Part I — Situation overview

On 19 August 2026 the Central Investigation Department of the Criminal Directorate General of the National Tax and Customs Administration (NAV) closed, for want of a criminal offence, the criminal proceedings opened on suspicion of money laundering in the so-called gold-convoy case. According to the reasoning of the closing decision, the seized banknotes and precious metals originated from an interbank transaction between Raiffeisen Bank International AG and the Ukrainian state savings bank, JSC Oschadbank; Raiffeisen substantiated the origin and the payment of the purchase price with documents, and no doubt arose regarding the lawful source of the assets. NAV had already suspended the investigation in July; the closure required the arrival of the still-missing reply from the Austrian investigating authority, which confirmed the regularity of the documentation of the sale.

The antecedent is 5 March 2026: units of the Counter-Terrorism Centre (TEK) stopped, at a rest area of the M0 motorway, two armoured vans owned by Oschadbank which were transporting 40 million dollars, 35 million euros and 9 kilograms of gold — a total value of more than 27 billion forints — from Raiffeisen in Vienna to Ukraine. The seven-member, unarmed crew was detained for more than a day and then expelled. The complainant was the Constitution Protection Office (AH), one of the Hungarian secret services; a prosecutor later established that AH had not substantiated with adequate data the facts pointing to a national security risk. On 10 March a government decree was also issued stating that the legal title of the seized assets could not be clarified on the spot. According to the report of Telex, the raid and its timing were decided by the prime minister of the time; a photograph of a prosecution document from June that came into the possession of 444.hu named, first among the persons “taking the substantive decision or giving the instruction”, Viktor Orbán, alongside him former national security state secretary Örs Farkas, former TEK director general János Hajdu and Tamás Demeter, former deputy head of NAV for criminal affairs. The institutional after-effects of the case continue to this day: Pál Fürcht, head of the Central Chief Prosecutor’s Investigation Office, resigned in June citing a professional dispute with the Prosecutor General’s Office, followed by Prosecutor General Gábor Bálint Nagy; the Budapest Investigative Prosecutor’s Office interrogated János Hajdu as a suspect for the crime of unlawful detention; and NAV withdrew the mandates of two of its executives concerned.

An important point of public-law precision, because everyday press language regularly blurs it: the investigation was closed by NAV as an investigating authority, not by a court and not by the prosecution service. The prosecution service is an autonomous constitutional organ, the holder of public prosecution (Article 29 of the Fundamental Law), and in this case its act was the designation of the investigating authority — what Pál Fürcht objected to was precisely that the criminal case on which the designation was built had come about through the deception of the secret service. MIAK’s reading is therefore not that “the previous government has been exposed”. The closing of an official procedure is in itself a routine event; the policy content is that the same administrative discretion — the freedom of assessment with which an authority decides whether to open and to continue a procedure — can become an instrument of power technique, and that this discretion is in the hands of the present government at exactly the same point where it was in the hands of the previous one. The character of the problem is thus not personal but structural: a decision point has remained unregulated and invisible.

Part II — Foundations in the literature

Before turning to MIAK’s proposals, it is worth putting down the conceptual framework in which the problem of administrative assessment can be formulated at all. Robert Klitgaard (an American economist, one of the founders of the institutional analysis of corruption) gave the best-known formula of the domain in his 1988 volume Controlling Corruption: corruption flourishes where a monopoly position and freedom of assessment meet weak accountability — in the Hungarian procedure all three terms were present, and it was precisely the third that was missing. The work Corruption and Government by Susan Rose-Ackerman (an American lawyer-economist, the leading author of the institutional school of corruption research) adds the most important counterweight to this: an independent anti-corruption authority is useful only as long as it cannot be used for political purposes — that is, the guarantees for MIAK’s own Singapore-modelled office proposal are prescribed by the literature itself. And the proposition of the book Spin Dictators by Sergei Guriev and Daniel Treisman (an economist and a political scientist, describers of modern autocracies built on information manipulation instead of open repression) answers why a change of persons is not enough: monopolising power often requires not illegal instruments but the abuse of the legal ones. The detailed treatment of the literature — author by author, with quotations — can be found in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures, none of which is about who acted correctly in a concrete case — all three are about making the next such decision visible.

3.1 A procedural statistics module on the criminal data platform (within 12 months)

MIAK asks that the investigating authorities — the Criminal Directorate General of NAV, the National Police Headquarters and the investigative prosecutor’s offices — publish quarterly, in aggregated and machine-readable form, the procedural statistics of cases of public concern: the number of procedures opened, suspended, closed and brought to indictment, broken down by case type, together with the duration of the procedures. This module should be made a mandatory part of the KB1 criminal data platform, with the same time-series logic that the programme point already prescribes for crime types. The request deliberately does not concern individual cases: we are not asking for investigation files but for ratios. In Klitgaard’s C = M + D − A framework (see 6.4.1) this strengthens precisely the A term, accountability, without taking away the D term, professional assessment — the authority continues to decide freely, only the aggregate pattern of the decisions becomes visible. If it turns out from the data thus published that the closure rate or the throughput time of cases of public concern differs systematically from that of similarly weighty but politically neutral cases, that is in itself an analysable signal — today, however, this comparison simply cannot be made.

3.2 An ethical limit on political communication built on a running procedure (in the next review of the code of ethics)

The second proposal concerns the self-restraint of the political leadership, and it is not at the level of legislation but at the level of a code of ethics: a claim built on the content of an ongoing investigation should not be a campaign instrument. This is not about a prohibition on information, but about the fact of the official procedure and the political conclusion drawn from it being separated from each other. The practical yardstick is simple: as long as there is no indictment in a procedure, a representative of the executive power should make no statement suggesting guilt about the subject of the procedure, and should not link it to the financing of a political competitor. This rule is the natural complement of the A6 checks and balances programme point, and it can also be made a measurable indicator of the A9 spin-dictatorship prevention index. It is important that the limit be symmetrical: it applies to the present government just as to the previous one — the Guriev–Treisman proposition (see 6.4.3) is precisely about the fact that abuse typically happens with legal instruments, that is, with instruments available after a change of government as well.

3.3 The guarantee package of the independent corruption investigation office (together with the preparation of the legislation)

MIAK’s A10 programme point proposes an independent corruption investigation office on the Singapore model, following the logic of the Corrupt Practices Investigation Bureau (CPIB). The lesson of the gold-convoy case also shows that this proposal cannot be written out without guarantees: an office with strong investigative powers holds the same discretion that we are now criticising. MIAK therefore asks that three mandatory elements be built into the preparation of the establishment of the office: a two-thirds parliamentary confirmation of the appointment of its head and a fixed, non-interruptible term of office; a mandatory, public annual report which also contains the ratios of the investigations opened and closed; and the possibility of reviewing the decision to open an investigation before an external panel of judicial composition. This package responds directly to the risk named by Rose-Ackerman (see 6.4.2), and fits the logic of the KB7 anti-corruption internal supervision reform and of the I4 protection of judicial independence.

The three proposals are bound together by one common principle: freedom of assessment should not be taken away but made visible. Procedural discretion is necessary — without it the authority could not make a professional decision. What turns it into an instrument of power technique is not the existence of discretion but the fact that its use cannot be reconstructed even afterwards. The statistics, the ethical limit and the guarantee package supply the same missing term that Klitgaard’s formula carries with a negative sign.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Rule of law The pattern of opening official procedures becomes comparable; the political cost of arbitrary proceedings rises The ratios can be misinterpreted without context: a high closure rate may also mean careful screening, not only unfounded openings
Public administration The quarterly data provision forces the investigating authorities into regular internal review Administrative burden and indicator-tuning: the recategorisation of statistically sensitive cases to avoid a bad figure
Political competition The ethical limit reduces the campaign value of ongoing procedures, and with it the pressure to open procedures The limit can be framed as an attempt at censorship; its credibility stands or falls on whether it applies to the government as well
International perception Procedural transparency directly improves the assessment of the quality of governance (World Bank WGI 2024, rule of law: +0.35) In the short term the indicators may even deteriorate because of the cases uncovered — uncovering statistically worsens the picture first

The main trade-off is between publicity and the interest of the investigation. Too fine a breakdown of the procedural statistics may make individual cases identifiable, endangering ongoing investigations; too coarse a breakdown, on the other hand, is uninterpretable. The practical solution is that the breakdown should be by case type and duration, allowing identification neither by territory nor by actor, and that fresh, ongoing cases should be included with a one-quarter delay. The proposal tips to the risk side if the purpose of publishing the statistics imperceptibly slides into performance measurement: if the authority starts to be evaluated for its closure rate, it will avoid precisely the professional screening, and will rather carry through procedures that ought to be closed. The purpose of the indicator is therefore expressly pattern-watching, not ranking — this intention has to be stated in the statutory authorisation itself.

Part V — Measurability and summary

5.1 What is worth following? (proposed KPIs)

The performance indicators below (KPIs, Key Performance Indicators) will show in 12 and 24 months whether the proposal has become a working practice. These are proposed yardsticks, not government commitments.

  • The procedural statistics module live: by the end of 2027 the numbers of openings, suspensions, closures and indictments in cases of public concern should be accessible with quarterly updates in machine-readable format — today no investigating authority publishes such data.
  • The written form of the ethical limit: by mid-2027 the code of ethics of the executive power should contain the prohibition of claims of guilt built on a running procedure, in an enforceable formulation.
  • The guarantee package in the bill: if a submission on the corruption investigation office is prepared, the presence or absence of the appointment, reporting and review guarantees in it is in itself measurable.
  • The dispersion of the closure rate: from the second year of data publication it is worth watching whether the closure rates of the public-concern and the politically neutral case groups converge.

5.2 Summary

MIAK’s request to the decision-maker in this case is not the pronouncement of responsibility — that is the business of the ongoing procedures — but three concrete steps: build the procedural statistics module into the criminal data platform; write down as an ethical rule the prohibition of campaign claims built on a running investigation; and submit the planned corruption investigation office together with the guarantee package. And towards the public, a request concerning attitude: this case will be closed when what emerges is not that “the other side was at fault”, but that the unregulated decision point has become regulated.

Two MIAK foundational values are directly at stake here. Accountability, because administrative assessment is today the point at which the exercise of power cannot be reconstructed even afterwards — and no one can be held responsible for what cannot be reconstructed. And being ideology-free, because the proposal presented here would constrain the present government in exactly the same way as the previous one: MIAK is not asking that discretion be placed in good hands, but that it should not be invisible in any hands.

Part VI — Reasoning and further sources

6.1 The press framing by spectrum

The left-liberal band framed the official decision as evidence of the collapse of the campaign narrative, and pushed the emphasis towards the chain of responsibility. Telex published the legal reasoning of the closure in detail, then arranged the antecedents of the case — the political route of decision behind the raid, the prosecutorial finding on the unsubstantiated complaint of the Constitution Protection Office — into a chronology. 444.hu built the same thread onto its own earlier revelations: it presented the document photograph, the internal NAV report and the investigative development about the suspicion against János Hajdu as one coherent sequence of events. HVG highlighted the expert reading: in its analysis a criminal lawyer spoke about the fact that the procedure could not even have been ordered, and the paper devoted a separate piece to the evidentiary situation the closure creates in the procedure running for unlawful detention.

The public-affairs and the economic band chose a narrower, fact-reporting frame. 24.hu published the legal reasoning and the chronology without commentary, while Portfolio highlighted the conclusive character of the decision and put the order of magnitude of the assets (more than 27 billion forints) at the centre — the economic band typically looks at the case from the financial and banking dimension of the seizure, not from the question of the branch of power.

The conservative band did not put the topic in focus in today’s issues: on the front pages of Magyar Nemzet and Mandiner the day’s leading threads were the evaluation of the government’s first hundred days and the transformation of the public media. This absence is in itself part of the framing: the emptying out, by an official decision, of the central claim of a campaign is a fact whose discussion would also override the earlier narrative. A methodological note: no valid article reference could be extracted from today’s front page of Index, and the headlines of Népszava were accessible without article URLs — therefore we state nothing about their framing in this section.

6.2 Facts and data

Datum Value Source
The date of the seizure 5 March 2026 Telex, 444.hu, 24.hu
The seized assets 40 million USD + 35 million EUR in cash + 9 kg of gold (more than 27 billion forints) 444.hu, Portfolio
The crew concerned 7 Ukrainian citizens, unarmed, detained for more than a day, then expelled 444.hu
The suspension of the investigation July 2026 NAV announcement, Telex
The closure of the investigation 19 August 2026, for want of a criminal offence NAV announcement, Telex, 24.hu
Hungary’s governance quality indicators rule of law: +0.35; control of corruption: −0.17 World Bank WGI 2024

The last row of the table gives the international scale of the case: the Hungarian rule of law indicator is positive, the control of corruption indicator is negative. The gap between the two is precisely the area covered by the lack of regulation of procedural discretion — the legislation is formally in order, the predictability of its application is not.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — the accountability of administrative assessment is a question of checks and balances: A6 institutional independence index, A9 spin-dictatorship prevention index, A10 independent corruption investigation office;
  • Public security and law enforcement (programme points) — the technical carrier of the procedural statistics is the KB1 criminal data platform, the internal control side is KB7;
  • Justice (programme points) — the reviewability of the decisions of the investigating authority and the strengthening of judicial control along the axis of I1 and I4;
  • Justice (background material) — the delimitation of the public-law position of the prosecution service and the investigating authorities, without which the topic cannot be described accurately.

6.4 Literature in detail

6.4.1 Robert Klitgaard: Controlling Corruption

Klitgaard’s analytical framework fits here because it examines not the intention of the actors but the structure of the decision situation. The volume derives the phenomenon from the coincidence of three factors, and records this in a stylised equation:

“Illicit behavior flourishes when agents have monopoly power over clients, when agents have great discretion, and when accountability of agents to the principal is weak. A stylized equation holds: CORRUPTION = MONOPOLY + DISCRETION − ACCOUNTABILITY.”

The other, directly parallel layer of the volume is the case study of the cleaning up of the Philippine tax authority (Bureau of Internal Revenue). Klitgaard shows that of the three pillars of the reform conducted there, the second was to gather information about the abuse itself — and that the purpose of this was not primarily detection but deterrence: when the staff of the office recognised that their decisions could be reviewed, their behaviour changed. In the case of the gold convoy this means that MIAK’s statistics proposal is not directed against the investigators but fits precisely into the mechanism Klitgaard describes: the freedom of assessment remains, but its pattern comes before the public, and that in itself is already disciplining. The Hungarian situation is graver than the case described in that here the question was not the internal integrity of the office but its external instrumentalisation — the A term of the formula, however, is the same in both cases.

📖 Source: Robert Klitgaard: Controlling Corruption

6.4.2 Susan Rose-Ackerman: Corruption and Government

Rose-Ackerman’s volume systematises international institutional experience, and from the point of view of the Hungarian proposal it contains the most important warning. Analysing the success of the Hong Kong and Singapore anti-corruption offices, the author also records the condition:

“A tough, independent anticorruption agency can be a potent tool so long as it represents a credible long-term commitment and can avoid being misused for political ends.”

To this she adds the institutional risk of the Hong Kong example: the office created there was subordinated exclusively to the governor under British rule, and according to the author an anti-corruption commission subordinated to an autocratic leader may become an instrument of repression against political opponents. This is the direct critical reading of MIAK’s A10 programme point: the programme point envisages the Singapore office as subordinated to the prime minister but operationally independent, and also proposes reversing the burden of proof in the case of unjustified enrichment. The gold-convoy case has shown how easily an official procedure turns into a political instrument — therefore in point 3.3 MIAK does not propose the withdrawal of the programme point, but a guarantee package tailored to the risk named by Rose-Ackerman: a two-thirds appointment, a mandatory public report and external reviewability of the opening of an investigation.

📖 Source: Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform

6.4.3 Guriev and Treisman: Spin Dictators

The main proposition of the volume is that modern authoritarian governance rests primarily not on open repression but on the manipulation of information and the systematic exploitation of formally lawful instruments. The authors summarise this mechanism tersely:

“Dictators do not always have to use illegal means to monopolise power, it is often enough for them to abuse the legal ones.”

The book lists as examples the instrumentalisation of defamation and libel laws, of judicial assessment and of official procedures, and also discusses the Hungarian media consolidation as a concrete case. In the present case this framework explains why a change of persons is not a sufficient answer. The procedure formally started on the lawful route: there was a complaint, there was an act of designation, there was an investigating authority. The abuse consisted not in breaking the rules but in the use of the space for assessment provided by the rules — and this space remains exactly as wide after a change of persons. Hence MIAK’s point 3.2: the ethical limit has to be symmetrical, because the mechanism is tied not to one actor but to an institutional possibility.

📖 Source: Sergei Guriev – Daniel Treisman: Spin Dictators

6.5 International comparison

Of the operative implementations of the Klitgaard framework, two are relevant to the Hungarian proposal. In the United Kingdom the parallel system of police recorded crime and of the population victimisation survey (Crime Survey for England and Wales) makes possible exactly what MIAK asks for in the case of procedural data: from the comparison of two mutually independent data sources the difference itself becomes analysable information. This model can be transferred to the practice of opening procedures: if, alongside the authority’s own statistics, the number of remedies and complaints is also public, then the gap between the two signals the systemic problem.

The second case, instructive from the side of guarantees, is Hong Kong. The institutional design of the Independent Commission Against Corruption (ICAC) created there contained three elements that also recur in MIAK’s proposal: the office was not subordinated to the police, its staff could not be seconded to other bodies, and no one could come under a superior whom they had previously investigated. At the same time, it is precisely this case that also supplies the counter-example: the reporting line ran to a single decision-maker, and according to the literature this left the possibility of institutional abuse open. The Hungarian preparation should therefore take over the organisational elements of the Hong Kong model, but not its reporting structure.

Transparency and anti-corruption policy

  • A6 — Strengthening checks and balances
  • A9 — Spin-dictatorship prevention index
  • A10 — Independent Corruption Investigation Office (CPIB model)

Public security and law enforcement

  • KB1 — Criminal data platform
  • KB7 — Anti-corruption internal supervision reform

Justice

  • I1 — Judicial transparency
  • I4 — Protection of judicial independence
  • I9 — Popular-sovereignty audit

Proposed new programme point: Procedural discretion statistics and an ethical limit on communication built on a running investigation — for the Transparency and anti-corruption policy area.

6.7 List of sources

Press sources (MIAK press monitor, 20 August 2026 — topic 1):

  • [Telex] A NAV bűncselekmény hiányában megszüntette a pénzmosás miatti nyomozását az ukrán pénzszállítókkal szemben — https://telex.hu/belfold/2026/08/19/a-nav-buncselekmeny-hianyaban-megszuntette-a-penzmosas-miatti-nyomozasat-az-ukran-penzszallitokkal-szemben
  • [Telex/EN] Investigation into money laundering allegations against Ukrainian cash couriers in Hungary closed by tax authority — https://telex.hu/english/2026/08/19/investigation-into-money-laundering-allegations-against-ukrainian-cash-couriers-closed-in-hungary
  • [HVG] Megszüntette a NAV a nyomozást az aranykonvojügyben, nem volt pénzmosás, amire Orbánék hivatkoztak — https://hvg.hu/itthon/20260819_nav-nyomozas-aranykonvoj-penzmosas-kampany-orban-kormany
  • [HVG] A NAV döntésével romlottak a volt TEK-főigazgató és a felbujtó esélyei az ukrán aranykonvoj ügyében — https://hvg.hu/360/20260819_nav-ukran-penzszallito-nincs-buncselekmeny-penzmosas-felbujto-rogan-antal-orban-viktor
  • [24.hu] Aranykonvojügy: a NAV megszüntette a pénzmosás miatt indult nyomozást — https://24.hu/belfold/2026/08/19/aranykonvoj-ugy-nav-nyomozas-megszuntetese/
  • [444.hu] Bűncselekmény hiányában megszüntette a nyomozást a NAV az ukrán pénzszállító ügyében — https://444.hu/2026/08/19/buncselekmeny-hianyaban-megszuntette-a-nyomozast-a-nav-az-ukran-penzszallito-ugyeben
  • [Portfolio] Bűncselekmény hiányában megszűnt a nyomozás az ukrán pénzszállítók ügyében — https://www.portfolio.hu/bank/20260819/buncselekmeny-hianyaban-megszunt-a-nyomozas-az-ukran-penzszallitok-ugyeben-857326

Knowledge base references (literature):

  • 📖 Robert Klitgaard: Controlling Corruption
  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform
  • 📖 Sergei Guriev – Daniel Treisman: Spin Dictators

Note: the local file path of the books does not appear in the visible text of the blog — only the author and the title. The file path is an internal matter of the generation process, not the reader’s.

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point IDs: A6, A9, A10)
  • MIAK policy area: Public security and law enforcement (programme points; programme point IDs: KB1, KB7)
  • MIAK policy area: Justice (programme points; programme point IDs: I1, I4, I9)
  • MIAK policy area: Justice (background material)
  • MIAK press monitor, 20 August 2026 — topic 1, score: 90/100

Supplementary public data sources:

  • World Bank Worldwide Governance Indicators 2024 — rule of law, control of corruption (Hungary)
  • Crime Survey for England and Wales (Office for National Statistics) — the reference model of parallel criminal data collection

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