Introduction
The United Nations Convention Against Corruption (UNCAC) defines itself as “the only legally binding universal anti-corruption instrument,” designed to promote global cooperation on anti-corruption measures ranging from legislative transparency to international peer review mechanisms. Central to the implementation and credibility of the UNCAC is the active involvement of civil society organizations (CSOs), whose participation is managed through the UNCAC’s biennial Conference of States Parties (CoSP). The UNCAC Coalition—a global network of NGOs focused on anti-corruption—has long championed the involvement of CSOs as essential to ensuring government accountability and preventing corruption.
Participation of CSOs in CoSPs is governed by the UNCAC Rules of Procedure, namely Rule 17, which permits States to object to the accreditation of organizations anonymously. Between CoSP7 (2017) and CoSP10 (2023), multiple CSOs were barred from participation following such objections, often without any official justification, raising widespread concern within the UNCAC Coalition. These objections have increasingly been criticized as politically motivated attempts to stifle dissent or suppress scrutiny of domestic and international governance.
This article examines the history of objections to NGO participation in the UNCAC from 2017 to 2023, revealing how geopolitical conflicts and domestic political considerations—particularly involving Türkiye and Azerbaijan—have influenced states’ use of Rule 17 to exclude CSOs. These objections, often lacking transparency or due process, not only reflect geopolitical tensions such as Türkiye’s conflict with the Fethullah Gülen movement and Azerbaijan’s dispute with Armenia over Nagorno-Karabakh, but also undermine UNCAC’s stated goal of promoting inclusive and transparent anti-corruption efforts.
The exclusion of civil society organizations (CSOs) from UNCAC Conferences of States Parties (CoSPs) has raised significant concerns about censorship and the weakening of international anti-corruption efforts. Under Rule 17 of the UNCAC Rules of Procedure, states can object to the participation of CSOs without offering justification. These objections are difficult to overturn and often result in outright exclusion, despite CSOs playing a vital role in promoting transparency and accountability. The UNCAC Coalition has consistently emphasized that civil society engagement is “essential” and that “governments cannot face this scourge alone.”
The following CSOs received objections:
2017:
- K-Monitor, Hungary (Unknown objector)
- European Centre for Not-for-Profit Law, Hungary (Unknown objector)
2019:
- Bingham Centre for the Rule of Law, UK (Anonymous objector)
- International State Crime Initiative, UK (Anonymous objector)
- Expert Forum, Romania (Anonymous objector)
- Pakistan Institute of Legislative Development and Transparency, Pakistan (Anonymous objector)
2021:
- Access Info Europe, Spain (Objected to by Türkiye)
- Alliance on Civic Initiatives Promotion, Kyrgyzstan (Objected to by Türkiye)
- Central Asian Research Institute on Corruption and Money Laundering, Kyrgyzstan (Objected to by Türkiye)
- Expert Forum, Romania (Objected to by Türkiye)
- Integrity Initiatives International, USA (Objected to by Türkiye)
- The Good Lobby Italia, Italy (Objected to by Türkiye)
- Transparency International Georgia, Georgia (Objected to by Türkiye)
- Eurothink – Center for European Strategies, North Macedonia (Objected to by Türkiye)
- Libyan Transparency Association, Libya (Objection upheld; unknown objector)
2023:
- Transparency International Armenia, Armenia (Objected to by Azerbaijan)
- Freedom of Information Center of Armenia, Armenia (Objected to by Azerbaijan)
- Armavir Development Center, Armenia (Objected to by Azerbaijan)
Unfortunately, identification of all barred CSOs is extremely difficult; however, meaningful analysis can still be gleaned from the instances above that have been publicly identified by the UNCAC Coalition, UNCAC documents, or otherwise. Although the countries that object rarely state their reasons for doing so, examining the activity of barred CSOs in the timeframe between CoSPs, they were permitted to attend. The ones they were barred from reveal potential motivations for such objections.
CoSP11 will take place in December 2025. As such, any objections by State parties to this year’s Conference are likely to be levied soon. Although no objections have been made yet, the UNCAC Coalition appears wary of the potential for objections at CoSP11, making a specific note in their briefing slides that preventing exclusion via unjust objections was a primary goal of the UNCAC Coalition. As such, potential objections and the concerns they pose loom over civil society in the context of the UNCAC.
Given the role of geopolitics in many of the objections, it is important to understand the two key geopolitical issues that have led to objections against CSOs: the Fethullah Gülen movement as it pertains to Türkiye and the Nagorno-Karabakh conflict as it pertains to Azerbaijan. The Fethullah Gülen movement, or FETÖ as referred to by Türkiye, is a widespread social and political movement, with Mr. Gülen himself being a prior political rival of Turkish president Recep Tayyip Erdoğan. The Gülen movement will be explored further in the section dedicated to the objection against the Bingham Centre in 2019. The Nagorno-Karabakh conflict is a territorial and ethnic conflict concerning the Nagorno-Karabakh region, an ethnically Armenian territory located geographically within Azerbaijan. The Nagorno-Karabakh conflict will be explored in greater depth in the section concerning objections with geopolitical motivations, specifically in the objections against Armenian CSOs in 2023.
By analyzing publicly identified objections, this article categorizes them into three primary motivations: scrutiny of domestic governance, criticism of foreign states, and broader geopolitical retaliation. In the interest of brevity, only the most significant objections will be analyzed in full. While some objections remain opaque, the patterns that do emerge raise critical questions about the politicization of the UNCAC process and the weakening of international civil society participation just as the next CoSP approaches in December 2025.
Reason One: Domestic Anti-Corruption Efforts
An objection to a CSO based on its domestic anti-corruption efforts is considerably rarer than all other reasons behind an objection. Only one instance, the objection against Eurothink – Center for European Strategies (hereafter referred to as “Eurothink”) in 2021, fits into this category. However, the Eurothink objection highlights the extent to which domestic politics can affect CSO participation in the UNCAC.
Eurothink – Center for European Strategies (2021)
Eurothink is a non-political think tank, like many other CSOs, based in North Macedonia. The objection against Eurothink differs significantly from those against other organizations in 2021. Although the allegation remains the same—association with or support of the Gülen movement—the source of the Turkish government’s belief comes from an alleged blacklist rather than publications or statements by the organization. A search on Eurothink’s website yields no results for the term “Gülen,” indicating no publications or statements from the organization regarding the Gülen movement. However, the story behind the Eurothink objection is extensive.
In an interview conducted for this article on July 15, 2025, Dimitar Nikolovski, the Executive Director of Eurothink, spoke about the objection against Eurothink. Mr. Nikolovski stated that the objection surprised Eurothink, as the organization had no relation to the Gülen movement. Following the objection, Eurothink searched its website for materials regarding the Gülen movement (and the Turkish government) but found nothing. Instead, Mr. Nikolovski believed that the objection stemmed from Eurothink’s anti-corruption efforts in North Macedonia.
In 2015, North Macedonia became engulfed in a government wiretapping scandal, which Mr. Nikolovski said spurred significant anti-corruption efforts by Eurothink as the organization became active in a movement against the government’s involvement in the wiretapping scandal.
Following the 2017 scandal, the Romanian security and intelligence sector underwent a series of transformations aimed at promoting accountability and reducing the concentration of power within the sector. Eurothink experts were heavily involved in the working groups on the transformation, which is how Mr. Nikolovski believes Eurothink garnered unfavorable attention from certain North Macedonian government officials. One of these officials was the Intelligence Director, Dr. Zoran Ivanov, who subsequently left North Macedonia and was given a professorship in Türkiye. According to Mr. Nikolovski, Dr. Ivanov then likely provided a blacklist of NGOs to the Turkish government, with Eurothink being listed for its supposed support for the Gülen movement, which appears to be fabricated. Mr. Nikolovski stated that such an objection by Türkiye was emblematic of Dr. Ivanov’s desire for revenge against Eurothink for its role in the 2017 transformation of the Intelligence Agency.
Overall, the objection against Eurothink sheds light on the objections against all CSOs in 2021. The Eurothink objection suggest that the Turkish government did not search CSOs’ publications or perspectives for pro-Gülen sentiments, but instead relied on a blacklist of CSOs that were allegedly affiliated with or supporting the Gülen movement. Such an explanation also accounts for the objections against III and the Bingham Centre (as discussed below), for example, as those organizations were likely included on this blacklist despite no pro-Gülen materials having been published by them.
Reason Two: Anti-corruption Efforts Directed at Foreign Countries
Primarily, objections to CSOs due to anti-corruption efforts directed at foreign countries pertain to the objections levied by Türkiye, specifically those in which Türkiye alleged that a CSO supported the Gülen movement, but such support was absent in reality. The two objections that fall into this category—the objection against III in 2021 and the Bingham Centre in 2019—were both levied as a result of the organizations’ criticisms of the Turkish government and corruption in Türkiye, which appears to have been interpreted as support for the Gülen movement by Turkish officials. In other words, investigation of Turkish corruption—not statements in support of the Gülen movement—resulted in these organizations being objected to.
Bingham Centre for the Rule of Law (2019)
Political tension between the Turkish government and the Bingham Centre appears to have a significant basis in the Gülen movement, but not necessarily for the organization itself, which has not stated any support for the movement.
In 2015, the Director of the Bingham Centre, Sir Jeffrey Jowell, was one of the authors of a 95-page report that detailed abuses suffered by supporters of Fethullah Gülen in Türkiye. According to the report, followers of Fethullah Gülen, also referred to as the Gülen movement, subscribe to Gülen’s teachings, seeking “a commitment to interfaith dialogue, community service, making education accessible to all and the need to create bridges between the Muslim world and the West.” The Gülen movement is estimated to include millions of Turkish citizens.
In 2013, Turkish then-Prime Minister (and now President) Recep Tayyip Erdoğan, prominent politicians, and the politicians’ families were implicated in a significant corruption scheme. Erdoğan claimed that the scandal was the result of the supporters and followers of Fethullah Gülen attempting a “judicial coup” against the Turkish government. Subsequently, he began a series of crackdowns against the movement. Sir Jeffrey’s report and subsequent academic literature stemming from it highlight abuses and human rights violations against the Gülen movement and other actors in a highly critical manner, targeting the Turkish government. In 2016, a group within the Turkish military attempted and failed to overthrow Erdoğan’s government in a coup; Erdoğan quickly attributed the attempt to the Gülen movement, spurring further crackdowns.
A Turkish think tank, SETA (Siyaset, Ekonomi ve Toplum Araştırmaları Vakfı, or “Foundation for Political, Economic and Social Research” in English), would publish its own report in 2018, directly referencing Sir Jeffrey’s report as “openly anti-Turkish and pro-FETÖ.” Such a characterization is likely to have contributed to Turkey’s animosity towards Sir Jeffrey and the Bingham Centre as an organization, given Sir Jeffrey’s leadership position within the Centre.
Moreover, Sir Jeffrey was directly involved in legal efforts against the Turkish government. In 2018, the Turkish government alleged that three men in the UK were members of the Gülen movement and engaged in terrorist activities, requesting their extradition to Türkiye. The request was ultimately refused, with Sir Jeffrey called by the defense to testify. Among other topics, Sir Jeffrey testified that the request was politically motivated and that the defendants would suffer violations if sent to a Turkish prison. Sir Jeffrey’s testimony was successful, and the extradition request was denied. Additionally, the judge noted that he was persuaded by Sir Jeffrey’s testimony on the aforementioned topics. As such, there were numerous motivations for Türkiye to object to the involvement of the Bingham Centre in CoSP8, and the objection against the Bingham Centre in 2019, likely levied by Türkiye, may have stemmed from a combination of the above reasons.
Although the aforementioned animosity stemmed from alleged support for the Gülen movement, it is important to acknowledge that Sir Jeffrey’s report was not a statement of support for the movement, but rather an academic study into corruption in Türkiye and the abuses suffered by followers or allies of the movement. Significantly, this circumstance differentiates this objection from purely geopolitical objections (as explored in the subsequent section), as the objection against the Bingham Centre would be more accurately characterized as punishment for academic inquiry rather than a purely geopolitical maneuver.
Integrity Initiatives International (2021)
The reason behind the objection to Integrity Initiatives International (III) is likely rooted in III’s criticism of Turkish corruption, leadership, and government. In terms of the allegation of supporting the Gülen movement, not only has III not published materials in support of the Gülen movement, but a search for the term “Gülen” on III’s website yields nothing from their organization (apart from the statement below). However, III did post on social media regarding the objection in 2019, calling the objections “opaque and baseless.” In 2021, III made a statement mentioning the objection when discussing CoSP10 two years later. The relevant portion of that statement reads:
“Turkey objected to III’s participation, incorrectly alleging III has material on its website glorifying what it deems to be Gülenist terrorism, and the attempted coup in Turkey in 2016. III does not have any material on its website that praises Gülen, terrorism, or any coup attempt. There are articles on its website that criticize the Turkish government for attacks on the independence of the judiciary and other concerning erosions of the rule of law.”
The III’s criticisms of the Turkish government, therefore, are likely the true basis behind the objection. More specifically, Türkiye may have construed such criticisms as support for the Gülen movement, as there is an overlap between some of the criticisms levied by III and the apparent actions against supporters of Gülen as explored by other organizations (such as the aforementioned report by the Bingham Centre). The 2018 article by III lists Türkiye as one country that “exemplified…grand corruption flourish[ing].” III notes the imprisoning, threatening, and killing of journalists, as well as having “corrupt leaders” with “no free election” mechanism for their “replacement.” As such, because Gülen is not explicitly mentioned by III, the Turkish objection likely results from an interpretation of III’s criticisms of the Turkish government as in favor of the Gülen movement.
Reason Three: Geopolitical Pursuits
The largest category, at least by the number of objections, is CSOs that have been objected to due to geopolitical issues, including those unrelated to anti-corruption efforts. Namely, two major geopolitical issues that have led to objections against CSOs—the Gülen movement and the Nagorno-Karabakh conflict. Every Turkish objection appears to be rooted in either a demonstrated or stated effort against the Gülen movement. While links to the Gülen movement vary from credible to unlikely, links to terrorism—a major portion of Türkiye’s allegations—were contested by the accused organizations and various state parties and are unsubstantiated. This claim comes from Türkiye’s assertion that the Gülen movement is a terrorist movement (evidenced by the use of the term “FETÖ” in their allegations), which other states do not recognize as a terrorist group. The second geopolitical issue, the Nagorno-Karabakh conflict, has exclusively appeared in Azerbaijani objections to Armenian CSOs, as will be explored below. The 2019 and 2021 objections discussed in this section were levied by Türkiye, while the 2023 objections discussed were levied by Azerbaijan.
Transparency International Georgia (2021)
In response to an email inquiry, Transparency International Georgia (TI Georgia) believes that the objection levied against them was in response to their public defense of Mustafa Emre Chabuk, a professor at Demirel College in Georgia. In 2017, the Turkish government claimed that a series of Georgian schools, including Demirel College, had links to the Gülen movement, which the Turkish government deemed a terrorist organization. Additionally, the Turkish government claimed that Mustafa Chabuk specifically was a member of the Gülen movement and pursued a criminal case against him. An extradition case against Chabuk began, raising concerns among Georgian NGOs that, if extradited to Türkiye, Chabuk may be subjected to “political persecution, torture, inhuman and degrading treatment or punishment, and will have no access to [a] fair trial.”
In response, multiple Georgian NGOs called for the Georgian government and parliament to refuse to extradite Chabuk and to pursue reforms to prevent further “unlawful extraditions.” TI Georgia criticized the Georgian and Turkish governments for rights abuses and the “unjustified loyalty” of the former to the latter. TI Georgia stated that the Georgian government, despite its own laws to the contrary regarding political extradition, was politically subordinating to Turkish authorities, an act which another NGO claimed would damage Georgia’s political reputation and democratization process.
Given Türkiye’s allegation that the CSOs it objected to in 2021 represented a “serious security concern” and were related to the “Fethullah Gulen terrorist organization (FETÖ),” TI Georgia’s defense and support of Chabuk’s legal battle presents a strong potential reason behind Türkiye’s objection. Türkiye considered Chabuk a member of a terrorist organization; TI Georgia defended Chabuk and criticized the merits of the Turkish government’s case and hoped to prevent the Georgian government from extraditing Chabuk to Türkiye.
Transparency International Armenia (2023)
Armenia and Azerbaijan have extremely poor relations, effectively in conflict with one another since the dissolution of the Soviet Union over thirty years ago, with fighting stemming greatly from disputes over Nagorno-Karabakh (an ethnically Armenian region in Azerbaijan’s geographic territory). As such, statements by Transparency International (TI AM) against Azerbaijan or in support of Armenia are likely to have provided a basis for the Azerbaijani objection to TI AM. Indeed, TI AM has consistently criticized Azerbaijan, including publishing annual reports on “Anti-Armenian Xenophobia and Racism in Azerbaijan.” The 2021 report (published in February 2022), for example, opens with quotes from Andrei Sakharov, a Nobel Peace Prize laureate, about the importance of the protection of the Armenian people with a specific reference to the region of Karabakh. Given ANND’s claim that Azerbaijan’s objections were based (at least in part) on what Azerbaijan claims to be a national security issue concerning CSO support for Armenia, it can be reasonably inferred that the issues at hand leading to the objections are related to the Nagorno-Karabakh conflict.
The 2021 report—published between CoSP9 and CoSP10, during the timeframe in which an objection would have been made—is particularly notable. This report not only focuses on Nagorno-Karabakh as its main topic but also alleges that corruption in Azerbaijan has been used “as a tool to spread or cover up Armenophobic policies.” In this report, TI AM discusses large-scale money laundering operations involving prominent Azerbaijani politicians, claiming that Azerbaijan uses “corruption as a ‘statecraft’…to help achieve foreign policy goals.” TI AM concludes this section by discussing the interplay between corruption and the Nagorno-Karabakh conflict, implying Azerbaijani culpability.
In response to an email inquiry, TI AM claimed that Azerbaijan “has a determined and aggressive policy to isolate Armenia from various initiatives,” especially following the escalation of the Nagorno-Karabakh conflict in 2020. TI AM believes that Azerbaijan’s “motivation is mostly geopolitical to demonstrate its power and humiliate” Armenia. Therefore, even in the absence of the aforementioned report, it is also plausible that mere geopolitical pursuits motivated the objection against TI AM.
Freedom of Information Center of Armenia (2023)
Similar to TI AM, the Freedom of Information Center of Armenia (FOICA) has also published materials that are highly critical of Azerbaijani actions in Nagorno-Karabakh, which is likely the reason behind Azerbaijan’s objection.
In 2021, FOICA released a statement on the Nagorno-Karabakh conflict that was particularly critical of Azerbaijan. It refers to the Azerbaijani government as a “dictatorial regime,” characterizes the 2020 conflict as unjustified Azerbaijani aggression, and puts forward concerns of mistreatment, civilian casualties, and violations of Armenian sovereignty before calling for sanctions and other diplomatic actions against Azerbaijan.
Additionally, a statement by Shushan Doydoyan, the President of FOICA, who responded to an email inquiry on the matter, suggests further geopolitical motivations behind the objection. Ms. Doydoyan stated that Azerbaijani objections to the Armenian CSOs were “pure[ly] political initiative[s],” for which “the sole reason is our Armenian nature/status.” Such a statement aligns with prior Azerbaijani objections, as interpreted by ANND which alleged that support for Armenia served as the basis for Azerbaijani objections that year.
Conclusion
Though rare, the UNCAC objection process has become increasingly politicized. Out of hundreds of CSOs that have historically participated, only eighteen documented objections have occurred between 2017 and 2023—nearly all lodged by just two countries: Türkiye and Azerbaijan. While the objection mechanism was designed as a procedural safeguard, it has been used in ways that reflect broader geopolitical motives, often invoking vague national security concerns or alleged ties to terrorism—claims that are frequently contested and lack international consensus.
As CoSP11 approaches, past patterns suggest new objections are likely, particularly from the same states and on similar grounds. The recurring nature of these controversies indicates that geopolitical dynamics are no longer peripheral to UNCAC—they are embedded within it. Civil society participation, once seen as a cornerstone of UNCAC’s legitimacy, now faces increasing barriers shaped not by procedural neutrality, but by international rivalries.
Ultimately, the history of CSO objections reveals that geopolitics has become a defining factor in UNCAC participation. Unless transparency and accountability are strengthened in the objection process, UNCAC risks undermining its own goals by enabling states to suppress civil society under the guise of procedural formality.
- Rules of Procedure for the Conference of the States Parties to the United Nations Convention against Corruption, Rule 17. https://www.unodc.org/pdf/crime/convention_corruption/cosp/07-80230_Ebooke.pdf.
- Rules of Procedure for the Conference of the States Parties to the United Nations Convention against Corruption, Rule 17(2). https://www.unodc.org/pdf/crime/convention_corruption/cosp/07-80230_Ebooke.pdf.
- “FETÖ” is a politically charged way of referring to the Gülen movement, which considers the movement a terrorist organization.
- In this article, the term “FETÖ” will only be used when it appears as part of a quotation. All other instances of the “Gülen movement” mentioned will be referred to as such. “FETÖ” is an acronym of “Fetullahçi Terör Örgütü,” or “Fethullahist Terrorist Organization,” which presupposes the Gülen movement as a terror organization. No states but Türkiye and Pakistan recognize the Gülen movement as a terror organization. Therefore, for the purposes of this article, it will not be referred to as such.
- While the objections in 2019 were made anonymously on paper, Türkiye appears to be responsible for four of the objections, as alluded to by a United States representative two years later at CoSP9 in 2021. In 2021, Türkiye objected to eight CSOs. In the report of CoSP9 to the UNCAC, a US representative condemned the 2021 objections and then claimed that the “same State party” had also objected to four CSOs at CoSP8 in 2019. Therefore, it is highly likely that Türkiye was the anonymous objector for the four overturned objections in 2019.
- See para. 11.
- See para. 11.
- See para. 53.
- See para. 28.
