Fighting Corruption from the Roots: Takeaways from Our First Webinar

At FININTEGRA, we believe that change starts with difficult conversations. Our first public webinar, Structural Corruption: Challenges for the Prevention and Fight Against Money Laundering, was a space to think critically about how systemic power structures enable money laundering and corruption, and what role compliance professionals, public institutions, and civil society have in challenging them.

We were honored to welcome Dr. Irma Eréndira Sandoval, renowned researcher and former Secretary of Public Administration of Mexico, for a deep discussion on her Theory of Structural Corruption and Theory of Double Fraud. Alongside her, FININTEGRA’s own Enrique Nort shared practical reflections on how these ideas reshape compliance practices and the fight against money laundering.

Held in Spanish, the session brought together compliance professionals, academics, public officials, and students from across Latin America, including participants from the Master’s Program in Analysis and Prevention of Corruption at the International University of La Rioja (UNIR), Spain. It was an ambitious and necessary start.

Below we share key excerpts and highlights from the conversation, with the hope of encouraging new strategies and alliances in the fight against structural corruption.

Structural Corruption: Beyond “Bad Apples”

Our guest speaker, Dr. Irma Eréndira Sandoval, one of Latin America’s most influential thinkers on transparency and public ethics, challenged us to see corruption not as the work of isolated “bad apples,” but as a problem of the entire orchard: the systemic structures that enable abuse, impunity, and inequality.

She introduced her Theory of Structural Corruption, arguing that corruption is:

• Always unethical, but not always illegal.
• Normalized rather than exceptional.
• Rooted in power, not simply greed.

As she explained, corruption “trickles down from the top of the pyramid” and thrives where public and private interests blend in opaque ways. One of her most striking concepts was the Theory of Double Fraud: a two-faced crisis where economic-financial fraud goes hand in hand with electoral-political manipulation. Illicit money doesn’t just fund luxury; it buys power, and vice versa.

“When economic elites can buy elections, and political actors can loot public coffers, we are no longer talking about isolated acts of corruption. We are facing a system of domination.”

While these dynamics are visible globally, Dr. Sandoval stressed that local solutions matter, rooted in civic participation, institutional reform, and above all, accountability.

From Theory to Practice: The Compliance Officer’s Role

Following Dr. Sandoval’s conceptual framework, Enrique Nort, FININTEGRA’s specialist in financial integrity and AML, helped ground the discussion in day-to-day practice.

With over 30 years of global compliance experience, he showed how these structural insights must inform the way we investigate, prevent, and report financial crimes.

Traditional AML compliance has rightly focused on Politically Exposed Persons (PEPs). But as Nort explained, this can lead to blind spots. We often overlook the complex ecosystems around PEPs: shell companies, professional enablers, relatives, brokers, and opaque corporate structures that distance dirty money from its true source.

He urged compliance professionals to:

• Map networks, not just individuals.
• Use open-source intelligence to identify patterns of scandal.
• Focus on red flags like unexplained wealth, offshore structures, or sudden lifestyle changes.
• Move beyond box-ticking toward a more investigative, connected approach to financial oversight.

Perhaps most importantly, Nort emphasized the role of Financial Intelligence Units (FIUs) as the “engine room” of AML efforts. But, he warned, they can only be effective if the private sector reports with clarity, depth, and purpose, not by submitting large volumes of defensive, low-quality reports.

“We must avoid ‘defensive reporting.’ Let’s send fewer reports, but better ones. With context. With links. With purpose.”

Impunity: The Shield of Structural Corruption

A key theme that emerged was impunity. Dr. Sandoval argued that there is no real fight against corruption without real consequences. Impunity, especially for political and economic elites, is not a side effect of corruption, but a defining feature of its structure.

She cited cases where major financial institutions involved in laundering were allowed to pay symbolic fines and quickly return to business as usual, with the social harm they caused going unaddressed. This sends a dangerous message: some actors are above the law.

“We cannot talk about financial integrity while operating in free zones of banking secrecy and complete lack of accountability for private actors.”

She also highlighted the connection between impunity and weakened democracy. When those in power face no consequences, it erodes not just the rule of law but also public trust, ultimately undermining institutional legitimacy.

Enrique Nort reinforced this point, noting that under-resourced regulators and politically captured institutions often lack the teeth to enforce rules. That’s why financial institutions themselves must strengthen their internal teams, compliance procedures, and ethical culture.

And this isn’t just about rules, it’s about people.

Dr. Sandoval described compliance officers as “Integrity Prosecutors”, professionals who stand at the boundary between legality and illegality, between democracy and distortion. She also stressed the critical importance of protecting whistleblowers in the financial sector:

“They are heroes, but too often we send them to war without armor.”

The Heptagon of Integrity: A Holistic Framework

To close her talk, Dr. Sandoval presented her Heptagon of Integrity, a model that goes beyond typical three-part frameworks of transparency, auditing, and accountability.

Her vision includes seven interconnected systems:

• Public Service Professionalization: Ethics, meritocracy, and institutional culture within the civil service.
• Public Procurement: Competitive, transparent contracting processes shielded from favoritism.
• Oversight and Auditing: Effective internal controls and independent audit bodies.
• Government Accounting: Accurate, timely reporting of public resources and operations.
• Transparency and Accountability: Public access to information and robust civic oversight.
• Combatting Impunity: Stronger enforcement mechanisms, including administrative, criminal, and financial sanctions.
• Budgeting and Public Debt: Transparent, well-managed public finance, especially around debt.

Final Reflections: Can Corruption Be Fought?

The webinar closed with a direct question from participants:

Why haven’t international organizations managed to eliminate corruption? Should we simply try to “manage” it instead?

Dr. Sandoval was unequivocal: “No.”

We may never eliminate all corruption, but that is no reason to give up the fight.

“This isn’t a time for cynicism. It’s a time for integrity, legality, and action.”

Enrique Nort agreed, reminding us that international standards like those of the FATF or Egmont Group are only tools. It is up to each country, and each citizen, to give them teeth.

At FININTEGRA, we are committed to fostering this kind of conversation and translating it into meaningful action. We thank all participants for making our first webinar such an insightful and thought-provoking event.

We invite you to watch or rewatch the full webinar https://youtu.be/AiO2jGHae34?si=9bKIOHJETD2Uv0Rt, available in both Spanish and English. Let’s keep the conversation going.