Asia Pacific (APAC) countries continue to “stagnate” in their rankings in 2023, only minimally above the global average, with most well below, according to two anti-corruption due diligence tools, TRACE’s 2023 Bribery Risk Matrix (TRACE Matrix) and Transparency International’s 2023 Corruption Perceptions Index (TI CPI). While the two ranking systems share the same view of the least and most risky countries, the TRACE Matrix presents a slightly more positive view overall, ranking most Asia Pacific counties as moderate risk. In contrast, the TI CPI ranks most as being high risk. When considered together, the two systems allow for a more complete and accurate view of the risks and opportunities offered in the APAC region based on their different methodologies and factors.  

TRACE considers just a quarter of the countries in the region to be high to very high risk, but two thirds are at least moderate risk. However, for the TI CPI, the average score of APAC countries was above the global average score (45 versus 43, as for the past four years), with more than half perceived as high to very high, hence TI’s description of the region’s scores as stagnating. The 2023 TRACE Matrix publication packet is available at https://www.traceinternational.org/trace-matrix, and the 2023 TI CPI is available at https://www.transparency.org/en/cpi/2023.

Although these tools offer a good starting point for assessing risk, they are not a substitute for adequate risk-based due diligence on counterparties in the region. Notably, many international bribery cases involve companies headquartered or conducting business operations in jurisdictions with very low-risk rankings. This is probably because their anti-corruption efforts support the investigation and prosecution of bribery. Countries with no track record of meaningful enforcement against their own companies for overseas bribery should be closely reviewed for bribery and corruption risks. These bribery risk tools should also be supplemented with other publicly available reports on money laundering and bank secrecy risks, as these are also indirect indicators of bribery and corruption risk.

Summary

High and Low: As in 2022, both the TRACE Matrix and the TI CPI rank New Zealand, Australia, and Japan among the countries in the APAC region with the lowest risk of corruption. However, the TI CPI also includes Hong Kong and Singapore in that category. At the same time, the TRACE Matrix ranks those two countries slightly lower, though still low risk, because the TRACE Matrix includes an analysis of media freedom and civil society engagement. Both rank North Korea as the riskiest in the region but also place Cambodia, Afghanistan, and Myanmar towards the bottom.   

Decliners and Improvers: There was significant movement in the TRACE Matrix rankings, including a decline of 36 places for India and an improvement of 29 places for Pakistan, which moved the latter from high to moderate risk. Cambodia slightly improved by a point, moving it from very high to high.  

Overall, while the TI CPI remarks on some declines in some scores of 1-4 points, the rankings and scores remain largely stable. Only the Maldives and India dropped to high risk from moderate risk as a result of a 1-point drop in their scores.   

In looking at the results of both tools, as illustrated in the chart below, there are a few directional inconsistencies. For example, China’s ratings illustrate the directional inconsistencies between the TRACE Matrix and the TI CPI, as the TRACE Matrix showed some improvement in rank. Still, the TI CPI showed a decline in China’s score and ranking. Similarly inconsistent was Indonesia (improving on the TRACE Matrix but declining on the TI CPI), as well as Vanuatu, Sri Lanka, Solomon Islands, the Maldives, the Philippines, Myanmar, and Bangladesh. The inconsistencies are explained by the different methodologies used to compile the data.

Methodologies

Both the TRACE Matrix and the TI CPI evaluate performance and assign a score between 1 and 100 to every country and jurisdiction, and then assign a rank based on the score. For the TRACE Matrix, a high score translates to a high-risk rank, but for the TI CPI, the risk score is inverse to the risk rank. For example, the least corrupt APAC country on both charts, New Zealand, is ranked second worldwide on the TRACE Matrix and third place globally on the TI CPI but got a score of 10 on the TRACE Matrix and 85 on the TI CPI (a decrease of one rank and two points on the TI CPI from 2022). In contrast, the country at highest risk, North Korea, is ranked 194 on the TRACE Matrix and 172 on the TI CPI but received scores of 92 and 17, respectively.

Another key difference to keep in mind is that the TI CPI measures perceptions of public corruption, while the TRACE Matrix also includes commercial bribery and business risk. The TRACE Matrix publishes scores for four corruption indicators, including the opportunity for bribery (government interaction, expectation, and leverage), deterrence (dissuasion and enforcement), transparency (government and civil service), and oversight (free press and civil society), together which provide granularity for interpreting the measurements.

Jurisdictions of Note

China stayed static in its score on the TRACE Matrix but moved up 4 places in the rankings and has improved its overall risk rating over the last several years. However, on the TI CPI, it slipped below the average for the APAC region (45), slowing its upward trajectory from past years.

Hong Kong SAR continued to decline on the TRACE Matrix by 3 points on its score and 6 ranks, though staying at low risk. TRACE explains that the decline in Hong Kong’s media freedom/quality and civil society engagement contributed to the continued decline. It declined a point in its score and two places in its ranking on the TI CPI, still ranking very low in corruption risk.  

Conclusion

The TRACE Matrix and the TI CPI continue to be useful tools for a preliminary evaluation of the general risk of corruption in foreign jurisdictions. Even though the APAC region saw no overall movement in the TRACE Matrix and the TI CPI in 2023, both TRACE and TI note concern about the region’s slow progress and lack of transparency in some more authoritarian regimes. Companies operating in the region should remain cautious of corruption in certain jurisdictions and should take a flexible and tailored risk-based approach and use due diligence and other compliance procedures to assess risks associated with their ventures.

Even if a country is headquartered in a relatively low-risk jurisdiction, it does not mean there is a low risk of the counterparty engaging in bribery and corruption. There are countless cases of companies from low-risk jurisdictions engaging in misconduct when operating overseas. Therefore, in order to truly understand counterparty risk, it is fundamental to understand the company’s compliance program and internal controls and its reputation in the market where the business will be conducted rather than just its global reputation.