A/HRC/28/60 bribery cases that were solved through legal settlements showed that only 3.3 per cent (or US$ 197 out of the total value of settlements of nearly US$ 6 billion) was returned or ordered to be returned to the countries where the bribery had taken place, as monetary sanctions were mostly imposed in countries where the corrupt companies were headquartered.19 21. It should be stressed that the return of stolen assets is only the last step and is unlikely to result in the full recovery of assets stolen, as it is frequently very difficult to trace, freeze and finally return stolen assets in accordance with international and national legal provisions. Much more needs to be done on the supply side of illicit financial funds, to prevent illicit financial outflows leaving countries of origin and to combat noncorruption-based illicit financial outflows related to tax evasion and questionable tax avoidance schemes. Curbing tax-based illicit financial flows would, from a purely financial perspective, have the biggest impact on the fiscal space of States and their ability to realize social and economic rights and the right to development. III. Illicit financial flows and human rights 22. There are various connections between illicit financial flows and human rights: illicit financial outflows deprive Governments first and foremost of resources required to realize progressively economic, social and cultural rights. They also undermine efforts to build up effective institutions to uphold civil and political rights and the rule of law in the countries of origin. Third, business enterprises, including transnational business corporations, have to ensure that their tax planning strategies and policies not only adhere to national law, but also comply with international human rights norms. Fourth, whistle-blowers and reporting persons, media representatives and human rights defenders require effective protection based on international human rights standards and the United Nations Convention Against Corruption . Fifth, human rights and due process guarantees are essential to protect persons from undue allegations, undue removal from office, criminalization, freezing or confiscation of their assets or arbitrary deprivation of property or detention. Finally, human rights obligations of States should also inform the public management of returned assets to ensure that maximum available resources are directed to the realization of economic, social and cultural rights. A. Impact on social, economic and cultural rights 23. Illicit financial outflows divert resources intended for development and may undermine government efforts to provide basic services and ability to comply with their international human rights obligations. The diversion of resources due to illicit financial outflows reduce the “maximum resources” available to the countries of origin for the realization of economic, social and cultural rights (A/HRC/26/28, paras. 24–28). It would be improper to solely blame illicit financial flows for lack of compliance with human rights obligations. Failure to respect social, economic and cultural rights is frequently not exclusively due to unavailability of public funds. However, illicit financial outflows from developing countries and tax abuse in industrialized countries have clearly limited the fiscal space of governments to ensure the progressive realization of social, economic and cultural rights. 19 Jacinta Anyango Oduor and others, Left out of the Bargain: Settlements in foreign bribery cases and Implications for Asset Recovery (Washington, World Bank, 2014), p. 2. 9