-ControlingSystemic and Localised Controls for Corruption

Systemic controls.
Increasing the moral cost retributive justice of corruption
Creating a culture of integrity
Vigilant media
Civil society oversight
Criminalization and penalties
Modification of conflicts of interest guidelines
External auditing for party finances and campaigns
Changing the burden of proof for demonstrating the legality of officials wealth
Simplifying regulatory framework

FATF (2012), Interpretive Note 10, paragraph 15

Customer risk factors:
The business relationship is conducted in unusual circumstances (e.g. significant unexplained
geographic distance between the financial institution and the customer)
The business relationships with politically exposed person

The business relationships with other public officials who have an important role in significant
procurement, export-imports contracts.
Non-resident customers.
Legal persons or arrangements that are personal asset-holding vehicles.
Companies that have nominee shareholders or shares in bearer form.
Business that are cash-intensive.
The ownership structure of the company appears unusual or excessively complex given the nature
of the companys business

Country or geographic risk factors:

The bases of political party

Countries identified by credible sources

Countries subject to sanctions, embargos or similar measures issued
Countries identified by credible sources as having significant levels of corruption or other criminal
activity.
Countries or geographic areas identified by credible sources as providing funding or support for
terrorist activities, or that have designated terrorist organisations operating within their country.

Localised controls
Appropriate oversight of discretionary decision making (increase risk)
CCTV or other surveillance where appropriate
Creating a code of ethics (increase risk; remove excuses)
Decision-making process transparent and available for regular and random audits (increase risk)
Establishing effective internal and external reporting procedures (increase risk)
Penalties for procurement breaches (reduce reward)
Random integrity testing (increase risk)
Random integrity testing
Rotating agents (increase risk; increase effort)
Setting and enforcement of procurement guidelines (increase effort; remove excuses)
Whistleblower protection (increase risk)
Workplace performance indicators

-DetectingSystemic and Localised Opportunities for Corruption

Systemic opportunities
Lack of integrity among leaders (in both the public
and private sectors)
Lack of culture of integrity
Ethical codes do not exist, or are not enforced
Patronage and nepotism are accepted
Complexity of regulations/complexity of systems
Where factionalism, regionalism or ethnic
differences matter
Weak legal regimes
Weak nancial controls
Weak institutions of governance
Very weak state( or very strong state)

Localised opportunities
Supervision and oversight is not taken seriously
Specialised knowledge/high discretion
Decisions affect costs and benets of activities
Activity remote from supervision
No capable guardian
Low decision monitoring
Silencing of whistleblowers
Low salaries
Low risk of being caught
Conict of interest disregarded
Demand exceeds supply

Controling

Corruption
Type, Activities, Sectors and Places that comprise corruption events

Corruption

Detecting

Systematic Study
quantitative and qualitative data
and methods

Systemic opportunities define the political and operational environment and reflect the institutionalization of
low ethical and integrity standards and limited structural reform and capacity building.
Localised opportunities bring offender and target together and reflect capacity and willingness of
organisational leaders to intervene and to implement controls.
localised opportunities are place and job specific
systemic opportunities relate to the structures and policy and social environments within which these places and
jobs exist.

Preventing

Investigating

Type
Bribery
Extortion
Embezzlement
Self-dealing
Patronage
Abuse of discretion
Conict of interest
Nepotism, clientelism
and favouritism, etc.)

Product, service, transaction or delivery channel risk factors:

Private banking.

Anonymous transactions (which may include cash).

Non-face-to-face business relationships or transactions.
Payment received from unknown or un-associated third parties

Perpetrators of
corruption

Eliminate
corruption

-PreventionPreventing Corruption in Public Administration

Protected Disclosures legislation
Raising Public Awareness
Codes of conduct
general principles of ethical behaviour - responsibility,
integrity and public interest
standards of service
handling conflicts of interest
acceptance of gifts and benefits
discrimination and harassment
fairness and equity
public comment on the work of the agency
protecting confidential information
use of official facilities and equipment
reporting corrupt conduct ,
maladministration and serious and substantial waste of public resources.
An area of particular interest in relation to corruption prevention
Achieving cultural change
Public Education campaigns
Establish systems which give guidance to public officials who wish to do the right
thing in difficult situations

Disorder
Reduction

Corruption
risk factors

Risk assessment

Activities
Appointing personnel
Buying things (procurement)
Delivering programs or services
Making things (construction/
manufacturing
Rebuilding things (after a disaster)
Controlling activities (licensing/
regulation/issuing of permits)
Administering .

Sectors
Construction
Health
Tax administration
Energy
Environment and water
Forestry
Customs and immigration
Legal system
Disaster relief
Education, etc.

Places
Countries
Regions
Localities
Work places, etc.