Removing the Barriers to Retroactive Application of the United Nations Convention Agaist Corruption to Pre-December 2005 Crime

By

Kayode Oladele

kayoladele@yahoo.com

During his recent visit to Nigeria, the British Foreign Secretary Jack Straw said that with coming into effect of “the newly signed UN convention against corruption, the British government was now committed to returning to the Nigerian government assets stolen from the country in accordance with the UK law."  U.K signed the convention on December 9, 2003, but did not ratify it until February 9, 2006.  The Convention which was adopted by the United Nations General Assembly in October 2003, has been signed by 140 countries and ratified by 38 came into force on December 14, 2005. It is the first legally binding global instrument designed to help Member States fight corruption in both the public and private sectors.  In the words of Antonio Maria Costa, Executive Director, United Nations Office on Drugs and Crime (UNODC), "time and time again, countries' assets have been looted by corrupt leaders, while in the corporate world; many shareholders have been robbed by corrupt managers."

 According to text of the Convention published by the UNODC, the Convention establishes certain specific crimes to combat activities which are commonly used in support of transnational organized crime activities: participation in organized criminal groups, money-laundering, corruption, and obstruction of justice. States Parties are required to criminalize these activities, as well as to adopt legislation and administrative systems to provide for extradition, mutual legal assistance, investigative cooperation, preventive and other measures, as necessary to bring existing powers and provisions up to the standards set by the Convention. In addition to establishing a corruption offence (Article 8), the instrument also requires the adoption of measures to prevent and combat corruption (Article 9).

The criminalization requirements include central provisions that are binding on States Parties and supplementary ones that are discretionary. The mandatory corruption offences capture both active and passive corruption: “…the promise, offering or giving…” as well as “…the solicitation or acceptance…” of any “undue advantage”. In both offences the corrupted person must be a “public official”, the advantage conferred must be linked in some way to acting or refraining from acting in the course of official duties, and the advantage may be conferred directly or indirectly. States Parties are also required to criminalize participation as an accomplice in these offences. In addition to the mandatory offences, State Parties are also required to consider criminalizing the same conduct where the person promising offering or giving the benefit is in one country and the public official who solicits or accepts it is in another.

They are also required to consider criminalizing other forms of corruption. In cases where the public official involved is involved in a criminal justice system and the corruption is directed at legal proceedings, the Convention offence relating to the obstruction of justice would also be added to the offenses. The Convention also requires the adoption of additional measures against corruption. The text calls for “…legislative, administrative or other effective measures to promote integrity and to prevent, detect and punish the corruption of public officials”. It does not specify details of the measures to be adopted, but does require further measures to ensure that officials take effective action, including ensuring that the appropriate authorities possess sufficient independence to deter inappropriate influences on them. See UNODC anticorruption kit @. www.unodc.org/pdf/crime. 

The Convention rests on four pillars: prevention and criminalization of corruption, international cooperation and asset recovery. It provides tough provisions on asset recovery and also guarantees that nowhere in the world will be exempt from the obligation to return looted assets. In the same vein, the old excuse such as banking secrecy will no longer be an imp ediment. Under the convention, countries agreed to co-operate with one another in every aspect of the fight against corruption, including prevention, investigation, and the prosecution of offenders. Countries are bound by the convention to render specific forms of mutual legal assistance in gathering and transferring evidence for use in court, to extradite offenders. Countries are also required to undertake measures which will support the tracing, freezing, seizure and confiscation of the proceeds of corruption. In effect, states are required to return money and other assets obtained through corruption to the country from which they were stolen.

This Convention is important for two reasons: it sends a warning to c orrupt officials everywhere that they can no longer expect to enjoy the fruits of their crimes by moving stolen assets abroad and secondly it is also a message of hope to millions of people who have grown angry and frustrated at seeing their country's wealth plundered by criminals. The Convention is an indispensable tool to encourage mutual legal support and technical assistance.  With its entry into force, it will become an international obligation and not just a principle of reciprocity. The wide range of measures on cooperation contained in the Convention and its protocols will provide national authorities with a more effective framework and a variety of tools.  Extradition, mutual legal assistance, police cooperation and technical assistance are among the well-known tools of international cooperation in the struggle against crime.

Another critical area is the justice sector. The Convention recognizes the integrity of the justice system as a central component of any strategy to counter corruption, in particular among members of the judiciary and the prosecution service. Building a culture that is adverse to corruption is central to the integrity of both the private and the public sectors.

Compared to any other international agreement, the Convention against Corruption is most comprehensive and ambitious and would soon become the global standard for a strong anti-corruption regime. Never before has a Convention included stringent provisions against money-laundering - the locomotive and conveyor belt of crime and corruption. And, it is, without a doubt, an effective instrument for combating the phenomenon of transnational financial crime

However, officials of the UN Office of Drug and Crime (UNODC), which is the legal custodian of the convention, in an attempt to clarify the ramifications of the Convention stated recently in an interview with the Guardian Newspapers that the Convention could not be used for crimes committed before the Convention came into force; meaning that the Convention cannot have retroactive effect on acts committed before December 14, 2005 pursuant to Article 28 of the Vienna Convention which voids retroactive effects in legislation.   It is relevant to refer here to Article 28 of the Vienna Convention on the Law of Treaties of 1969, which provides:

Unless a different   interpretation appears from the Treaty or is otherwise established, its provisions do not bind the party in relation to any act or fact which took place or any situation which ceased to  exist before the date of the entry into force of the Treaty with respect to that party.

The Convention does not create a new offence in national and international criminal law but is declaratory of pre-existing law

With due respect to the position taking by the officials of UNODC to the contrary, it is submitted that this Convention may be applied retroactively and that is the intention of the U.N.  This is because the Convention does not create a new offence in international criminal law, but is declaratory of pre-existing national and international law. What the Convention added to the existing body of international law is an affirmative obligation on States parties to make provision for mechanism towards prevention and criminalization of corruption, international cooperation and asset recovery.

Growing concern about corruption as an international problem increased through the 1980s and 1990s to the point where many countries were forced to criminalize it.  Several countries including the U.S, U.K and very recently, Nigeria had enacted anti-corruption legislation which criminalize corruption, prescribe punishment for their violation and make provisions for asset recovery or reparation of ill-gotten wealth ever before the convention came into force. In other words, the Convention merely codified the prohibition of corruption which had been criminalized by many national legislation and has been made a binding international law. In this sense, the Convention is necessarily both retrospective and future-oriented.

According to Blacks Law Dictionary, (6th Edition, 1990),  a retroactive or “retrospective” statute is defined as “one which gives to pre-enactment conduct a different legal effect from that which it would have had without the passage of the statute,”  and in the words of Danielle DuCaine, 724 Loy. L.A. Int’l & Comp. L. Rev [Vol. 25:697, the term also refers to laws which take away, impa ir, or change rights acquired under existing laws with respect to transactions already past. In general, while statutes are presumed to operate prospectively only curative statutes may apply retroactively in order to “clarify” existing law or cure a defect in prior legislation. See Charles B. Hochman, The Supreme Court and the Constitutionality of Retroactive Legislation, 71 HARV. L. REV. 692, 692 (1960).

The positivist approach to international law insists on a basic rule of non-retroactivity.  As Professor Charles R ousseau stated, "International law appears to be determined by the principles of non-retroactivity. This principle is the result of both the treaties and the diplomatic and judicial practice. However, the rule of non-retroactivity, has known many exceptions, most notably in the context of crimes against peace”.  In this Connection Professor Hans Kelsen commented:

The rule against retroactive legislation is a principle of justice. Individual criminal responsibility represents certainly a higher degree of justice than collective responsibility, the typical technique of primitive law.  Since the internationally illegal acts ………. established individual criminal responsibility w ere certainly also morally most objectionable, and the persons who committed these acts were certainly aware of their immoral character, the retroactivity of the law applied to them can hardly be considered as absolutely incompatible with justice. ... In case two postulates of justice are in conflict with each other, the higher one prevails; and to punish those who were morally responsible for the international crime …… may certainly be considered as more important than to comply with the rather relative rule against ex post facto laws, opens to so many exceptions.

In his opening Statement at the International Military Tribunal, the British Chief Prosecutor Lord Hartley Shawcross stated:  

There is thus no substantial retroactivity in the provisions of the Charter. It merely fixes the responsibility for a crime already clearly established as such by positive law upon its actual perpetrators. It fills a gap in international criminal procedure. There is all the difference between saying to a man, “You will now be punished for what was not a crime at all at the time you committed it” and in saying to him “You will now pay the penalty for conduct which was contrary to law and a crime when you executed it, although, owing to the imperfection of the international machinery, there was at time no court competent to pronounce judgment against you.

The general rule of non-retroactivity of treaties and conventions, which was relevant in Nuremberg in connection with the new concept of a "crime against peace", is not however of relevance in the context of the crime of corruption and money laundering which have always been crimes under national penal laws and universally regarded as international crimes.

 Corruption is not only a crime; it is a crime against humanity. Corruption and organized crime affect the daily lives of many people and fundamentally undermine the chances of economies to grow, stated Mo derator Marc Champion, Columnist, The Wall Street Journal Europe, United Kingdom, in his opening remarks to this session on fighting corruption and organized crime. Speaking at the World Economic Forum, Peter Eigen, Chairman of the Board, Transparency International, Germany, stated that over time, corruption has become so overwhelming and systematic that it is difficult to deal with.

Corruption may not be as bad as genocide, but it is also a crime against humanity. Corruption is a killer of initiative and trust. It drives away foreign investment and undermines th e development of the rule of law. But most callously, corruption robs African children of a better future. Corruption directly harms the people, particularly the poor. Corruption undermines the institutional foundation on which economic growth depends. Corruption lowers the quality of public services and infrastructure, distorts government spending decisions, decreases tax and customs revenues, and damages confidence in the rule of law. Corruption undermines confidence in public institutions and exacerbates budget problems. Former U.S. President Grover Cleveland had as his motto, “Public office is a public trust.” When officials abuse that trust, democracy suffers. Corruption tears at the fabric of democracy itself. The World Bank has identified corruption as “the single greatest obstacle to economic and social development.”

Former U.S Attorney General Ashcroft, speaking at the Second Global Forum, said, "Corruption is no longer seen as an accepted cost of doing business; it is no longer tolerated as an unavoidable aspect of government. It is now widely recognized that the consequences of corruption can be devastating: devastating to economies, devastating to the poor, devastating to the legitimacy and stability of government, and devastating to the moral fabric of society." This change in perspective is the harbinger of a future where the corrupt and those who corrupt them will be treated simply as what they are – petty criminals, who will have to face the consequences of their actions in a court of law, just like the thieves, vandals, or common criminals.

Describing corruption as a crime against humanity, Susan Dicklitch, associate professor of government at Franklin & Marshall College, writing in Christian Science Monitor laments as follows: 

“As long as corruption exists at its current levels in Africa, and as long as donors continue to look the other way, foreign aid will simply serve to keep African kleptocrats in power. Consider this: Sub-Saharan Africa has received an estimated $114 billion in bilateral and multilateral aid from 1995-2002. Yet African countries have consistently ended up at the bottom of the United Nations Development Program's Human Development report, which measures life expectancy, gross domestic product per person, and literacy.

So you may ask the billion-dollar question: Where did the money go? Perhaps the British high commissioner to Kenya, Edward Clay, was asking the same question about official graft last month when - suggesting donor aid to Kenya could be suspended - he publicly accused unnamed Kenyan officials of behaving so gluttonously at the aid trough that they are now "vomiting on the shoes" of donors.

And sub-Saharan Africa has seen the likes of many gluttons. Some of the most infamous include Mobutu Sese Seko, the former president of Zaire (now the Democratic Republic of Congo) who allegedly stole $5 billion, and Sani Abacha, former president of Nigeria, who allegedly looted more than $2 billion. Both former leaders are dead, but their leg acy of corruption continues to afflict their nations.”

According to UNODC, every criminal needs to "launder" the proceeds of crime, but where organized crime, drug trafficking and corruption are involved; the consequences of money laundering are bad for business, development, government and the rule of law. Left unchecked, money laundering can erode a nation's economy by changing the demand for cash, making interest and exchange rates more volatile, and by causing high inflation in countries where criminal elements are doing business.

The siphoning away of billions of dollars a year from normal economic growth poses a real danger at a time when the financial health of every country affects the stability of the global market. Money laundering is bad for the economy. Most disturbing of all, money laundering empowers corruption and organized crime. Corrupt public officials need to be able to launder bribes, kick-backs, public funds and, on occasion, even development loans from international financial institutions.

Organized criminal groups need to be able to launder the proceeds of drug trafficking and commodity smuggling. Terrorist groups use money laundering channels to get cash to buy arms. The social consequences of allowing these three groups access to the capacity to launder money can be disastrous. Taking the proceeds of their crimes from corrupt public officials, traffickers and organized cr ime groups is one of the best ways to stop them in their tracks.

Because they deal with other people's money, banks (and other financial and professional institutions) rely heavily on a reputation for probity and integrity. Banks need their good name to build business. A financial institution with a reputation for shady dealing will be shunned by legitimate enterprise. The prestige of even a major bank that is revealed to have assisted in the laundering of money can be severely damaged. Money laundering is bad for business.

Comparing corruption to “gangrene”, a monster affecting developed and developing countries alike, speakers in Committee II of the Eleventh United Nations Crime Congress held in April 2005 agreed said the challenge in the months ahead would be to ensure the implementation of the United Nations Convention against Corruption.

Non-prescription of the crime of crime against humanityIt could be recalled that when the United Nations drafted the Convention on the Non-Applicability of Statutory Limitations to War Crimes and Crimes against Humanity (adopted 26 November 1968, in force 11 November 1970), it clearly and deliberately pronounced its retroactive application.  The principle of nullum crimen sine lege, nulla poena sine lege praevia (no crime  without law, no penalty without previous law), laid out in paragraph 1 of  Article  15 of the International Covenant on Civil and Political Rights is conditioned as follows in paragraph 2: "Nothing in this article shall prejudice the trial and punishment of any person for any act or omission which, at the time when it was committed, was criminal according to the general principles of law recognized by the community of nations." Similarly, article 11, paragraph 2, of the Universal Declaration of Human Rights of 10 December 1948 stipulates that the prohibition of expost facto penal sanctions does not apply if the offence was an offence under national or international law. Clearly corruption and money laundering are offenses recognized and criminalized by U.K, Nigeria and the comity of nations before the coming into force of the Convention. In this context it is relevant to recall the double vocation of the Convention against Corruption, namely to prevent and to punish the crime of corruption. In order to prevent corruption, it is important to deter future offenders by abundant precedent of punishment of prior offenders. < /PRE>

In the classic Oppenheim/Lauterpacht textbook on “International Law”, Professor Hersch Lauterpacht noted that the Genocide Convention which is similar to the Convention against Corruption was not only forward-looking but that it had a primary retrospective significance. He states that “It is apparent that, to a considerable extent, the Convention amounts to a registration of protest against past misdeed of individual or collective savagery rather than to an effective instrument of their prevention or repression. Thus, as the punishment of acts of genocide is entrusted primarily to the municipal courts of the countries concerned, it is clear that such acts, if perpetrated in obedience to national legislation, must remain unpunished unless penalized by way of retroactive laws.”

It is important to note, moreover, that whether or not the Convention itself applies, State practice shows that the crime of corruption can be prosecuted by many national governments today on the basis of national law enacted following the commission of the offence and this law can be made retroactively.   There are many precedents of retrospective application of international law in several countries in matters concerning crimes against humanity, corruption and money laundering. For instance, in the case of Regina v. Imre Finta in Canada, a trial for "crimes against humanity" was carried out on the basis of a 1 987 Canadian statute that permits retrospective application of international law. Therefore, if the U.K and Nigerian laws allow retroactivity of its anti-corruption law, the Convention can not be a barrier to its implementation.

In conclusion, the Convention is also arguably a jurisdictional statute which does not establish new crimes. The United States Supreme Court faced with the question whether a jurisdictional statute may be applied retroactively has held that a statute which confers jurisdiction may be applied retroactively where it does not interfere with a party’s substantive rights. Specifically, Landgraf v. USI Film Products considered whether the U.S Civil Rights Act of 1991 could apply retroactively.  

In deciding this issue, the Court delivered a new pronouncement on the retroactivity of jurisdictional statutes that a statute “does not operate ‘retrospectively’ merely bec ause it is applied in a case arising from conduct antedating the statute’s enactment, or upsets expectations based in prior law. Rather, the court must ask whether the new provision attaches new legal consequences to events completed before its enactment.”

The absence of express retroactive intent does not necessarily prevent the court from applying a statutory provision retroactively. The Supreme Court further explained: “While we have strictly construed the Ex Post Facto Clause to prohibit application of new statutes creating or increasing punishments after the fact, we have upheld intervening procedural changes even if application of the new rule operated to a defendant’s disadvantage in the particular case.” To this effect, the Court noted that jurisdictional and procedural rules may apply retroactively because they regulate ‘secondary’ rather than ‘primary’ conducts. In such situations, the Court held that “present law normally governs.”

Kayode Oladele is a U.S based international law attorney