
should pay more attention to the positive promotion of integrity, supported by a better understanding of the
drivers of individual behavior, particularly how these are more complex than suggested by the incentives-
based literature. The final section of the essay outlines some practical measures we can take, underlining
the need to focus reform efforts at both supra- and subnational levels in order to help move beyond what
has become a sterile conversation about corruption.

paul m. heywood is the Sir
Francis Hill Professor of Europe-
an Politics in the School of Pol-
itics and International Relations
at the University of Nottingham.
He is the author of Values and Po-
litical Change in Postcommunist Europe
(with William L. Miller and Ste-
phen White, 1998) and editor of
Political Corruption (1997), the Rout-
ledge Handbook of Political Corruption
(2015), and Debates of Corruption and
Integrity (with Peter Hardi and Da-
vide Torsello, 2015). He is a Trustee
of Transparency International-UK.

Why do we still need to ask how to combat corrup-

tion? After all, there has been no shortage of attention
devoted to this issue over the last twenty-five years:
academic researchers, policy-makers, international fi-
nancial organizations, dedicated anticorruption agen-
cies, civil society organizations, investigative journal-
ists, prosecuting authorities, advocacy groups and coa-
litions, and individual champions have all engaged in
the fight against corruption. And they have produced
no shortage of strategies and approaches to win that
fight: the World Bank has recommended “six strate-
gies to fight corruption,” designed to complement a
prior “two-pronged strategy,” in addition to “10 ways
to fight corruption”; Transparency International iden-
tified “5 key ingredients” to stop corruption; while the
World Economic Forum has published “5 ways to beat
global corruption,” as well as “3 key steps to end cor-
ruption.”1 The answers seem to keep coming, but the
problem remains stubbornly resistant to resolution.

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Indeed, we could argue that anticorrup-
tion efforts represent a huge policy fail-
ure: there seems little evidence that we
are much closer to resolving the issue in
2018 than we were in 1996 when James D.
Wolfensohn, then president of the World
Bank, announced that “we need to deal
with the cancer of corruption.”2 More-
over, there has been a growing chorus of
calls for a fundamental reassessment of
how we should understand and combat
corruption, often framed in terms of the
need to “rethink” existing approaches.3

All this rethinking inevitably begs the
question of what the anticorruption move-
ment and its efforts have achieved so far.
One somewhat cynical answer is that an-
ticorruption has highlighted a broad con-
sensus that we need to understand better
what corruption is, why it occurs, and what
we can do to stop it: a sort of intellectu-
al Groundhog Day that keeps bringing us
back to the same fundamental questions.
As Transparency International’s Dieter
Zinnbauer has observed,

The problem with most of the corruption lit-
erature is that plausible drivers of change in
corruption are too narrowly tied to changes
in corruption, integrity and governance. Or
they introduce broader forces of change in
very conceptual, correlational fashion (e.g.
internet penetration) without the ability or
objective to unpack these black boxes and
unearth actual transmission mechanisms.4

In other words, we keep engaging in the
same kind of circular logic that suggests
the best way to reduce corruption is to de-
velop institutional configurations and so-
cioeconomic settings in which public of-
ficials act with integrity so that corruption
does not prosper.

In seeking to move forward the discus-
sion on corruption and anticorruption, this
essay identifies three things we should fo-
cus more attention on and three things
we should stop doing. It then offers some

practical steps that may address some of
the shortcomings of current approaches.
Given the scale and complexity of the is-
sues under consideration, the essay offers
provocations, rather than fully formulat-
ed solutions, in the hope that they may not
only contribute to the growing calls to “re-
think” corruption, but also help reframe
the terms of the conversation.

Integrity is often posited as the opposite

of corruption, reflected in the widespread
use of the term in anticorruption circles:
from ngos such as Global Integrity and In-
tegrity Action through Transparency Inter-
national’s National Integrity System (nis)
assessments and the Organisation for Eco-
nomic Co-operation and Development’s
(oecd) Public Sector Integrity Reviews
and Integrity Weeks/Forums, to instru-
ments such as the recently launched In-
dex of Public Integrity. In practice, though,
much of the attention devoted to integri-
ty has been implicit: rather than exploring
in depth what should be understood by in-
tegrity in public life, and how to achieve it,
researchers, activists, and policy-makers
have often seemed to assume that integri-
ty will result simply from the elimination
of corruption.

Predominant anticorruption approach-
es respond to a logic that does not sit easi-
ly with the promotion of integrity. The rea-
son is that policies designed to combat cor-
ruption are usually developed as a reaction
or response to specific scandals, or else are
designed to prevent particular forms of be-
havior. They are driven by an attempt to
address the visible expression of corrup-
tion, focusing primarily on institutional
configurations or regulatory frameworks,
rather than the promotion of prointegrity
values among public officials. This means
that the practical expression of integrity in
anticorruption contexts often reflects this
institutional and regulatory focus: for ex-
ample, Transparency International’s nis

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Dædalus, the Journal of the American Academy of Arts & SciencesCombating Corruption in the Twenty-First Century: New Approaches

approach focuses quite narrowly on for-
mal law enforcement as exercised through
core institutions (so-called pillars) and cor-
ruption-combating agencies. Similarly, the
Index of Public Integrity has a strongly in-
stitutional tenor, consisting of six compo-
nents (judicial independence, administra-
tive burden, trade openness, budget trans-
parency, e-citizenship, and freedom of the
press) that contribute to the “control of cor-
ruption.” The oecd CleanGovBiz Integrity
in Practice “toolkit” similarly emphasizes
rules and regulation, even when discussing
prevention. More promising is the oecd’s
recent Recommendation on Public Integ-
rity that includes a section on cultivating a
culture of integrity–perhaps the single key
factor at all organizational levels in building
defenses against corrupt activity–but again
major emphasis is placed on control, over-
sight, and enforcement measures.5

Yet ensuring that public officials do
not behave corruptly offers no guaran-
tee that they will instead act with integri-
ty. It is quite possible to act noncorruptly
but also without integrity; for instance, by
performing a task with little effort, habit-
ually turning up late to work, or refusing
to cover for colleagues. While the absence
of corruption does not imply the presence
of integrity, it is not so obvious that the re-
verse holds: if public officials are acting
with integrity, they generally cannot–by
most common definitions of the term–be
acting corruptly. We therefore need a bet-
ter conceptual understanding of integrity
in public life and its relationship to corrup-
tion in order to build an effective model of
integrity management: that is, the formal
framework that ensures that public offi-
cials engage in ethical behavior, acting with
honesty and fairness while complying with
prevailing legal norms.

But the promotion of integrity faces seri-
ous challenges, among them the difficulty
of defining just what exactly we do mean by
the term, compounded by its overlap not

only with anticorruption, but also with
ethics, morality, and good governance.
The oecd refers to public integrity as “the
consistent alignment of, and adherence to,
shared ethical values, principles and norms
for upholding and prioritising the public
interest over private interests in the pub-
lic sector.” However, just as with generic
definitions of corruption, such a conceptu-
alization begs a host of questions, not least
about the relationship between personal
integrity and role-based integrity–as well
as between integrity at the individual or at
the institutional level–and also the rela-
tionship between public and private sec-
tors. Thus, integrity entails complex rela-
tionships with other dimensions and can
be analyzed from various perspectives.

Drawing on moral and political philoso-
phy, we can identify the core characteristics
of personal integrity as: wholeness (think-
ing beyond just the personal); action that is
consistent with principles (doing the right
things); morality (doing things for the right
reasons); and process (doing things in the
right way). Some would add the coda “even
when no one is watching” (attributed, ap-
parently in error, to C. S. Lewis) to indicate
that genuine integrity does not require any
oversight, though such a prospect is whol-
ly unrealistic in real life. Political integrity,
meanwhile, encompasses normative jus-
tice, openness and transparency, citizen en-
gagement, and impartial authorities.6

An effective integrity-management frame-
work, at whatever administrative level, re-
quires mechanisms that reinforce interac-
tion between the personal and political di-
mensions. However, with few exceptions
(such as the work of governance scholar
Leo Huberts and associates at the Vrije
Universiteit Amsterdam or the emerging
oecd agenda) integrity per se is very of-
ten effectively little more than a slogan, or
else is subsumed without detailed analysis
within a broader emphasis on “good gov-
ernment/governance.”7

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147 (3) Summer 2018Paul M. Heywood

In contrast, Bo Rothstein and political
scientist Aiysha Varraich have argued that
quality of government understood as im-
partiality should be seen as the opposite of
corruption.8 However, impartiality (“when
implementing laws and policies, govern-
ment officials shall not take anything into
consideration about the citizen/case that
is not beforehand stipulated in the policy
or the law”) has little to say about how to
address genuine ethical dilemmas or chal-
lenges that, for some, represent the only
true test of whether individuals act with in-
tegrity.9 To take a recent example from the
United Kingdom, a woman who had spent
twenty-seven years married to a British cit-
izen and whose children and grandchildren
were born in the country was deported to
Singapore after breaching regulations in
relation to periods spent out of the coun-
try. In a YouGov survey of more than 6,700
UK citizens, 63 percent of respondents felt
that the decision was wrong, with just 17
percent believing that deportation was the
right decision (even among ukip voters, 50
percent said she should have been allowed
to stay).10 Although the case had seen the
UK’s policy on residency rights impar-
tially applied, it raises difficult questions
about interpretation of the “letter” ver-
sus the “spirit” of a law.11 Indeed, “com-
mon sense justice,” in psychologist Nor-
man Finkel’s sense of reflecting what ordi-
nary people think is just and fair, suggests
that in a case such as this, the exercise of
impartiality is problematic.12 While this is
just one example, there are countless situ-
ations in which specific circumstances or
complexities are not prestipulated in a pol-
icy or law, leaving public officials having to
rely on their individual discretion or inter-
pretation rather than the impartial appli-
cation of rules. In such cases, integrity–
rather than impartiality–is the key virtue.
The second thing we should start doing
is pay greater attention to the drivers of in-
dividual behavior, in relation to both cor-

ruption and integrity. Although behavior-
al economists have increasingly focused in
recent years on experiments that seek to ex-
plain corruption, there is still a very widely
held assumption among many researchers
that, in the words of economists Benjamin
Olken and Rohine Pande, “corrupt behav-
ior can be modeled in line with a few gen-
eral economic principles: corrupt officials
respond to monitoring and punishments
as one would expect from basic incentive
theory.”13 Yet in practice, and as behavior-
al economics suggests, people rarely act as
rational cost-benefit optimizers, and their
decisions and motivations are subject to a
wide variety of biases and influences that
are not always coherent or consistent.

Indeed, some psychologists have suggest-
ed that fraudulent behavior is often driv-
en not so much by financial incentives as
by more complex sets of relationships, in-
cluding a desire to help or hurt others even
when there is no material gain for the indi-
viduals involved.14 “Bounded ethicality” af-
fects how we make ethical judgments: that
is, the way that decisions and choices are
framed influences our very capacity to see
the bigger picture. Experimental evidence
suggests that when people assess business
decisions, they use different standards and
measures than when they consider ethical
choices: the former cognitive frame stress-
es achievement and success as the key deci-
sion drivers, making people subconsciously
more likely to consider cheating in pursuit
of goals. In short, we routinely overestimate
our ability to do what is right, and underes-
timate the extent to which we may behave
unethically without meaning to.15 One re-
cent study–based on four behavioral ex-
periments using a newly developed corrup-
tion game–suggests that, contrary to the
idea of a slippery slope through which cor-
rupt acts start small and build up over time,
some people may find it easier to rational-
ize leaping off a cliff when a too-good-to-
pass-up “golden opportunity” arises than

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Dædalus, the Journal of the American Academy of Arts & SciencesCombating Corruption in the Twenty-First Century: New Approaches

to bear the moral cost of repeated unethi-
cal behavior.16

In general, though, there is a striking lack
of detailed work on the individual motiva-
tions that underpin corrupt behavior. In
contrast to studies of deviance and crimi-
nal behavior, social psychologists have with
few exceptions devoted little attention to
corruption. And yet corruption is manifest-
ed in concrete acts that take place in con-
crete settings, usually (if not always) involv-
ing purposive interaction between at least
two individuals. If we are to understand
better why people decide to engage in cor-
rupt activity, we urgently need to move be-
yond the reductionist and simplistic idea
that it can all be explained by incentives,
and that by changing or tweaking those in-
centives we can address the issue. Linked to
this point, we should focus more attention
on the role of unwritten and informal social
norms as a driving factor behind patterns of
corrupt behavior; as highlighted in a recent
Chatham House report on collective action
and the social norms underpinning corrup-
tion in Nigeria: “identifying the specific so-
cial drivers of specific collective practices is
critical to designing targeted and effective
policy interventions to change those prac-
tices.”17

The third thing we should start doing is
accept that we can never “win” the battle
against corruption in the sense of defeating
or eradicating it, and we should therefore
set more realistic aspirations for anticorrup-
tion interventions. While there have been
some widely cited contemporary “success-
es” (for instance, Singapore and Hong Kong
in Asia, Botswana and Rwanda in Africa, Es-
tonia and Georgia in Eastern Europe), such
cases represent a strikingly small number in
both absolute and proportional terms, and
the evidence suggests things may be getting
worse elsewhere. As Syed Hussein Alatas
long ago observed, corruption “inheres
in all social systems. . . . It affects all classes
of society; all state organizations, monar-

chies and republics; all situations, in war
and peace; all age groups; both sexes; and
all times, ancient, medieval and modern.”18
That will remain true, and so the best we
are likely to achieve is to “manage” corrup-
tion, or to constrain it within more accept-
able limits. In particular, we should identi-
fy the most egregious and damaging forms
of corruption, the ones that cause most so-
cial harm at greatest cost, and focus partic-
ular attention on measures to combat them.
That inevitably means making hard choic-
es about what we should not expend much
energy on, rather than sticking to the man-
tra of “zero tolerance” toward any and all
forms of corruption in the pursuit of chi-
merical aspirations.19

We should also focus more attention
on the feasibility of any reform measures.
As economist Mushtaq Khan has argued,
conventional anticorruption strategies
have sought to improve rule-following
across the board, alongside changes to
the cost-benefit calculations of public of-
ficials, but have generally failed because
they pay insufficient attention to the in-
terdependencies and variables that deter-
mine what is possible as opposed to what is
desirable.20 To be feasible, reforms need to
be appropriate to and consistent with the
political settlement in question, instead of
seeking, for instance, to introduce formal
regulatory changes to legal frameworks in
situations in which entrenched elites ben-
efit from their control of informal power
networks. There is a tendency in much anti-
corruption programming to equate law
with stable government, rather than fo-
cusing on the critical question of how to
establish the rule of law in those environ-
ments where it is lacking.21 In line with the
social drivers of specific practices, without
a better understanding of how the interac-
tion between institutions, beliefs, and be-
haviors results in a given legal order, it will
be difficult to implement successful anti-
corruption interventions.

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147 (3) Summer 2018Paul M. Heywood

From a focus on feasibility, it follows
that we also need to pay more attention to
variability both in form and outcomes of
political settlements, even if we allow for
the individualistic version of modernity
that underpins the anticorruption vision
of “ethical universalism” associated with
open-access societies. In practice, even the
most well-ordered Western states fall short
on some aspects of the ideal type of cor-
ruption-free governance, and–more im-
portant–they manifest a range of different
modalities to achieve similar ends (rang-
ing from constitutional forms of govern-
ment to territorial organization, electoral
terms and systems, accountability frame-
works, and so forth). As development
scholar Merilee Grindle has persuasive-
ly argued, we should be suspicious of the
normative connotations associated with
“good” governance and its ever-growing
list of requirements, and focus instead on
the practical organization of actual gov-
ernance tasks.22 That means accepting
messiness and ambiguity, reflecting the
complexity of modern political organiza-
tion, as well as the need to understand bet-
ter the interplay between microlevel inter-
ventions and macrolevel drivers of histori-
cal development.

In order to strengthen our assault on cor-

ruption, there are three things we should
stop doing, each representing a logical ex-
tension of the discussion to this point. First,
we should stop talking about corruption as
if its meaning were self-evident. For a vari-
ety of reasons, the way the term has come
to be used by academics and practitioners,
as well as by journalists and political com-
mentators, acts as an obstacle to moving
the anticorruption agenda forward.23 A
main drawback to discussing “corruption,”
without any adjectives, is that we cannot
reach any kind of consensus, other than
at an abstract or generic level, over what
it comprises. To be sure, there is increas-

ing reference to some variation on the now
well-worn formulation that corruption is
the “abuse of public office for private gain”;
but this definition suffers from two prin-
cipal problems. First, since what should
count as “abuse” is not itself defined, the
definition effectively begs the question:
what constitutes the alleged transgression
of what norm, and who decides? Second,
even if we could agree on what we mean by
abuse, the definition still encompasses such
a vast array of different kinds of activity by
different actors in different settings that it
is not helpful in any operational or policy-
informing sense.

Definitions in other fields often provide
what might be termed “core” or “umbrel-
la” terms, which are then taxonomically
subdivided. For instance, both condors
and wrens are birds, but ornithologists
have no difficulty distinguishing between
them. Alternatively, to use the analogy
most frequently applied to corruption,
cancer always describes abnormal and un-
controlled cell growth, but encompasses
over a hundred different diseases.24 When
it comes to corruption, though, we seem
somehow stuck at the generic level: much
of both the research and the associated an-
ticorruption strategies developed over the
last twenty-five years have signally failed
to engage in the critical differentiation
of pathological characteristics that dis-
tinguish some forms of corruption from
others. If corruption is a form of cancer
(or some other disease), then corruption
oncologists need a more sophisticated un-
derstanding of its dna if they are to de-
velop effective responses; but discussions
of corruption and how to combat it often
proceed as if such efforts are a tiresome or
annoying distraction. It is as if many who
seek to combat corruption set out from the
proposition that we sort of know what we
mean, so let’s not get too hung up on the
definitional niceties; in the words of one
scholar:

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Dædalus, the Journal of the American Academy of Arts & SciencesCombating Corruption in the Twenty-First Century: New Approaches

We all basically know what we’re talking
about–primarily bribery and embezzlement,
[as well as] some other bad conduct relating
to conflict of interest. . . . Why not just accept
that when most of us use the term “corrup-
tion,” we’re talking about that cluster of stuff,
and charge ahead with our research?25

While many scholars and anticorruption
practitioners do indeed mean “that cluster
of stuff” when talking of corruption, others
see the term as encompassing different or
additional dimensions (for instance, legal
uses of power that nonetheless betray the
“democratic transcript” by violating the
rationale and spirit of public rules).26 Ul-
timately, the likely impossibility of estab-
lishing an uncontested, yet rigorous, defi-
nition means that corruption, unless we
specify what precisely we understand by it,
ceases to have any clear referent in research
or practical policy terms. However, in real-
ity, we rarely see such specification;27 in-
stead, at best, there has been a tendency to
develop dichotomous distinctions (grand/
petty, political/administrative, systemic/
sporadic, individual/institutional, extor-
tive/transactive, need/greed). Not only
are modalities of corruption more complex
and flexible than suggested by such bina-
ry schema, but there tends to be a separa-
tion between, on the one hand, work that
seeks to identify “types” of corruption and,
on the other, policy-oriented approaches to
combat corruption writ large.

But perhaps just as significant, this lack
of clarity means that the term can easily
be pressed into political use as a descrip-
tor of whatever is unpopular. We begin to
see corruption everywhere and in every-
thing, the root cause of any form of failure
in any political setting: popular protests
against the alleged corruption of political
leaders have become common through-
out the world, regardless of regime type.
In turn, mutual accusations of corruption
have become the stock-in-trade of polit-

ical contestation, as was starkly evident
in the 2016 U.S. elections, and as has long
been the case in post-Communist regimes
and elsewhere. As a result, the term has be-
come ever more devalued even as it is ever
more widely used, ultimately serving as lit-
tle more than a boo word.

Our failure to specify what exactly we un-
derstand by corruption is reflected in a ten-
dency to amalgamate all forms of corrup-
tion into a value that can then be measured
within a jurisdiction. This brings us to the
second practice to stop: the near exclusive
focus on nation-states as our unit of analy-
sis; and with it, the increasing production
of rank indices measuring the amount of
corruption in any one state compared with
another. There is now a very extensive lit-
erature on the problems of measuring cor-
ruption, but relatively little of it questions
the utility or relevance of focusing on na-
tion-states. While there are a few measures
that look at the subnational level, notably
from the Quality of Government Institute
at the University of Gothenburg, the vast
majority of approaches both to measure-
ment and remedies are pitched at the level
of individual countries. In the words of po-
litical scientists Alexander Cooley and Ja-
son Sharman:

As much as social scientists may hold the
sanguine view that “everybody knows” that
corruption is a cross-border problem, the
methodologies commonly adopted system-
atically suggest the opposite conclusion, i.e.,
that corruption is a bordered, bounded char-
acteristic of individual states.28

In many ways, such a focus on nation-
states is entirely understandable. States
are so well established as units of politi-
cal analysis, given their dual claim to sov-
ereignty and legitimate authority, that it
is natural to focus on individual state cor-
ruption and state efforts to combat it, just
as we look at and compare a host of oth-
er governance indicators at the state lev-

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el. However, there are clear problems with
such an approach. To begin, it rarely works
in practice, since most national-level mea-
sures of corruption provide only a single
aggregate indicator. Moreover, it can still
mask potentially significant variation with-
in countries; as political scientist Staffan
Andersson has observed, “actual instanc-
es of corruption may vary spatially–both
subnationally and across government lev-
els and sectors–a factor not detected by
studies relying on single-country scores.”29
The obvious case is Italy, with its stark dif-
ferences between North and South, though
these variations are also evident both in
very large jurisdictions like Russia and In-
dia and in small countries like Sweden and
the United Kingdom.30 Research shows
that 80 percent of the variance in the out-
comes of aid projects occurs within coun-
tries rather than across them, further un-
dermining the idea that there is anything
approaching a uniform “level” of corrup-
tion within nation-states.31

But most important, the focus on nation-
states fails to reflect the reality of how some
of the most egregious forms of corruption
operate in practice, particularly those that
entail shifting value from one jurisdiction to
another. We know that kleptocracy most of-
ten relies on the collusion of rich countries:
“the bigger the financial center, the more
dirty money flows through it.”32 While it is
true that effective action against such activ-
ities would require sovereign nation-states
to come together in a concerted manner,
that is unlikely to happen if we systemat-
ically underplay the interconnectedness
of how some forms of corruption function
and the facilitating role of so-called clean
countries. As Cooley and Sharman have ob-
served, the implication for how we research
and combat corruption is that we need “a
shift in the unit of analysis, to transnation-
al networks, rather than just states,” a point
underlined by the revelations in the “Pana-
ma Papers” and “Paradise Papers.”33

Third, we need to stop searching for uni-
corns. By this, I mean any attempt to identi-
fy “the answer” to how we should combat
corruption, exemplified by the various lists
mentioned at the start of this essay. There
is now a consensus that one-size-fits-all
approaches are doomed to failure, and yet
the temptation to develop prescriptive ap-
proaches remains deeply embedded and
anticorruption “toolkits” abound. Even if
those once offered by the United Nations,
for example, are no longer peddled quite so
hard, the language of anticorruption tools
and toolkits is still widely used, as is the in-
vocation to establish anticorruption agen-
cies with common standards.34 It is essen-
tial, of course, to outline some core stan-
dards and expectations against which to
judge progress, but research increasingly
emphasizes the need to pay due attention
to specific contexts and how these shape
the implementation of any given reform
measures. Equally, the “paths to success” in
those countries deemed to have done well
in combating corruption can vary signifi-
cantly, calling into question any notion
of one specific or “correct” route: as the
eighteenth-century biologist and Catho-
lic priest John Needham observed, there
are more ways to heaven than one. The
evidence suggests that, historically, crisis
and existential threats, gradualist reform,
visionary leadership, and/or popular de-
mands can all be key factors–depending
on their interaction with other circum-
stances–in moving from particularism to
the more universalistic and impartial pro-
vision of public goods that characterizes
low-corruption jurisdictions.35

There is, then, no single route that needs
to be followed, just as apparently similar
circumstances in different countries can
result in very different outcomes. Roth-
stein convincingly argues against precise-
ly the institutional toolkit approach that
seeks a “magic key” to unlock incremen-
tal anticorruption measures.36 He uses

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the examples of Sweden and Denmark to
illustrate how a “big-bang” approach to
major administrative reorganization in
the mid-nineteenth century–following
crushing military defeats that threatened
their very survival–better accounts for the
move from “limited” to “open-access”
orders. However, in Spain, which also suf-
fered a catastrophic military defeat at the
end of the nineteenth century, the response
was very different: in this case, rather than
a move toward more impersonal, univer-
salistic forms of administrative organiza-
tion, the crisis brought forth a so-called
iron surgeon in the form of Miguel Primo
de Rivera, establishing a model of Spanish
dictatorship that would persist for much
of the twentieth century. Ultimately, and
as unsatisfactory as it may seem, it is hard
to escape the conclusion that a very signifi-
cant element of contingency plays into how
different administrative orders have come
about. For all that comparative historical
and institutional sociologists–building
on Barrington Moore’s classic Social Or-
igins of Dictatorship and Democracy–have
persuasively identified different routes to
the modern world, we still struggle to un-
pack the precise mechanisms that explain
the relationship between long-term struc-
tural factors and short-term agency.37
Given these arguments, the challenge

is to identify what kinds of specific initia-
tives may work in combating corruption.
An essential first step is to specify both the
type of corruption in question and its lo-
cus. That means paying far more attention
to the modalities of different forms of cor-
ruption and how they change and mutate
in response to wider sociopolitical and eco-
nomic developments. Different strategies
will be required to address different types
of corruption. If we wish to concentrate on
tackling transnational corruption, for in-
stance, then we need a more sophisticat-
ed understanding of how licit and illicit

practices interact to establish global net-
works populated by individuals who ex-
ploit channels made available through the
operations of banks, shell companies, re-
altors, and so forth.

Of particular note, the emergence of
what has been termed the “post-modern
state” has led to a blurring of conventional
divisions between different spheres of ac-
tivity, notably the public and private sec-
tors. Despite continued contestation over
the nature and meaning of processes asso-
ciated with both “globalization” and the
“hollowing out” of the state, the fact is that
in many states, there no longer exists a clear
separation between the respective remits
of public and private providers: not just in
terms of policy delivery, but increasingly
in terms of policy design, especially in re-
lation to financial and regulatory matters.
This point matters greatly for any attempt
to tackle transnational corruption because
corrupt individuals have been able to adapt
and change in response to these broader de-
velopments, exploiting new opportunities
in a continuing effort to outsmart the reg-
ulatory measures designed to curb their ac-
tivities. Notably, changes in the global fi-
nancial architecture associated with the
way that money can be moved internation-
ally have not only made it much harder for
individual states to enforce effective regu-
lations, but have also created new oppor-
tunities for illicit international networks to
hide the proceeds of corrupt activities. At
the same time, the increased interpenetra-
tion between public and private sectors, as-
sociated with the rise of what have been var-
iously described as “business politicians,”
“flexians” (an elite professional class who
serve multiple, overlapping roles ranging
across government and private enterprise),
or “globalized individuals,” undermines
traditional forms of accountability.38 In this
emerging and fluid environment, the abili-
ty of individuals to move between a range of
roles and nationalities, coupled with quan-

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147 (3) Summer 2018Paul M. Heywood

tum leaps in information technology, offers
new opportunities for malfeasance.

The implication of such developments
is that successful efforts to tackle the in-
creasingly transnational nature of much
contemporary corruption, often struc-
tured through intermediaries operating in
the legal and professional world, requires
much greater international cooperation
and shared activity than has been the con-
vention in anticorruption programming. A
transnational strategy must put greater em-
phasis on the policy role of such interna-
tional bodies as the Financial Action Task
Force, supported by its equivalent region-
al groups,39 as well as more extensive use of
such instruments as beneficial ownership
regulations, unexplained wealth orders,
and the United Nations Office on Drugs
and Crime’s International Money Laun-
dering Information Network. Twenty EU
member states have recently announced
an agreement to set up in Luxembourg the
European Public Prosecutor’s Office, de-
signed to tackle cross-border fraud, and
some, including Judge Mark Wolf in this
volume, have called for the establishment
of an International Anti-Corruption Court,
modeled on the International Criminal
Court.40 Clearly, the role of such instru-
ments in turn raises questions about ac-
countability, transparency, and civic par-
ticipation, but it is clear that without more
concerted cooperation across states, na-
tionally focused responses are unlikely to
succeed in managing corruption.

A second observation about practical in-
terventions again relates to scale, but this
time it focuses on the subnational rather
than transnational level. It is noteworthy
that two of the most widely cited exam-
ples of positive anticorruption measures,
Hong Kong and Singapore, are effectively
city-states. Other “success stories” have
also involved various agencies working
together to clean up cities, as in Lviv, La
Paz, Monterrey, and Ciudad Juárez.41 That

points to the need to focus more attention
on anticorruption initiatives in urban cen-
ters. Just 3 percent of the earth’s landmass
is urbanized, yet cities are responsible for
around 70 percent (and growing) of over-
all primary energy consumption, reflect-
ing their status as the prime drivers of the
global economy: 50 percent of global gdp
is generated by 380 cities in the developed
world (20 percent from 190 cities in North
America alone), and just 20 cities are home
to one-third of all large corporations and
nearly half their income.42 Dieter Zinn-
bauer is one of the few to have noted that
cities matter in fighting corruption, point-
ing out a “double blind-spot: anti-corrup-
tion analysts and advocates do not pay suf-
ficient attention to cities, and urban prac-
titioners do not pay enough attention to
corruption.”43 Writing for The Guardian,
Jack Shenker observes that

despite the soaring relevance of cities to our
lives, to date global anti-corruption efforts
have largely been targeted at countries as a
whole, rather than at the urban settlements
within them. The recent Panama Papers ex-
posé . . . revealed the extent to which tax ha-
vens have a direct impact on cities.44

In June 2017, the Center for Advancement
in Public Integrity at Columbia Law School
hosted the Global Cities II conference,
which focused on the increasing use of data
analytics to combat corruption.45 The con-
ference brought together anticorruption
leaders from Bogotá, Cape Town, London,
Melbourne, Miami, Montréal, New York,
Paris, Rio de Janeiro, and San Francisco to
explore how data driven approaches in ar-
eas highly vulnerable to fraud (benefits, hu-
man resources, procurement, campaign fi-
nance) can help identify outliers that may
indicate untoward activity. Anticorruption
analysts have put great hopes in the use of
open data to help fight corruption, nota-
bly through the auspices of the Open Data
Charter, following recognition by the G20

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much emphasis on the public sector ver-
sus the private sector, coupled with calls
for generic, national anticorruption plans
and strategies.

The argument I have sought to make is
that if we want to make progress in tack-
ling corruption, we need to make funda-
mental changes to our approach. Most im-
portant, we should stop talking in glob-
al, generic terms about corruption and be
much more attentive to which precise is-
sues we are concerned about, where they
occur, and how they operate. That means
taking proper account of how changes in
both the international architecture of glob-
al trade and finance, and also the design
and organization of modern states, affect
the nature of and possibilities for emerg-
ing corrupt exchanges. We therefore need
to rein in our ambition and be more realis-
tic about what it is possible to achieve and
at what level. We need to focus more atten-
tion on appropriate units of analysis, both
in terms of research and in policy-formu-
lation; that means better understanding
when and why individuals engage in cor-
rupt activities, how their actions are shaped
by social norms, and how those norms can
be changed. Equally, we should pay much
more attention to what we mean when we
talk about integrity, recognizing that it does
not result simply from removing corrup-
tion. In short, we need to change the terms
of the conversation and accentuate the pos-
itive, rather than only trying to eliminate
the negative.

Anti-Corruption Working Group of its po-
tential to follow financial flows and high-
light irregularities in public contracting and
procurement processes in particular.46 The
use of open data, of course, is not a mag-
ic bullet, and the extent to which it offers a
route forward will be conditioned by oth-
er factors (including the capacity to inter-
pret and act upon it). Whereas data analyt-
ics are clearly of significant potential rele-
vance in “world cities” where illicit money
flows enable corrupt networks to operate,
they are less likely to be helpful in war-torn
centers where law and order has effective-
ly collapsed, or where bribery for access to
services is routinized and there are strong
links between corruption and generalized
violence and organized crime.

The key point, however, is that successful
anticorruption initiatives can start small:
there is no ineluctable need for them to be
led from above by national authorities. That
is encouraging, since it suggests that there
can be a possibility of progress even when
political will at the national level is lack-
ing. Increasingly, anticorruption research-
ers and programmers are recognizing that
the need to consider context means that ini-
tiatives need to be highly targeted, both in
terms of scale and sectoral focus.

In addition to looking in more detail at
the prevalence and operation of corrup-
tion in cities and at other subnational lev-
els, there is a growing realization that we
need to pay greater attention to sectoral
differentiation, exploring the pathologies
of corruption risk in specific fields. This
line is further developed, with notable ad-
vances in studying procurement process-
es, as well as initiatives such as the Trans-
parency International global programs on
defense and security, pharmaceuticals and
health care, and mining, among others, to-
gether with a growing recognition of cor-
ruption in fields like education and pro-
fessional sports. However, in general anti-
corruption programming, there is still too

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endnotes
1 See Augusto Lopez-Claros, “Six Strategies to Fight Corruption,” The World Bank, May 14, 2014,
http://blogs.worldbank.org/futuredevelopment/six-strategies-fight-corruption; Robert Hunja,
“Here are 10 Ways to Fight Corruption,” The World Bank, December 8, 2015 http://blogs
.worldbank.org/governance/here-are-10-ways-fight-corruption; Transparency International,
“How to Stop Corruption: 5 Key Ingredients,” March 10, 2016, https://www.transparency
.org/news/feature/how_to_stop_corruption_5_key_ingredients; Blair Glencorse, “5 ways to
Beat Global Corruption,” World Economic Forum, November 6, 2014, https://www.weforum
.org/agenda/2014/11/five-ways-beat-global-corruption/; and Dimitri Vlassis, “3 Key Steps
to End Corruption,” World Economic Forum, January 16, 2015, https://www.weforum.org/
agenda/2015/01/three-ways-to-end-global-corruption/.

2 James D. Wolfensohn, “People and Development: Annual Meetings Address,” in Voice for the
World’s Poor: Selected Speeches and Writings of World Bank President James D. Wolfensohn, 1995–2005
(Washington, D.C.: The World Bank, 2005).

3 See Daniel Kaufmann, “Rethinking the Fight Against Corruption,” The Brookings Institution, No-
vember 29, 2012, https://www.brookings.edu/opinions/rethinking-the-fight-against-corruption/;
Alina Mungiu-Pippidi and Niklas Kossow, “Rethinking the Way We Do Anti-Corruption,”
NATO Review, 2016, http://www.nato.int/docu/review/2016/Also-in-2016/anticorruption
-corruption-laws-regulation-control-anticorrp-budget-index/EN/index.htm; Janine Wedel,
“Rethinking Corruption in an Age of Ambiguity,” Annual Review of Law and Social Science 8 (2012):
453–498; John M. Ackerman, “Rethinking the International Anti-Corruption Agenda,” Amer-
ican University International Law Review 29 (2) (2014): 293–333; Franklin A. Gevurtz, “Rethink-
ing Corruption: An Introduction to a Symposium and a Few Additional Thoughts,” McGeorge
Global Business and Development Law Journal 20 (2) (2007): 237–242; Paul M. Heywood, “Re-
thinking Corruption: Hocus-Pocus, Locus and Focus,” Slavonic and East European Review 95 (1)
(2017): 21–48; Michael Sidwell, “Rethinking Corruption in the Middle East and North Africa,”
Transparency International, July 7, 2011, http://blog.transparency.org/2011/07/07/rethinking
-corruption-in-the-middle-east-and-north-africa/; Rustamjon Urinboyev and Måns Svens-
son, “Rethinking Corruption in Post-Soviet Uzbekistan,” in Eugen Ehrlich’s Sociology of Law,
ed. Knut Papendorf, Stefan Machura, and Anne Hellum (Münster: lit Verlag, 2014), 207–
235; Marlon Arthur Huwae, “My Voice: Rethinking Corruption in Southern Hemisphere,”
USA Today, November 6, 2015, https://www.usatoday.com/story/opinion/2015/11/06/voice
-rethinking-corruption-southern-hemisphere/75325512/; and Meredith L. Gore, Jonah Rat-
simbazafy, and Michelle L. Lute, “Rethinking Corruption in Conservation Crime: Insights
from Madagascar,” Conservation Letters 6 (6) (2013): 430–438. I should also mention the spe-
cial issue of Slavonic and East European Studies 95 (1) (2017) on “Innovations in Corruption Stud-
ies,” linked to anticorrp and edited by Alena Ledeneva, Roxana Bratu, and Philipp Köker,
available at http://www.jstor.org/stable/10.5699/slaveasteurorev2.95.issue-1.

4 Dieter Zinnbauer, “Social Accountability–Taking Stock of All the Stock-Taking and Some Inter-
esting Avenues for Future Practice and Research,” February 8, 2017, https://papers.ssrn.com/
sol3/papers.cfm?abstract_id=2913597.

5 Organisation for Economic Co-operation and Development, “Recommendation of the Coun-
cil on Public Integrity,” January 26, 2017, http://webnet.oecd.org/OECDACTS/Instruments/
ShowInstrumentView.aspx?InstrumentID=353&InstrumentPID=476&Lang=en&Book=False.
The Transparency International “School on Integrity” that has run annually since 2011 of-
fers a program predominantly focused on identifying, monitoring, measuring, and reporting
corruption, as well as providing “state-of-the-art” anticorruption training, but seems to have
no sessions on what is meant by integrity; see http://transparencyschool.org.

6 See Paul M Heywood, Heather Marquette, Caryn Peiffer, and Nieves Zúñiga, “Integrity and In-
tegrity Management in Public Life,” anticorrp D11.4 Academic Report on Integrity Man-
agement, February 28, 2017, http://anticorrp.eu/wp-content/uploads/2017/08/D11_4-FINAL
-combined.pdf.

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7 Leo Huberts, The Integrity of Governance: What It is, What We Know, What is Done, and Where to Go

(London: Palgrave Macmillan, 2014).

8 Bo Rothstein and Aiysha Varraich, Making Sense of Corruption (Cambridge: Cambridge Univer-

sity Press, 2017), 125–148.

9 See Lynne McFall, “Integrity,” Ethics 98 (1) (1987): 5–20; and Damian Cox, Marguerite La Caze,
and Michael P. Levine, Integrity and the Fragile Self (Hampshire, United Kingdom; Burlington,
Vt.: Ashgate, 2003).

10 Matthew Smith, “Deporting Irene Clennell was Wrong, Say Nearly Two Thirds of Brits,” YouGov
UK, https://yougov.co.uk/news/2017/03/01/deporting-irene-clennell-was-wrong-say-nearly
-two-/ (accessed March 31, 2017).

11 Stephen M. Garcia, Patricia Chen, and Matthew T. Gordon, “The Letter Versus the Spirit of the
Law: A Lay Perspective on Culpability,” Judgement and Decision-Making 9 (5) (2014): 479–490.
12 Norman J. Finkel, Commonsense Justice: Jurors’ Notions of the Law (Cambridge, Mass.: Harvard Uni-

versity Press, 1995).

13 Benjamin A. Olken and Rohine Pande, “Corruption in Developing Countries,” Annual Review

of Economics 4 (2012): 479–509.

14 Francesco Gino and Lamar Pierce, “Lying to Level the Playing Field: Why People May Dishon-
estly Help or Hurt Others to Create Equity,” Journal of Business Ethics 95 (S1) (2010): 89–103.
15 Max H. Bazerman and Ann E. Tenbrunsel, Blind Spots: Why We Fail to Do What’s Right and What
to Do about It (Princeton, N.J.: Princeton University Press, 2012); and Ann E. Tenbrunsel and
David M Messick, “Ethical Fading: The Role of Self-Deception in Unethical Behavior,” So-
cial Justice Research 17 (2) (2004): 223–236.

16 Nils C. Köbis, Jan-Willem van Prooijen, Francesca Righetti, and Paul A. M. Van Lange, “The

Road to Bribery and Corruption,” Psychological Science 28 (3) (2017): 297–306.

17 Leena Koni Hoffmann and Raj Navanit Patel, Collective Action on Corruption in Nigeria: A Social
Norms Approach to Connecting Society and Institutions (London: Chatham House, Royal Institute of
International Affairs, 2017), v–vi. See also Cheyanne Scharbatke-Church and Russell Hatha-
way, “Are Social Norms an Important Missing Link in Anti-Corruption Programming?” cda
Perspectives Blog, March 21, 2017, http://cdacollaborative.org/blog/social-norms-important
-missing-link-anti-corruption-programming/.

18 Syed Hussein Alatas, Corruption: Its Nature, Causes and Consequences (Aldershot, United Kingdom:

Avebury, 1990), 3–4.

19 Charles Kenny, Results Not Receipts (Washington, D.C.: Center for Global Development, 2017),
111, suggests that “donor countries” professing “zero tolerance” for corruption is more of a
marketing ploy than a matter of principle.

20 Mushtaq H. Khan, “Governance and Anti-Corruption Reforms in Developing Countries: Pol-
icies, Evidence and Ways Forward,” G-24 Discussion Paper Series No. 42 (New York and Ge-
neva: United Nations Conference on Trade and Development, 2006), http://www.unctad.org
/en/docs/gdsmdpbg2420064_en.pdf.

21 Gillian K. Hadfield and Barry R. Weingast, “Microfoundations of the Rule of Law,” Annual Review

of Political Science 17 (2014): 21–42.

22 Merilee S. Grindle, “Good Governance, R.I.P.: A Critique and an Alternative,” Governance 30 (1)
(2017): 17–22. See also Merilee S. Grindle, “Good Enough Governance: Poverty Reduction and
Reform in Developing Countries,” Governance 17 (4) (2004): 525–548; and Merilee S. Grindle,
“Good Enough Governance Revisited,” Development Policy Review 25 (5) (2007): 533–574.

23 In a recent post on his influential From Poverty to Power blog, Duncan Green of Oxfam ob-
served that he felt “the anti-corruption movement is a bit stuck and really does need to re-
think. One option would be to stop using the ‘C’ word altogether because it’s such a terrible

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147 (3) Summer 2018Paul M. Heywood

starting point.” See Duncan Green, “How Can the Anti-Corruption Movement Sharpen Up
Its Act,” From Poverty to Power, July 20, 2017, http://oxfamblogs.org/fp2p/how-can-the-anti
-corruption-movement-sharpen-up-its-act/. Kenny, in Results Not Receipts, 1–17 and 109–111,
argues that the way we conceptualize and measure corruption damages the potential for hu-
manitarian aid to deliver results.

24 I have argued elsewhere that, despite its widespread use, cancer is a very poor analogy for corrup-
tion. See Paul M. Heywood, “Why We Need to Kill the ‘Corruption as Cancer’ Analogy,” cda
Perspectives Blog, September 19, 2017, http://cdacollaborative.org/blog/need-kill-corruption
-cancer-analogy/.

25 See Matthew Stephenson’s comment in response to the post by Rick Messick, “Why is Cor-
ruption so Hard to Define,” The Global Anticorruption Blog, August 5, 2015, https://global
anticorruptionblog.com/2015/08/05/why-is-corruption-so-hard-to-define/.

26 Michael Johnston notes that in influence markets, “even if all funds flow through legal chan-
nels there can still be major corruption concerns”; Michael Johnston, Syndromes of Corruption
(Cambridge: Cambridge University Press, 2005), 60. See also Daniel Kaufmann and Pedro C.
Vicente, “Legal Corruption,” Economics & Politics 23 (2) (2011): 195–219; and Zephyr Teachout,
“The Problem of Monopolies and Corporate Public Corruption,” Dædalus 147 (3) (Summer
2018): 111–126.

27 In the words of Staffan Andersson: “The literature often treats corruption as if it consists of
one thing regardless of where or how it occurs.” See Staffan Andersson, “Beyond Unidimen-
sional Measurement of Corruption,” Public Integrity 19 (1) (2016): 58–76.

28 Alexander Cooley and J. C. Sharman, “Transnational Corruption and the Globalized Individual,”

Perspectives on Politics 15 (3) (2017): 746.

29 Andersson, “Beyond Unidimensional Measurement,” 59.
30 See Miriam Golden and Lucio Picci, “Proposal for a New Measure of Corruption, Illustrated
with Italian Data,” Economics and Politics 17 (1) (2005): 37–75; Alexander Libman and Vladimir
Kozlov, “Sub-National Variation of Corruption in Russia: What Do We Know About It?” Re-
gion 2 (2) (2013): 153–180; Nicholas Charron, “The Correlates of Corruption in India: Analy-
sis and Evidence from the States,” Asian Journal of Political Science 18 (2) (2010): 177–194; and
Jonas Linde and Gissur Ó. Erlingsson, “The Eroding Effect of Corruption on System Support
in Sweden,” Governance 26 (4) (2013): 585–603.

31 Kenny, Results Not Receipts, 110.
32 J. C. Sharman, The Despot’s Guide to Wealth Management (Ithaca, N.Y.: Cornell University Press,

2017), 17.

33 Cooley and Sharman, “Transnational Corruption,” 746.
34 United Nations Office on Drugs and Crime, The Global Programme Against Corruption: UN Anti-
Corruption Toolkit, 3rd ed. (Vienna: United Nations Office on Drugs and Crime, 2004), https://
www.un.org/ruleoflaw/files/UN_Anti%20Corruption_Toolkit.pdf; and Organisation for Eco-
nomic Co-operation and Development, Specialised Anti-Corruption Institutions: Review of Models
(Paris: Organisation for Economic Co-operation and Development, 2013), https://www.oecd
.org/corruption/acn/specialisedanti-corruptioninstitutions-reviewofmodels.htm. See also
acts Anti-Corruption Toolkit for smes (small to medium business enterprises), http:/www
.acts-project.eu/P42A0C155S124/Contacts.htm; Transparency International, “Corruption Fight-
ers’ Toolkits: Introduction,” https://www.transparency.org/whatwedo/tools/corruption_
fighters_toolkits_introduction/3/; cdc Group, “esg Toolkit for Fund Managers: Anti-Cor-
ruption,” http://toolkit.cdcgroup.com/business-integrity/anti-corruption; and Sam East-
wood, Jason Hungerford, Mark Pyman, and Jasmine Elliott, “Countries Curbing Corruption,”
Norton Rose Fulbright, April 2017.

35 Alina Mungiu-Pippidi, The Quest for Good Governance: How Societies Develop Control of Corruption

(Cambridge: Cambridge University Press, 2015), 57–82.

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Dædalus, the Journal of the American Academy of Arts & SciencesCombating Corruption in the Twenty-First Century: New Approaches

36 Bo Rothstein, “Anti-Corruption: The Indirect ‘Big Bang’ Approach,” Review of International Po-

litical Economy 18 (2) (2011): 228–250.

37 Barrington Moore Jr., Social Origins of Dictatorship and Democracy: Lord and Peasant in the Making of

the Modern World (Boston: Beacon Press, 1966).

38 Donatella della Porta, “Actors in Corruption: Business Politicians in Italy,” International Social
Science Journal 48 (149) (1996): 349–364; Janine Wedel, Shadow Elite (New York: Basic Books,
2009); and Cooley and Sharman, “Transnational Corruption.”

39 See details at Financial Action Task Force, http://www.fatf-gafi.org/countries/.
40 Reuters, “Twenty EU Countries to Set Up Prosecutor for Cross-Border Fraud,” October 12,
2017, https://www.reuters.com/article/eu-fraud/twenty-eu-countries-to-set-up-prosecutor-for
-cross-border-fraud-idUSL8N1MN47B; and Judge Mark L. Wolf, “The Case for an International
Anti-Corruption Court,” Brookings Institution, July 23, 2014, https://www.brookings.edu/
research/the-case-for-an-international-anti-corruption-court/. See also Mark L. Wolf, “The
World Needs an International Anti-Corruption Court,” Dædalus 147 (3) (Summer 2018): 144–156.
41 See Ilya Lozovsky, “The Spirit of Lviv,” Curbing Corruption: Ideas That Work (London: Legatum In-
stitute, 2015), http://www.li.com/programmes/curbing-corruption-ideas-that-work/; Nieves
Zúñiga and Paul M. Heywood, “Cleaning Up La Paz,” Curbing Corruption: Ideas That Work; and
Lucy Conger, “The Private Sector and Public Security: The Cases of Ciudad Juárez and Mon-
terrey,” Working Paper Series on Civic Engagement and Public Security in Mexico (San Diego:
Wilson Center at the University of San Diego, 2014).

42 McKinsey Global Institute, “Urban World: What Next?” October 2016, https://www.mckinsey

.com/mgi/overview/in-the-news/urban-world-app.

43 Dieter Zinnbauer, “Cities of Integrity,” draft working paper (Berlin: Transparency Interna-

tional, 2013).

44 Jack Shenker, “Which are the Most Corrupt Cities in the World?” The Guardian, June 21, 2016,
https://www.theguardian.com/cities/2016/jun/21/which-most-corrupt-cities-in-world.
45 Center for the Advancement of Public Integrity, “Data Analytics, the Next Frontier: Taking a Byte
Out of Corruption,” July 2017, http://www.law.columbia.edu/sites/default/files/microsites
/public-integrity/data_analytics_the_next_frontier_0.pdf.

46 Open Data Charter, Open Up Guide: Using Open Data to Combat Corruption (New York: Open Data
Charter, May 2017), https://opendatacharter.net/wp-content/themes/proparty/assets/anti
corruption_guide.pdf.

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147 (3) Summer 2018Paul M. Heywood
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