How the IMF is Promoting Transparent and Accountable Use of COVID-19 Financial Assistance

February 17, 2021

COVID-19 is causing tragic loss of life and has disrupted economies and societies on a scale that we have not seen in living memory. The IMF is working closely with its members to meet their need for emergency financing, while sustaining its fight against corruption and the misuse of urgently needed resources. In this time of crisis, it is more important than ever to ensure that IMF financing is used to protect lives and livelihoods.

How does the IMF help countries improve governance and fight corruption?

In 2018, the IMF adopted a Framework for Enhanced Engagement on Governance. An interim assessment of its implementaiton show that, the IMF has had deeper and more candid discussions with member countries on reforms and issues related to governance and anti-corruption since the Framework was introduced. The discussions with country authorities take place through several channels:

  • Article IV consultations: IMF country teams analyze governance and corruption issues and provide clear policy advice to enhance good governance and address corruption vulnerabilities, including on combatting transnational corruption.[1] To date, more than 40 staff reports have dedicated in-depth annexes or Selected Issues Papers on these topics.[2]
  • Lending programs: Governance and anti-corruption-related conditionality is included when such vulnerabilities are critical to achieving the goals of the member’s program, including preventing the misuse of Fund resources.[3]
  • Governance diagnostics: IMF staff has begun conducting detailed diagnostic analyses that take a deep dive into governance weaknesses and make specific and prioritized reform recommendations to strengthen governance across a range of areas. To date, 10 such reports have been completed or are underway.[4]
  • Capacity development: The IMF provides extensive technical assistance and training in the areas of fiscal governance, financial sector oversight, central bank governance and operations, anti-money laundering measures, and anti-corruption frameworks. The IMF’s first training course on “Fighting Corruption” was delivered in November 2020 at its Africa Training Institute to about 70 senior government officials from 34 countries.
  • Research and outreach: The IMF has been implementing a broad agenda of analytical and research work on governance issues,[5] as well as a range of outreach activities to promote collaboration with other international institutions, academia, and CSOs on this topic.

How can the IMF help enhance transparency and accountability with its emergency financing in the time of COVID-19?

In the wake of the COVID-19 pandemic, the IMF maintains its commitment to address governance and corruption vulnerabilities in member countries. The IMF is working to balance the need for immediate COVID-19 financing against appropriate accountability and transparency to ensure, as best as possible, that financial help reaches those in need. IMF emergency financing is provided in upfront, outright disbursements. While there is less scope for traditional conditionality in the context of emergency financing, the IMF ensures its resources are used for their intended purpose by implementing the following:

1. Asking member authorities to commit in their Letters of Intent to ensuring that emergency assistance is used for the very urgent purpose of resolving the current crisis and not diverted for other purposes. Letters of Intent are published by the member country and the governance commitments are also published in a separate document available on the IMF’s ‘COVID-19 Financial Assistance and Debt Service Relief' website.

2. Identifying public financial management, anti-corruption, and anti-money laundering measures that countries can put in place without unduly delaying urgently-needed disbursements. For example, the IMF has asked member countries requesting emergency assistance to commit to (i) enhanced reporting of crisis-related spending; (ii) undertaking and publishing independent ex-post audits of crisis-related spending; (iii) ensuring procurement transparency by, for example, publishing procurement contracts; and/or (iv) preventing conflicts of interest and corruption by publishing the beneficial ownership information of firms awarded procurement contracts. Specific examples include the following:

  • In Papua New Guinea, the authorities have begun: (i) publishing details of awarded COVID-19-related procurement on the government procurement website (http://www.procurement.gov.pg/), including related beneficial ownership information and have committed to (ii) providing a consolidated report on procurement to the National Executive Council within three months of the end of the State of Emergency; and (iii) commissioning and publishing an audit by an independent and reputable auditor within one year of the end of the State of Emergency.
  • In Cameroon, the authorities have: (i) modified standard procurement forms to allow for the provision of the beneficial ownership information of companies receiving procurement contracts; (ii) begun publishing on the website of the Public Procurement Regulatory Agency, public procurement contracts awarded by the government and the beneficial ownership of companies receiving procurement contracts; (iii) begun publishing all COVID-19 related contracts awarded since May 2020, including related beneficial ownership information and committed to (iv) issuing a semi-annual report on COVID-19 related spending; and (v) commissioning an independent audit of this spending at the end of the 2020 fiscal year and publishing the results.
  • In Malawi, the authorities have begun: (i) publishing COVID-19-related procurement documentation and the names of the beneficial owners of the awarded companies on the Public Procurement and Disposal of Assets website (https://www.ppda.mw/#); (ii) publishing on the PPDA website the results of ex-post validation of delivery on a contract-by-contract basis; and committed to (iii) publishing quarterly statements on commitments and payments of COVID-19 related activities; (iv) publishing funding earmarked for COVID-19 related spending; (v) submitting quarterly audits of COVID-19 related spending by the National Audit Office to the Minister of Finance for submission to the Cabinet and (vi) publishing and submitting to Parliament a comprehensive audit of COVID-19-related spending
  • In Moldova, the authorities have committed to: (i) publishing information on crisis-related public procurement and beneficial owners of companies contracting with the government; (ii) continuing to enforce the anti-money laundering framework and asset declaration regime; and (iii) subjecting all crisis-mitigation spending to a dedicated audit by the Court of Accounts Chamber and making the report public.
  • In Nepal, the authorities have committed to publish online: (i) quarterly reports on COVID-19 related spending; (ii) the results of an independent audit of COVID-19 related spending by the Office of the Auditor General; and (iii) large public procurement documentation, together with ex-post validation of delivery, the name of awarded companies, and their beneficial owner(s).
  • In the Kyrgyz Republic, the authorities have committed to: (i) subject all procurement of urgently needed supplies to an ex-post audit by the Audit Chamber and publish the results online; (ii) publish online documentation on all direct procurement and bidding documents for competitive procurement; (iii) take the necessary measures within the government’s prerogative to publish ex-post validation of delivery along with the name of awarded companies and their beneficial owner(s) for all public procurement contracts; and (iv) ensure that the Independent Complaints Review Commission on procurement has sufficient means to operate by including its fees on the list of government payable services.
  • In Nigeria, the authorities have committed to: (i) strengthening the role of the Federal Audit Board in combating corruption and the asset-declaration framework; (ii) fully implementing the risk-based approach to AML/CFT supervision while ensuring the transparency of beneficial ownership of legal persons; (iii) creating specific budget lines to facilitate the tracking and reporting of emergency response expenditures and of funds released and expenditures incurred monthly on the transparency portal (http://opentreasury.gov.ng); (iv) publishing procurement plans and procurement notices for all emergency response activities—including the name of awarded companies and of beneficial owners—on the Bureau of Public procurement website; and (v) publishing no later than three to six months after the end of the fiscal year an independent audit into the emergency response expenditures and related procurement process, which will be conducted by the Auditor General of the Federation.

Similar commitments have been made in Afghanistan, The Bahamas, Bangladesh, Chad, Comoros, Djibouti, the Democratic Republic of Congo, Dominican Republic, Ecuador, Eswatini, Ethiopia, Egypt, Gabon, Guatemala, Guinea, Jamaica, Jordan, Lesotho, Liberia, Madagascar, Mali, Mauritania, Mongolia, Montenegro, Mozambique, Nicaragua, Pakistan, São Tomé and Príncipe, Sierra Leone, Solomon Islands, South Africa, South Sudan, St. Vincent and the Grenadines, Uganda, and Uzbekistan, among other countries.

3. Ensuring that emergency resources are subject to our “Safeguards Assessment” policy. These assessments involve a diagnostic review of the central bank's governance arrangements and legal framework, internal and external audit mechanisms, financial reporting, and control systems. They provide reasonable assurance to the IMF that a central bank's governance framework is adequate to manage resources, including IMF disbursements. Where there are shortcomings, IMF staff make time-bound recommendations and closely monitor their implementation. Given that emergency financing is provided upfront, such assessments will be conducted after the disbursement, but before the approval of any subsequent financing under a more traditional multi-year financing arrangement.

4. Continuing to include governance and anti-corruption measures in these countries’ multi-year financing arrangements, where warranted as part of our ongoing implementation of the 2018 Enhanced Governance Framework. Many of the countries currently receiving emergency assistance either already have existing multi-year financing arrangements with the IMF or will be seeking such arrangements soon. These multi-year arrangements are better-suited than emergency financing to addressing longer-term structural issues that underpin poor governance and corruption.

 

 


[1] Analysis on combatting transnational corruption has occurred on foreign-bribery issues (France, Germany, and Japan), anti-money laundering issues (the United States), and both areas (Switzerland, Canada, the Czech Republic, and the United Kingdom).

[2] Topics discussed in Article IVs include fiscal governance (e.g., Bulgaria, Malaysia), central bank governance and operations (e.g., Liberia and Mozambique), financial sector oversight (e.g., India, Moldova), market regulation (e.g. Nigeria, South Africa), contract enforcement and property rights (e.g., Djibouti), anti-money laundering issues (e.g., Malta, Malaysia), and the anti-corruption framework (e.g., Bulgaria, Mexico).

[3] Several new programs have brought the fight against corruption to the forefront of their core objectives (e.g., Angola, Central African Republic, Equatorial Guinea, Honduras, Liberia, Mali, Rep. of Congo).

[4] Upon the authorities’ request, so far governance diagnostic missions have been undertaken for ten countries (Central African Republic, Democratic Republic of Congo, Equatorial Guinea, Moldova, Mozambique, Honduras, Guinea Bissau, Republic of Congo, Paraguay, Peru, and Zimbabwe).

[5] One example of analytical work is the April 2019 Fiscal Monitor’s chapter on Curbing Corruption. The chapter assesses the fiscal costs of corruption and explores practices and institutions in the fiscal area that reduce opportunities and incentives for corruption. In addition, three IMF special series notes—"Keeping the Receipts: Transparency, Accountability, and Legitimacy in Emergency Responses”, "Budget Execution Controls to Mitigate Corruption Risk in Pandemic Spending", and "COVID-19 Funds in Response to the Pandemic"—provide guidance on public financial management practices, drawing on cross-country examples, to ensure transparency and accountability of ramped-up spending in response to COVID-19 and address vulnerabilities to corruption.