Phase 2: Financing & Appraisal

Insider trading in land and right of way (misuse of confidential route/site information)

Individuals with access to non-public route/site/right of way information misuse or leak it (directly or via intermediaries) to acquire land/rights or influence valuations/compensation, driving inflated acquisition costs.

Red Flags & Indicators

  • Shortly before a project becomes publicly known, there is an unusual concentration of land sales, speculative purchases, ownership transfers, or sharp increases in land values in or around the proposed project area.
  • Beneficial ownership is concealed through proxies, nominees, or shell entities, while ownership, transaction, or valuation records are incomplete, inconsistent, or difficult to verify.
  • Confidential information on proposed routes, sites, or land acquisition plans circulates outside authorised channels and coincides with price spikes, speculative purchasing, or unusual changes in land ownership.

Stakeholder Guidance

Stakeholder Exposure

Exposure includes inflated land and right of way costs and associated delays in securing land; anti‑bribery exposure; and reputational harm if linked to contested acquisition.

Decision Point

During land negotiations, approve route/site information release and appoint agents and valuers under controlled protocols, including conflict-of-interest and beneficial ownership checks.

Mitigation Actions

• Require a documented land acquisition plan and agree compensation principles beforehand
• Classify route/site information, and restrict access on a need-to-know basis
• Use secure sharing and non-disclosure agreements during land negotiations, and maintain a disclosure and contact log for any third-party releases of information
• Appoint land agents/brokers/valuers through documented selection and clear terms
• Require conflict-of-interests and beneficial ownership checks where feasible to stakeholders involved in land negotiations
• Ban/reject undisclosed commissions, and use traceable payments with a payment and beneficiary record
• Adopt a lobbying policy that sets clear limits on gifts and hospitality and applies to agents and intermediaries
• Monitor for speculative buying, or valuation anomalies before a project becomes publicly known
• Escalate and pause land negotiations when documentation is weak, leaks are suspected, or preferential access signals arise

Mitigation Resources

Require conflict-of-interest declarations and documented conflict management before sharing or acting on confidential route, site, or right of way information; exclude conflicted staff, advisers, agents, or valuers from the decision process until conflicts are resolved and documented, and record gifts, lobbying contacts, secondary roles, and revolving-door risks that could influence those decisions.

Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/

Screen land agents, brokers, valuers, advisers, and other counterparties linked to route, site, or right of way decisions; verify beneficial ownership, PEP, sanctions, and related-party risks, and escalate concerns or exclude parties where red flags remain.

Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/