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
• 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/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes inflated capex and schedule risk; opaque ownership applied in land structures; higher legal risk; delays due to disputes and social conflict; and reputational exposure if beneficiaries are hidden.
Decision Point
Before agreeing a term sheet and committing resources, establish a land acquisition plan with due diligence checks on stakeholders, including agents and intermediaries.
Mitigation Actions
• Confirm roles, approvals, and information controls before commitment to any land acquisition and resettlement plan
• Conduct enhanced due diligence on land intermediaries, agents, and related parties
• Require conflict-of-interests and beneficial ownership checks where feasible to stakeholders involved in land negotiations
• Require verification/audit rights related to payments and the identify of final beneficiaries
• Condition disbursements on an independent verification of land acquisition outcomes and suspend disbursements if irregularities or suspicious transactions persist
Mitigation Resources
Conduct integrity due diligence on land intermediaries, agents, related parties, and counterparties with access to confidential route, site, or right of way information; require beneficial ownership disclosure where feasible, use covenants and monitoring requirements, and trigger enhanced due diligence, audit rights, or suspension before approval, disbursement, or waiver where red flags remain.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Appoint an independent technical adviser to test whether route changes, land requirements, valuation assumptions, and compensation rules are justified and properly reflected in acquisition costs, and to flag anomalies that may indicate misuse of confidential route or site information.
Independent technical due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/independent-technical-due-diligence-and-monitoring/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes scalating acquisition and compensation costs; delays from land disputes and litigation; social tension and unrest; and loss of public trust in land governance.
Decision Point
Before approving land budget and compensation, authorise disclosure of the land acquisition plan (registry checks, valuation method, acquisition steps, and information controls).
Mitigation Actions
• Publish the budget available for land compensation and do not authorise budget increase
• Maintain a record of approvals related to land acquisition values and compensation, and publish correponding decision log
• Separate valuation, negotiation, and approval roles
• Require written justification and sign-off for deviations from standard valuation and compensation rules
• Monitor and identify unusual price movements and beneficiary patterns before a project becomes publicly known
• Pause land acquisitions and refer cases to independent oversight bodies for investigation when red flags emerge, documenting outcomes and corrective actions
Mitigation Resources
Verify compensation and payments linked to route, site, and right of way decisions through beneficiary checks, compensation registers, payment reconciliation logs, and review of unusual price movements or beneficiary patterns; investigate mismatches before payment.
Resettlement planning and grievance management — https://toolbox.infrastructuretransparency.org/resource/resettlement-planning-and-grievance-management-2/Publish and maintain public access to land acquisition plans, valuation methods, compensation decisions, and parcel-level registers with approval trails, disclosure logs, and reasons for material deviations, with only lawful redactions.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes community displacement and price inflation from speculative buying; opaque ownership on land negotiations; intimidation and retaliation risks when land issues are reported; and loss of trust in land decisions.
Decision Point
When project information starts circulating or land prices/ownership shift unusually near the proposed project expected location, request disclosure of land acquisition plans and the budget available for land compensation. Decide whether to (a) escalate through oversight channels, or (b) monitor while gathering evidence safely.
Mitigation Actions
• Document community observations of coercion, misinformation, and speculative buying
• Use access to information to request disclosure of land acquisition plans, the budget available for land compensation, land acquisition agreements, including status, valuation method, and compensation decisions
• Advocate for disclosure of project information based on recognised infrastructure data standards such as the OC4IDS
• Engage oversight bodies to raise credible concerns about land negotiations and transfers (use safe, confidential reporting and anonymisation where retaliation risk is material)
• Mobilise communities affected by land issues to raise concerns about poor project planning
Mitigation Resources
Request access to non-public route, land, and right-of-way decision records, such as route-change approvals, valuation notes, meeting records, or records explaining ownership changes, compensation decisions, or acquisition sequencing, so unusual ownership transfers, valuation anomalies, or unexplained decisions can be examined and raised through oversight channels.
Access-to-information and demand-side transparency — https://toolbox.infrastructuretransparency.org/resource/access-to-information-and-demand-side-transparency/Review publicly disclosed route, land, and right-of-way records at an early stage, including parcel-level registers, acquisition status, valuation methods, and compensation decisions; identify disclosure gaps, unexplained changes, or missing records, and raise concerns about non-disclosure with an oversight body.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/