Recent high-profile cases have focused attention on the transfer of assets abroad by heads of state and other senior officials from developing countries in amounts that far exceed their legitimate sources of income. Article 20 of the United Nations Convention against Corruption, criminalizing illicit enrichment, was drafted to address this issue. However, very few of the states parties to the UNCAC have introduced this offence in their legal systems, largely because of due process concerns. The challenge is to find ways to implement Article 20 that balance the rights of the accused with the right of society to recover illicitly acquired national wealth.