Structural Considerations in Anti-Corruption Frameworks

International anti-corruption frameworks have significantly contributed to the formalisation of corruption as a global legal and policy category, establishing common definitions, normative standards and evaluation mechanisms. This development has largely been grounded in the extension of general criminal law logic, whereby corruption is addressed through the typification and sanctioning of individual conduct. This paper argues that this analytical configuration gives rise to a structural limitation. While legal frameworks focus on conduct-based definitions, they simultaneously recognise that corruption produces broader institutional, economic and social consequences. This duality generates a structural gap between the level at which corruption is defined and the level at which its most significant effects become observable. Drawing on a comparative analysis of major international frameworks—including those of the United Nations, the Inter-American system, the European Union and the Council of Europe—the paper shows that this gap is not framework-specific but constitutes a transversal feature of contemporary anti-corruption systems. The analysis suggests that certain systemic dynamics may remain only partially captured by approaches centred on individual conduct, particularly where effects emerge through cumulative processes, institutional configurations or aggregate outcomes. In response, the paper proposes the analytical relevance of incorporating a structural perspective as a complementary layer of analysis. Such an approach may enhance the interpretation of evaluation results, measurement indicators and institutional performance without altering existing normative frameworks. While the paper remains strictly analytical, it also indicates that the identification of this structural gap may open avenues for future research on the alignment between legal definitions and systemic consequences.