Query

Please provide an overview of existing evidence around anti-corruption programming, transparency and accountability in the MENA region, including evidence on what type of intervention has had the most impact. If possible, please include specific evidence on the Occupied Palestinian Territories

Introduction

Anti-corruption programmes have been implemented for decades, rising to prominence in the 1990s (DFID 2015). Such programmes have frequently been implemented in developing countries or emerging markets with the support of international donor agencies. The objectives have often been to: i) support national governments in building institutions able to prevent and investigate corruption; ii) support civil society in raising awareness and providing oversight; and iii) establish a culture of integrity in the civil service able to resist corruption (DFID 2015; Johnsøn et al. 2012; NORAD 2011).

Considering that anti-corruption has been high on the policy agenda since at least the end of the Cold War, it is surprising how little is known about what measures have had any lasting impact in practice. Very few programmes have included actionable impact assessments, and few governments or donor agencies publish thorough evaluations or studies on the impact of their interventions (NORAD 2011 and USAID 2014).

Figuring out what works in anti-corruption programming is thus a challenge. This is especially true for the MENA region, which has faced substantial upheaval in the last decade. Revolutions and civil wars have toppled or weakened governments, and in a majority of countries the situation with corruption, transparency and accountability has taken a notable turn for the worse (Transparency International 2019).

The few countries in the region that have exhibited some political will to address corruption have generally done so in the recent past, leaving limited time to assess the effects and impact of their efforts.

The following Helpdesk answer will consider the available research on the effectiveness of anti-corruption programming globally, and aim to derive lessons for the MENA region by assessing the replicability of these lessons against region-specific corruption challenges, as well as recent efforts undertaken to tackle them.

Forms of corruption in the MENA region

Across the Middle East and North Africa, corruption was a common denominator in protests shaking the region in 2011 and subsequent years. But eight years on, the overall picture in the region looks grim. Some countries remain or have reverted to authoritarian regimes and others are caught in protracted, sometimes violent, conflict (Transparency International 2019). These ongoing conflicts and the fight against terrorism have often served as a pretext to not carry out sincere political reforms, while contrary to the aspirations of many protestors during the Arab Spring “public freedoms, freedom of expression and freedom of opinion have seen a sharp decline” (Transparency International 2016b).

However, some countries in the region have introduced reform programmes in recent years, including much-needed legal reforms, efforts to strengthen institutions and some concessions to allow space for civil society participation. Although results are still mixed (Doughan 2017), they present outliers in an overall unfavourable environment. Four of these cases are considered in greater detail below.

Across the region, political corruption and state capture remain a challenge, checks and balances are weak on average, and spaces for civic engagement are generally limited or absent. In this climate, anti-corruption efforts tend to have limited effect (Transparency International 2019). In a 2016 survey conducted by Transparency International in the region, 61% of respondents said they felt corruption had worsened in the past year, 66% said their governments were doing badly, and nearly one in three said that they had paid a bribe in the previous year (Transparency International 2016a).

Institutional shortcomings

The lack of checks and balances in many countries of the region and a limited separation of powers affect the independence and transparency of political institutions (Transparency International 2018). While most constitutions in the region provide for a separation of powers, it is often not upheld in practice, with the executive branch tending to hold substantial power over legislative and judicial agencies (Transparency International 2015a). The institutions that people reported having to bribe most often, according to Transparency International’s 2016 survey, were the courts and the police, while government officials, tax officials and members of parliament were perceived to be the most corrupt groups of people (Transparency International 2016a).

While provisions requiring asset disclosure for public officials are provided for by law in many countries of the region, such provisions are typically ineffective in practice as they are rarely enforced and there is a lack of accountability and oversight within the relevant institutions (Transparency International 2015a). The lack of a separation of powers also affects anti-corruption bodies and law enforcement, who across the region are often subordinate to the executive and thus lack independence.

As part of their efforts to ratify the United Nations Convention against Corruption (UNCAC), which 16 countries in the region have done, 11 countries have established anti-corruption authorities. While these bodies have contributed to a greater awareness among the public, across the region their independence and efficiency needs strengthening, greater inter-agency cooperation is required, and many agencies suffer from a lack of resources and capacity (Transparency International 2016b).

Civil service and public service delivery

Levels of corruption in the public service are high across the region (Transparency International 2016a). Almost a third of people in the region (30%) reported they had had to pay a bribe in the previous year to access basic services. The high levels of disillusionment towards the authorities particularly affects countries where levels of petty corruption are high and citizens feel they cannot access needed public services without paying small bribes. These frustrations are nonetheless also evident in countries where levels of petty corruption are low, or at least comparable to countries in similar regions or income brackets, but where high levels of nepotism leave citizens with the impression that their public servants are corruptible and do not serve the public interest (Kukutschka 2018).

Across the region, the need to use connections to facilitate public service delivery is widespread. One such phenomenon is that of “wasta”, which can be described as “local practices of political patronage and favouritism” (Doughan 2017:1). In Jordan, the system of “wasta” is considered corruption by a vast majority of people (up to 86%). At the same time, 90% of respondents in a study from 2002 stated they would attempt to use wasta for their own advantage in the future (Doughan 2017:4). Similarly the Palestinian Anti-Corruption Commission reported in 2015 that the “abuse of public office, favouritism, nepotism or wasta and deviation of public funds were the most prevalent forms of corruption in the West Bank and Gaza” (Kukutschka 2018: 4).

A particular challenge in this regard, is that nepotism and clientelism do not always constitute a legal violation. Even where these practices breach the legal code, social acceptance is often high or the practice gets excused with reference to the low salaries of public sector employees or simply habit (Doughan 2017).

High levels of nepotism, clientelism and favouritism ultimately result in the misuse of public positions for personal gain as well as in the misappropriation and theft of public resources (Kukutschka 2018).

Doughan (2017) has argued that approaching corruption from a purely criminal justice reform perspective has rendered such reform efforts ineffective. He instead advocates for an “understanding of corruption as a problem of distributive justice rather than criminal justice … to address political grievances in the Middle East and beyond” (Doughan 2017: 2).

The practice of wasta has been partially criminalised in Jordan and other countries of the region (such as Egypt, Palestine, Iraq, and Saudi Arabia), but no case has resulted in a conviction, attesting to the inability of a legal prohibition alone to curb the practice (Doughan 2017: 6).

As the system of wasta is often used to ensure access to a service (such as healthcare, jobs, licences, etc.) putting in place measures that facilitate equal citizen access to services is crucial (Doughan 2017).

Limited spaces for citizen participation

Across the region, the re-emergence of authoritarian regimes in many countries has resulted in a shrinking of civil society space. Crackdowns on political dissent, limited freedom of speech, and an absence of independent media and civil society organisations are commonplace (Transparency International 2015a and Transparency International 2018).

Organised civil society in particular faces challenges due to restrictions put on their ability to register and operate across the region and a general distrust from governments towards NGOs (Transparency International 2015a).

Worryingly, while citizens across the region feel that reporting bribery and refusing to pay bribes are some of the most effective ways in which citizens can make a difference, current reporting channels are considered unsafe and inefficient (Transparency International 2015b).

Whistleblowing, considered one of the most effective ways to uncover corruption, is largely unheard of in the MENA region. As of 2015, no country in the region was considered to have adequate whistleblower safeguards or safe reporting channels (Transparency International 2015b). According to Transparency International (2015b), even if citizens were to report wrongdoing, the absence of institutional frameworks and protections for the media would make it unlikely for reports to be consistently exposed and acted upon.

Some laws provide for limited regulations and protections (notably in Palestine, Jordan and Lebanon), but there are few clear channels or official hotlines available for whistleblowers to make such reports” (Transparency International 2015b: 9). In 2017, Tunisia passed whistleblower legislation (Lee-Jones 2018), but its effects and implementation are still too early to assess. In Jordan, the recently strengthened anti-corruption commission provides for increased protections for witnesses, informants and whistleblowers, and records cases of whistleblowing (Rasheed for Transparency et al. 2017).

While many countries provide some protections against physical harm and other reprisals for reporting individuals, these de jure measures appear to have limited effect in practice. Furthermore, whistleblowers are often required to provide evidence, and no protections are in place if whistleblowers unwittingly make false reports. Coupled with high levels of (perceived) corruption in the judiciary, this discourages reporting (Transparency International 2015b).

Evidence of the effectiveness of anti-corruption programming

Anti-corruption and social accountability programming has been used in many developing and emerging market economies, with the aim of reducing corruption and building stronger institutions to tackle the challenge. Among the measures supported, often by international organisations, are institutional and legal reforms, technical assistance and capacity building to public authorities, as well as support to civil society organisations (NORAD 2011 and USAID 2014).

However, the many years of implementation have seen limited systematic efforts to assess the effectiveness of the measures applied. Partially this is due to a lack of data, research and impact evaluation studies being conducted, making reliable, evidence-based assessments of the effectiveness of a given measure difficult (DFID 2015; Hanna et al. 2011; Johnsøn et al. 2012).

From the evaluations that are available, many direct anti-corruption interventions have actually proven ineffective, leading donors to change their approach to focus more on sectorial approaches integrating anti-corruption indirectly (DFID 2015; Hanna et al. 2011; Johnsøn et al. 2012; Scharbatke-Church & Chigas 2016). But corruption is also a very “complex, adaptive system” (Scharbatke-Church & Chigas 2016: 4) as well as being highly idiosyncratic. It has thus been argued that trying to identify interventions that would work anywhere is part of the problem and will set measures up to fail (Canadian International Development Agency 2000; Heeks 2011; Scharbatke-Church & Chigas 2016).

Implementers of anti-corruption programming thus have to conduct a balancing act that ensures measures are designed on the basis of available evidence elicited from other contexts and previous experiences, while also considering the context they operate in.

In the following section, a number of anti-corruption programming angles are discussed that are commonly considered effective or necessary to tackle the kinds of corruption challenges encountered in the MENA region as discussed above.

Institutional reform

Strong and independent institutions are the backbone of successful anti-corruption programmes. Where institutions, such as courts, parliaments and anti-corruption agencies, lack integrity or are considered to be corrupt, other efforts of the kind discussed below will find it much harder to produce the desired effect.

During the 1990s, in the “formative years of the anti-corruption agenda” (DFID 2015: 63), many direct anti-corruption interventions focused on the establishment of anti-corruption entities. This process was later deemed largely ineffective, and international donors changed course in favour or “mainstreaming” or the integrating of anti-corruption elements into broader sector-based frameworks (DIFID 2015 and Johnsøn 2012).

Governments in the MENA region, however, still struggle with institutional insufficiencies, either because control and oversight agencies are not in place, are inadequately set up or are unable to operate due to political and resource constraints (Transparency International 2016b). Institutional reform therefore remains germane in many of these countries to ensure that legislation is consistently and impartially enforced and to create a functioning institutional framework in which other anti-corruption measures can take hold.

Judiciary

The justice sector and especially the courts are often considered particularly prone to corruption (Transparency International 2016a). Indeed, according to Johnsøn et al. (2012), there is a strong correlation between corruption and the effectiveness of the judiciary. Donors have consequently supported a variety of efforts to strengthen integrity in the justice sector, including building technical competence, improving case management, improving training and appointment of judges and prosecutors, and developing codes of conduct (Johnsøn et al. 2012).

Supreme audit institutions (SAI)

Audit institutions are responsible for the review of financial, management and operation activities of governmental entities and are expected to communicate information regarding public accounts to relevant government entities and the public. They are thus key to ensure that public funds are spent responsibly and effectively, as well as to increase the likelihood that malfeasance is detected. To fulfil their role successfully, it is paramount that they are independent from government and are provided with sufficient authority and funding as well as a broad mandate (Canadian International Development Agency 2000; Center for Constitutional Transitions et al. 2014; DFID 2015).

While studies aiming to assess the effectiveness of SAI in countering corruption are scarce, a study conducted by NORAD found that “SAIs are more effective at reducing corruption compared with other anti-corruption institutions, such as anti-corruption authorities” (DFID 2015: 62).

In a similar vein, from what evidence is available on institutional reforms, Johnsøn et al. (2012) have found that interventions regarding public financial management reforms and supreme audit institutions were generally successful.

Where there is an unclear distribution of authority and power across governmental institutions, executive interference in the auditing process, and insufficient capacity and resources, however, SAIs may struggle to make an impact in anti-corruption efforts (DFID 2015 and Johnsøn et al. 2012). To function as intended, SAI also need a supporting institutional context, such as a parliament effectively exercising its oversight function (Johnsøn et al. 2012).

Anti-corruption agencies (ACA)

Anti-corruption agencies or commissions are generally set up to perform three functions: investigation and prosecution, prevention, and awareness raising and education (Transparency International 2016b). While they may be given additional tasks, at the minimum, as per UNCAC, they should be mandated to “prevent corruption, implement the country’s anti-corruption policies and increase and disseminate knowledge about preventing corruption” (Center for Constitutional Transitions et. al. 2014: 16).

According to Johnsøn et al. (2012), while relatively comprehensive assessments have been made on the effectiveness of ACAs, most of the research is qualitative and case-specific. The majority of studies that have been conducted on individual ACAs generally came to the conclusion that they were rather ineffective in reducing corruption (DFID 2015 and Johnsøn et al. 2012). But considering the methodological limitations of these studies, Johnsøn et al. (2012: 11) conclude that it is “not possible to generalize whether the failure of ACAs is predominantly a problem of design, implementation, or the conditions within which they operate”.

Several studies (DFID 2015; Johnsøn et al. 2012, NORAD 2011) have looked at the reasons for failure of ACAs and came to the conclusion that failure was generally due to an inadequate implementation or unfavourable environment and not intrinsic to the agency itself. ACAs typically failed or underperformed in countries where governance was poor, political will low, the judiciary weak and corruption levels high. They also failed where they lacked resources, access to skilled labour, geographical reach, leadership, strong institutional mandates and independence from political interference.

Conversely, they were more likely to be successful if they had strong internal controls and accountability mechanisms, were able to build alliances with relevant public sector and civil society stakeholders, and focused on preventive and educational efforts (DFID 2015). According to NORAD (2011), donor support to ACAs was relatively effective, but capacity building requirements tended to take longer than expected and required more resources.

Other oversight bodies include inspector generals and ombudsmen. Their authority and mandate can differ, but they are commonly tasked with monitoring government operations, reviewing administrative processes and investigating accusations of mismanagement (Canadian International Development Agency 2000). Again, there are few studies that assess their effectiveness (Johnsøn et al. 2012).

Improving accountability

Improving accountability in institutions can help increase detection through transparency and oversight provisions. It can also enhance self-regulation and increase trust in institutions by giving citizens access to relevant information and holding institutions accountable to their constituency (Canadian International Development Agency 2000).

Measures to increase accountability include access to information provisions, financial and asset disclosure, and open budget or open government initiatives. Some countries in the MENA region have enacted provisions that require public officials to declare significant interests or assets, and some of these asset disclosure regimes are overseen by the country’s ACA.

Such measures are most successful if disclosure occurs periodically, is accompanied by strong access to information provisions and proactive public reporting mechanisms, and allows for limited exceptions and has clear guidelines (Center for Constitutional Transitions et al. 2014). Several countries in the region (Morocco, Afghanistan, Jordan and Tunisia) have joined the Open Government Partnership. While some have joined the initiative very recently (Afghanistan in 2017 and Morocco in 2018), all four countries have submitted recent action plans, and all countries, except Morocco, have submitted progress reports.

However, transparency and accountability will only prove useful when accompanied by a strong engagement of civil society and a public able to engage with the information made available (see below).

Civil service and administrative reform

Corruption in public sector administration is one of the forms of corruption most often encountered by citizens, as lower ranking public officials are usually the primary point of interaction between citizens and the state (Transparency International 2017).

Corruption in public service delivery reduces the quality of such services and creates unequal access to essential services such as health, education, water and sanitation, and affects citizens’ ability to receive necessary papers and permits (Hanna et al. 2011 and Transparency International 2017).

Tackling corruption in the civil service is crucial in many countries in the MENA region, but studies that examined previous civil service reform efforts have generally found them ineffective (Johnsøn et al. 2012). Some studies have blamed failure on elites unwilling to give up power. Personnel management reforms are believed to be more promising. One study by the World Bank, for example, found that personnel reforms that produce merit-based recruitment can counter patronage-based systems. But the research basis is too thin to make a robust general assessment (Johnsøn et al. 2012).

Addressing corruption in the civil service and public service delivery thus requires a wide set of mutually reinforcing measures including transparency, open data and e-government provisions; public scrutiny and social accountability; complaint and grievance mechanisms; transparent and merit-based recruitment; a better management of human resources; and codes of conduct (DFID 2015; Johnsøn et al. 2012; Transparency International 2017). Additionally, measures targeting the socio-economic side of the equation, such as welfare state structures and higher salaries need to be considered where possible (Canadian International Development Agency 2000 and Doughan 2017).

However, raising salaries alone has no discernible effect on corruption levels and should thus always be embedded into a process that also professionalises civil service so as to not create new incentives for corrupt behaviour. This should include merit-based hiring and remuneration, formalised hiring processes and establishing codes of conduct (Canadian International Development Agency 2000; Johnsøn et al. 2012; DFID 2015).

According to Hanna et al. (2011), measures aiming at reforming the civil service can be divided into: i) monitoring and incentive efforts; and ii) programmes to change the rules of the system.

Improving monitoring, adjusting incentives and strengthening sanctions

Monitoring and incentives/sanctions reforms aim to ensure that lower level public officials carry out their tasks in line with governmental efforts and policy, instead of following their own private interests. This can be done through measures increasing monitoring and control over civil servants and/or the implementation of incentive and sanction schemes that encourage civil servants to abide by the rules.

Based on an evaluation by Hanna et al. (2011) of previous efforts, efforts to increase monitoring civil servants require two things to be successful. Firstly, the measure must be implemented and monitored by a party genuinely interested in lowering levels of corruption. Secondly, they must be combined with a form of incentive and sanctions programme. The goal is to raise the cost of corrupt behaviour by increasing the likelihood of being caught (through monitoring) and raising the price of corrupt behaviour and the benefits of ethical behaviour (through sanctions and incentives).

The first requirement is a sticking point for Scharbatke-Church and Chigas (2016). They have argued that approaches focusing exclusively on “restricting monopoly and discretion and increasing accountability” (Scharbatke-Church and Chigas 2016: 9) are set up to fail in contexts were corruption is systemic. These interventions are built on a principal-agent approach, i.e. a principal (e.g. the ministry of finance) wishes to enact reforms and relies on front-line agents (e.g. tax officials) to carry out tasks accordingly. They thus fail in settings where the system and the principal are either corrupt, or lack sufficient will to truly implement reforms. While Hanna et al. (2011) acknowledge this, and Scharbatke-Church and Chigas (2016) argue that in most developing and conflict-laden contexts the principal is compromised, yet such measures are continuously applied and consequently fail.

System reform

Among measures to change the system, a contested one is decentralisation. According to Hanna et al. (2011), decentralisation is promising as it reduces monopoly and discretion. Moreover, its likelihood of success is believed to increase if it includes an element of citizen participation, if public officials are elected and where efforts include initial capacity building (Hanna et al. 2011).

Similarly, Johnsøn et al (2012) have found decentralisation to be more successful where local capacity was high, and high levels of citizen participation and community monitoring existed. However, a study from the UK Department of International Development (DFID 2015) found inconsistent results regarding the benefit of decentralisation, suggesting that the measure on its own would have limited impact on corruption levels. However, they found some evidence to suggest that decentralisation works in specific contexts, such as in the presence of a free press, in contexts where beneficiaries are able to hold decision makers accountable, and if fiscal and revenue-gathering activities are decentralised together.

But both Hanna et al. (2011) and Johnsøn et al. (2012) warn that decentralisation can be an expensive and ineffective undertaking in communities were participation and capacity are insufficient. Ultimately, decentralisation is not a panacea and whether or not it will be beneficial depends heavily on contextual factors: “Decentralization can either lead to increased oversight by local citizens, or increased capture by local elites, depending on context” (Johnsøn et al. 2012: 19).

A measure that has been increasingly used in public service delivery, especially licensing, are “one-stop-shops” or “single-window facilities”. These aim to streamline processes, increase efficiency, and reduce repeated interaction between public sector officials and citizens, and thus reduce opportunities for corruption. According to a USAID evaluation of anti-corruption programming efforts worldwide (USAID 2014), results of these efforts are mixed. Many one-stop-shops were successful in reducing time to receive licences and/or costs. Among these was a smaller programme in Egypt, and a more widely applied one in Jordan. However, there were also cases of one-stop-shops that remained largely unused because citizens stuck to the use of agents that they were accustomed to (USAID 2014).

Another measure that is commonly proposed to help reduce corruption in public service delivery and administrative processes are e-government tools. Like one-stop-shops they reduce the number of interactions and thus opportunities for corruption. E-government tools remove discretion from public officials and allow for a better tracking and monitoring of processes. According to DFID (2015), several studies have found a positive impact of e-government processes in reducing corruption, especially where telecommunication infrastructure and online services are appropriate.

Financial management

Public financial management includes a wide area of reform approaches, such as reforms in tax administration or procurement authorities. Financial management reforms can fall under either of the above reform categories (increased monitoring or system reform), but are discussed separately due to their prominence and the relatively large number of studies compared to other interventions (Johnsøn et al. 2012).

Research has found a link between strong budget management systems and greater participation of external stakeholders in public spending, and lower levels of corruption (Johnsøn et al. 2012). Specifically, computerised integrated financial management was considered likely to have contributed to greater transparency and preventing certain types of fraud.

Tools such as public expenditure tracking surveys, by which financial flows from ministries to front-line agencies are tracked to identify leakages, are also considered promising (DFID 2015 and Johnsøn et al. 2012).

Procurement measures are also shown by several studies (DFID 2015; Hanna et.al. 2011; Johnsøn et al. 2012) to be beneficial in reducing corruption and leakages. Among the procurement measures considered effective are open and non-discretionary audits, increased monitoring and oversight and publicity requirements. In their 2012 study, Johnsøn et al. (2012) found no evidence as to the effectiveness of e-procurement systems, despite their popularity. As of today, this Helpdesk answer was still not able to identify any overarching studies specifically looking at the impact of e-procurement systems on corruption. But their increasing success in recent years (e.g. the case of Pro-Zorro in Ukraine or that of KONEPS in Korea that was replicated in Jordan Rasheed for Integrity and Transparency, et al. 2017) points towards to their potential impact.

While several studies look at tax and revenue collection reform and their effect on corruption, most of these are case studies evaluating very specific environments and thus do not allow for the deduction of general assessments (Johnsøn et al. 2012).

Projects in the MENA region that aimed to implement e-processes included a programme to improve tax collection in the West Bank and Gaza, piloting e-invest software to process investment applications in Morocco, and a financial management system in Jordan to monitor and control government spending (USAID 2014).

Creating space for citizen engagement

There are several ways in which civil society and the public can contribute to efforts to counter corruption, such as monitoring and reporting, social accountability, or involvement in awareness raising and capacity building efforts.

For media and civil society to adequately perform their role, freedom of expression and information are crucial. They ensure access to relevant information and safeguard organisations from governmental interference or oppression. Awareness raising and education campaigns are often an important first step, especially in countries where citizen participation was previously limited or impossible (Canadian International Development Agency 2000 and USAID 2014).

Support to civil society organisations is often channelled through development agencies, who largely consider programmes to strengthen civil society effective (DFID 2015; NORAD 2011; USAID 2014). According to NORAD (2011), efforts of local evidence gathering (such as national surveys) and grassroots monitoring initiatives to strengthen service delivery were deemed particularly effective. According to DFID (2015), factors contributing to the effect of citizen engagement are a wide range of civic organisations, professionally organised civil society organisations, a surrounding supportive framework and political will.

Other evaluations differed in their assessment of NGO/CSO support and found it mostly ineffective in reducing corruption (Johnsøn et al. 2012). Reasons identified for this ineffectiveness include a lack of political will to engage with civil society, inadequate legal frameworks and insufficient NGO/CSO representatives.

Several studies have identified a clear link between greater freedom of speech and lower levels of corruption. However, some studies have put a caveat on this as they found freedom of speech only effective where reports of corruption lead to subsequent sanctions for the offender (Johnsøn et al. 2012). On the introduction of freedom of information laws results are mixed. While, according to Johnsøn et. al. (2012), civil society organisations have reported positive effects of freedom of information laws, studies examining their link to reduced corruption produced inconclusive results.

Social accountability and monitoring

Social accountability refers to ways for citizens to hold authorities accountable beyond the traditional means of formal political accountability (DFID 2015 and Johnsøn et al. 2012). It includes a broad range of mechanisms, such as participatory budgeting, citizen monitoring of service delivery, citizen advisory boards and public complaints mechanisms.

Social accountability and monitoring programmes were largely found to be effective (DFID 2015; Hanna et al. 2011; Johnsøn et al. 2012). However, according to the available research, to be successful they require a few external conditions to be met. The levels of community capacity and participation are relevant, as is the ability to remove public officials from office or otherwise apply sanctions in case of violations. Efforts have also been found to be more successful if civil society stakeholders were involved in the design and implementation of interventions and were directly affected by corruption. Other positively reinforcing factors include political will and a low risk of elite capture.

Engaging media stakeholders has also shown promise in raising awareness about corruption and exposing corrupt behaviour among public officials (Hanna et al. 2011). Johnsøn et al. (2012) found a strong correlation between press freedom and lower levels of corruption. However, reporting through media can only be successful if there are established and trusted media outlets who are able to work free from political interference, and if reports come at a cost to the offending individual (e.g. legal consequences, reputational cost) (Hanna et al. 2011 and Johnsøn et al. 2012).

Whistleblowing

Whistleblowing is defined as the “disclosure of information related to corrupt, illegal, fraudulent or hazardous activities being committed in or by public or private sector organisations – which are of concern to or threaten the public interest – to individuals or entities believed to be able to effect action’” (Transparency International 2015b: 5) and it is considered one of the most effective ways of stopping corruption, according to Transparency International.

To encourage people to come forward and report misconduct requires clear and comprehensive legislation. It also requires the establishment of effective protections for whistleblowers, as long as they do not knowingly make a false report. Procedures need to allow for reporting anonymously if necessary, and authorities need to demonstrate that reports are followed up with, so that prospective whistleblowers put trust in the process (Transparency International 2015b).

However, for whistleblowing to be ultimately effective, it needs to be embedded into a supporting context of institutional and legal reform that guarantees an independent judiciary and law enforcement, free media and independent civil society (Transparency International 2015b).

Interventions across the MENA region

Even though frustration about high levels of corruption was one of the main catalysts for the protest movements sweeping the region almost 10 years ago, the governance situation has not improved over the past decade (Transparency International 2019). Countries in the region have largely joined relevant international conventions, such as UNCAC and the Arab Convention against Corruption, and have taken some required steps, such as establishing ACAs, SAIs and passing national anti-corruption strategies (Center for Constitutional Transitions et al. 2014).

In support of the region’s anti-corruption efforts, international organisations have funded national approaches to counter corruption. According to a USAID review, out of the projects it funded in the MENA region with an anti-corruption component as part of their programmes between 2007 and 2013, the most common areas of intervention were, in descending order: rule of law, local government and decentralisation, civil society and economic growth (USAID 2014). Specific anti-corruption initiatives were usually in support of independent national entities countering corruption. Legal drafting and enforcement efforts were also supported, as were capacity-building programmes for civil society and public sector entities on corruption complaints systems, investigative reporting, oversight, awareness raising and promoting corporate ethics.

This Helpdesk review has not encountered region-specific impact assessments or studies that would allow for a generalised verdict as to what has worked and what has not in the Arab world. Nonetheless, the institutions that have been put in place to control and investigate corruption are mostly deemed ineffective or of little effect due to resource constraints and a lack of independence (Transparency International 2016b). Space for civil society has been shrinking too, while an overly strong executive overrides checks and balances (Transparency International 2015a).

However, some countries in the region have been more active in tackling corruption challenges than others. While results are still mixed and many measures are too recent to assess, they may still provide some insights into which strategies could work and what gaps remain.

Morocco

In Morocco, as in other countries of the region, a key challenge is the general perception that positions of power and public service are used for the enrichment of selected individuals. A stagnating positioning on Transparency International’s Corruption Perception Index (CPI) and other international indicators attests to the prevalence of corruption-related challenges (Saddouq 2015).

Abdessamad Saddouq, Transparency Maroc’s secretary general, argues that entrenched failures of governance, such as widespread impunity and a lack of accountability and transparency, have led to a system in which “corrupt practices, the distribution of privileges and the exchange of services organise the public space more than the rule of law” (Saddouq 2015: 28).

Recent reform efforts

After the protests of 2011, some reforms were launched but the results are mixed. The new constitution established in 2011 gives a central role to good governance and accountability and established provisions for conflicts of interest. (Saddouq 2015).

In 2015, the government launched a 10-year national strategy for anti-corruption, and, in 2018, a national committee for anti-corruption started operating to follow up on the strategy’s implementation (Berraou 2019).

Starting in 2007, the Moroccan supreme audit institution (or court of accounts) took on the role of addressing mismanagement and misuse of public funds. According to Berraou (2019), the court of accounts has quickly gained prominence and was successful in prevention, in forwarding cases to criminal jurisdiction and applying financial penalties. The court also has the capacity to audit the financial reports of political parties. “More recently, the king has relied on a court’s report to take punitive measures in 2018, called ‘political earthquake’, against a number of ministers and senior officials in the Ministry of Interior” (Berraou 2019: 7). Furthermore, transparency provisions were included in a number of laws, and new laws on anti-money laundering, asset declaration law and a witness protection were enacted.

The country’s anti-corruption agencies have undergone substantial reform and changes in recent years. The country’s Central Authority for the Prevention of Corruption (ICPC), established in 2007 to comply with UNCAC, was replaced in 2015 by a new anti-corruption authority established per the new constitution, the National Authority for Integrity, Prevention and the Fight against Corruption (Instance Nationale de Probité, de Prévention et de Lutte contre la Corruption, INPLC).

However, no chairperson or members were appointed, and the new authority remained largely inactive, with the officially disbanded ICPC continuing basic operations in the interim (Transparency International 2016b). Late 2017 saw the renewed announcement of the new commission, emphasising its independence and new investigative and prosecutorial powers (ICPC 2017). However, its members and chair were not appointed until 2018, leaving too little time to assess its implementation.

Effects of reforms and remaining challenges

The consensus in the literature is that the effect of reforms so far have been limited (Berraou 2019; Saddouq 2015; Transparency Maroc 2014). Reasons for the efforts’ failure were attributed to an absence of political will and sincere commitment from government, insufficiencies in the legal and institutional frameworks, inadequate resources and capacities, an inability to adequately integrate civil society in the process, insufficient independence and transparency of relevant institutions, persistent impunity, and a perceived normalisation of corruption within society.

In 2018, an access to information law was passed (Kingdom of Morocco 2018). However, it was criticised by civil society stakeholders as insufficient and providing for too many exceptions (Transparency International 2019).

Encouraging signs include a strong civil society presence, shifting public opinion, and international partners who are engaging on the topic (Saddouq 2015 and Transparency Maroc 2014).

Current developments

Reacting to remaining deficiencies, new royal decrees of November and December 2018 appointed a new president to the competition council and filling the previously vacant position of chair of the anti-corruption authority NAIPFC. Additional royal directives explicitly called for institutional cooperation (Berraou 2019).

Also in 2018, Morocco joined the Open Government Partnership. While it is too early to look at progress, the country has submitted a first action plan, detailing reform commitments underway or upcoming (Kingdom of Morocco 2018). The action plan had been developed in consultation with civil society organisations and underwent several rounds of review including with international organisations, such as the OECD. Commitments made include: i) establishing access of information through training and awareness raising; ii) improving public service delivery including complaints mechanisms; iii) improving budget transparency; and iv) increasing citizen participation (Kingdom of Morocco 2018). The establishment of a law to protect whistleblowers was recently announced.

It remains to be seen whether these new steps will ensure the legal and institutional reforms and have an impact.

Jordan

Legal and institutional reforms

In the years following the Arab Spring, Jordan has taken several steps at legislative, executive, administrative and judicial levels to improve transparency, integrity and good governance in public institutions. At the same time, King Abdullah II has repeatedly committed to countering corruption, and royal decrees have been issued to that effect (Rasheed for Integrity and Transparency 2016). Legal reforms were advanced to create more balance between the legislative and executive, grant more authority to judicial entities, and create a constitutional court and independent election commission.

The country’s anti-corruption commission was established in 2006 and gained substantial prominence in the years following 2011. It was given more authority in 2012 and 2016 and subsequently gained a higher profile, increased its enforcement capacities, was able to tackle a large number of corruption cases and received an increasing number of whistleblower reports. Under the directives of King Abdullah II, the anti-corruption commission has implemented a series of anti-corruption strategies, the most recent one (2017-2025) aimed to raise awareness, strengthen preventive efforts, identify gaps in legislation, enhance capacities of the anti-corruption commission, strengthen citizen participation, and increase investigative efforts and international cooperation (Hashemite Kingdom of Jordan 2018; Rasheed for Integrity and Transparency et al. 2017; Rasheed for Integrity and Transparency 2016).

The commission provides a substantial level of transparency through a website including relevant information, reports and activities (Transparency International 2016b). Since the inception of a witness protection programme in 2014, the commission provides for increasing protection of witnesses and whistleblowers, records cases of whistleblowing, and outreach efforts were undertaken to inform the general public, NGOs, public officials and media of the new provisions (Rasheed for Integrity and Transparency et al. 2017).

While the commission generally exercises broad powers and is able to investigate extensively and issue sanctions, its preventive capacities and awareness raising need strengthening, and its reach in the private sector and inter-agency cooperation should be advanced (Rasheed for Integrity and Transparency 2016 and Transparency International 2016b).

New legal amendments added provisions against money laundering, illicit enrichment and conflict of interest disclosures, and a new law on political parties regulates party financing. A new integrity and anti-corruption commission law went into effect in 2016, creating a designated prosecution arm in the judiciary that specialises in cases from the anti-corruption commission, stipulating minimum penalties for those convicted, and introducing a witness protection programme (Rasheed for Integrity and Transparency et al. 2017 and Rasheed for Integrity and Transparency 2016). The country’s anti-money laundering units have also seen an increase in cases received in recent years

Public sector reforms

Corruption in the public sector administration remains high, especially with nepotism and low legal compliance (Doughan 2017). Inadequacies in public sector administration are a particular challenge in Jordan, where 43% of the country’s workforce is employed in the public sector (Rasheed for Integrity and Transparency 2016: 121). A Ministry for Public Sector Reform was established in 2006 and amended in 2007 and 2012. The ministry was tasked with restructuring and reorganising institutions, improving the quality of government services, streamlining procedures, and preparing policies for the management and development of human resources. In 2014, a code of conduct and ethics in public service was established and “awareness workshops were held for government ministries, institutions, and directorates to familiarise participants with the provisions of the code” (Rasheed for Integrity and Transparency 2016: 136). The code of conduct includes provisions regarding conflicts of interest, “revolving door” provisions, and measures for gifts and hospitality acceptance (Rasheed for Integrity and Transparency et al. 2017).

To monitor the performance of institutions and to provide technical support and strategic planning, a Directorate of Policy and Decision-making Support was established in the same year (Rasheed for Integrity and Transparency 2016). An online portal was launched in 2017 and updated in 2018 to allow citizens to make complaints, report corruption, or submit suggestions (Hashemite Kingdom of Jordan 2018).

Reforms in the business environment

In addition to reform efforts in the public sector, programmes were also launched to tackle corruption in the business environment.

One such effort was the establishment of a one-stop-shop to reduce corruption in customs processing that was supported by USAID. The “web-based single-window facility … facilitates the exchange of data among government agencies to reduce processing times for all import, export and transit procedures and makes customs operations more cost-effective, while reducing delays and costs to importers. Expanded in 2011, the single-window facility covers 95% of all imports into the country” (USAID 2014: 23). Also supported by USAID, a financial reform project was launched that aimed to increase efficiency and transparency in tax collection. An Income and Sales Tax Department Audit Manual Committee was created to develop a manual and training programme on tax auditing. The goal was to standardise tax audits across the country and to make it easier to audit a greater number of taxpayers (USAID 2014).

In 2017 Jordan adopted an e-procurement system that “allows for the online consolidation of an e-procurement web portal, bids for tender, and electronic contracts, thus enabling procurement tasks to be carried out on one online platform” (Rasheed for Integrity and Transparency et al. 2017).

Effect of reforms and remaining gaps

According to the country’s most recent national integrity system (NIS) report, reforms so far have had limited effect (Rasheed for Integrity and Transparency 2016). The study found the country’s non-governmental players, such as media and civil society, to be relatively weak due to a lack of freedom to operate and limited cooperation between the stakeholder groups, but did also note that media has recently seen a substantial increase in freedom and was able to highlight a considerable number of corruption cases. The government’s latest report on its participation in the Open Government Partnership from 2018 acknowledges the importance of civil society and notes that “Civil society in Jordan has witnessed remarkable development during the past 10 years, as its organizations became a key partner in the reform process pursued by state’s actors” (Hashemite Kingdom of Jordan 2018: 8). This notwithstanding, media still face restrictions on their ability to operate freely in the name of public order and public security and media overall lacks independence as the majority of media outlets are government-owned (Rasheed for Integrity and Transparency et al. 2017).

While access to information legal provisions exist, these are insufficiently implemented in practice, as few public sector institutions publish relevant information regularly and exhaustively (Rasheed for Integrity and Transparency et al. 2017).

Current developments

Like Morocco, Jordan has submitted an action plan as part of its membership in the Open Government Partnership in 2018 (Hashemite Kingdom of Jordan 2018). The new action plan focuses on increased engagement with civil society, the development and enhancement of open data provisions and better enforces the access to information law, among others. This includes a commitment to an increased investment in e-government programs, the establishment of an online citizen complaints mechanism, and better protection of informants. These measures are expressly aimed to detect corruption and improve public service by holding civil servants accountable (Hashemite Kingdom of Jordan 2018).

Tunisia

Following the 2011 uprisings, the new Tunisian government made countering corruption a priority, and several high-profile arrests were made on corruption-related charges. A specialised Ministry of Governance was established after the revolution, to support capacity building and anti-corruption work in public administration. Anti-corruption and transparency commitments were enshrined into the new 2014 constitution, which also includes access to information guarantees. In the same year, Tunisia joined the Open Government Partnership with progress trackable online (Lee-Jones 2018). According to Tunisia’s most recent action plan, new commitments are made in the areas of access to information, open data, promoting transparency in natural resource management, increasing integrity in the public sector, increasing participation on budgetary matters, and improving access to and administration of public services (Republic of Tunisia 2018).

Also, since 2011, several national independent bodies have been established to deal with past corruption cases and prevent corruption in future. However, there is some concern that the central agencies lack the resources necessary to effectively carry out their roles (Lee-Jones 2018). The National Authority for the Fight Against Corruption (Instance Nationale de Lutte Contre la Corruption, INLUCC) was enshrined in the 2014 constitution. INLUCC’s role is both preventive and investigative. To date, INLUCC has received around 11,000 cases and has examined over 5,000 (Lee-Jones 2018: 8).

However, Tunisia’s anti-corruption authority is faced with severe resource constraints, both in terms of its budget and its staff (Lee-Jones 2018 and Transparency International 2016b). Previous chairs of the authority confirmed that they lacked political support or were actively side-lined. As of 2016, the authority had no website to publish reports or other information for the public, thus providing for limited transparency (Transparency International 2016b).

Another concern, raised in the country’s most recent NIS was that, despite crucial steps taken, their effect remains limited in practice. It was argued that the different stakeholders and processes lack coordination and a common strategic vision, that laws are often bypassed, ignored or instrumentalised, and that corruption remains widely entrenched in everyday culture (I Watch Organisation 2016).

Since the last national integrity system assessment, additional reform steps have been enacted. In 2016, an anti-corruption strategy was adopted. Several legal reforms were also put forward. Laws were passed on civil service reform, asset disclosure, conflict of interest, illicit enrichment, whistleblower protection and access to information (Lee-Jones 2018 and Republic of Tunisia 2018). Additionally, a code of conduct for public sector employees was passed and a further anti-corruption agency was established in 2017, the National Instance of Good Governance and the Fight Against Corruption (IBGLCC) (Lee-Jones 2018).

In addition to the increasing legal and institutional reforms, Tunisian civil society has been very active and vocal on the topic of anti-corruption, helping to keep pressure on government and playing a crucial watchdog function (Lee-Jones 2018).

Tunisia also increased its performance on the Open Government Partnership between 2016 and 2018, mostly due to progress made on financial and fiscal transparency. The country has also enshrined the principle of open government in its constitution and a “national open data portal” was launched in 2016. Additionally, an e-procurement system was established, as were websites to follow up with infrastructure projects, to increase participation at the local and municipal levels, and to submit citizen petitions to the government (Republic of Tunisia 2018). According to the country’s most recent action plan for the Open Government Partnership, preparations are also underway to join the Extractives Industries Transparency Initiative (Republic of Tunisia 2018).

Palestine

In Palestine, reported levels of bribes are relatively low compared to other countries in the region, and it rates above the regional average on some governance indicators. However, perceived levels of corruption remain high, with almost 80% of Palestinians seeing the Palestinian Authority as corrupt (Dana 2015 and Kukutschka 2018). One explanation may be that many key manifestations of corruption in Palestine, such as state capture, nepotism and clientelism, abuse of positions for personal gain and a politicising of civil service, are not easily tracked through the common indicators (Kukutschka 2018).

A power monopoly within the elite, illicit enrichment at the top and the aid dependency of the economy further contribute to the problem (Dana 2015). Despite the fact that complaints relating to “wasta” (see above) were among the most common complaints received in 2018, no case was brought in front of the anti-corruption courts, indicating the ineffectiveness of the country’s anti-corruption law in addressing the issue as a crime (Coalition for Accountability and Integrity – AMAN 2018). The complete dysfunction of the Palestinian Legislative Council means there are no effective checks and balances over the executive and no monitoring of governmental budgets (Coalition for Accountability and Integrity – AMAN 2013; Dana 2015; Kukutschka 2018). Additionally, the Coalition for Accountability and Integrity, Transparency International’s local chapter, has noted a continuous decline in openness and transparency of the government and its institutions, as well as a decline in transparency and integrity in the management of public funds, leading, among others, to low levels of trust in institutions (Coalition for Accountability and Integrity – AMAN 2018).

Efforts to counter corruption are complicated by the continued Israeli occupation and the divide between the West Bank and Gaza (Coalition for Accountability and Integrity – AMAN 2013; Dana 2015). According to the country’s last NIS, the fact that the Palestinian Authority has limited actual sovereignty and authority severely affected any attempts at institution building or legal reform. The ensuing lack of political stability also complicated any attempts at a national plan or long-term strategy, as does the inner-Palestinian divide between the Palestinian Authority in the West Bank and Hamas in Gaza.

Considering this backdrop, Tariq Dana has stated that anti-corruption efforts in Palestine have tended to focus on “technical solution[s]” while ignoring the “root causes, which are embedded in the very nature of the regime” (Dana 2015: 16).

Recent developments

Some positive developments were noted in previous years, including the establishment of a Commission for Combating Corruption, progress in asset declarations, increased political transparency, improvements in public procurement and the issuance of a code of conduct for public sector employees (Coalition for Accountability and Integrity – AMAN 2013).

The anti-corruption commission was established in 2010, the same year an anti-corruption law was issued (Transparency International 2016b). The commission has financial and administrative independence, and the law defines corruption sufficiently broadly, in line with international conventions. The commission was able to conduct investigations of senior officials, including three ministers, and noted a significant increase in complaints submitted since 2011, which it attributes to a greater awareness of and confidence in the commission. It provides transparency by publishing annual reports on its website. The website also provides a complaints and submissions form (Transparency International 2016b).

According to the 2013 NIS, the election commission and civil society are both relatively strong. The judiciary, the state audit and administrative control bureau, the independent commission for human rights, and the anti-corruption commission are all likewise seen to enjoy reasonable independence and resourcing (Coalition for Accountability and Integrity – AMAN 2013). In the years since the last NIS, some notable improvements were noted by Transparency International’s local chapter (Coalition for Accountability and Integrity – AMAN 2018), even as the overall challenges relating to the occupation and inner-Palestinian conflict remain unchanged.

Positive developments were noted specifically in public service reform, (Coalition for Accountability and Integrity – AMAN 2018). These included an increased commitment to integrity in public affairs management, the approval of a strategic plan for civil service, the establishment of a code of conduct for security services, awareness raising activities on the code of conduct for public employment, and a mechanism for dealing with gifts.

In an effort to increase transparency and accountability in public service recruitment and reduce nepotism, some governmental agencies (e.g. the Ministry of Expatriates and Foreign Affairs, the Prosecution Office, and the Judicial Higher Council) have invited civil society representatives to their recruitment committees. Other public institutions advertised job postings in the media, specifying requirements and interview details, and names of interviewed and selected candidates were later published through the General Personnel Council.

A positive note was also made in the prime minister’s public commitment to integrity and safeguarding public funds, documented in a strategic plan to manage public funds (Coalition for Accountability and Integrity – AMAN 2018). Accountability also improved with the State Audit and Administrative Control Bureau (SAACB) in the West Bank continuing to “carry out its monitoring role effectively” and in its “2017 annual report exposing dozens of financial and legal administrative transgressions and violations” (Coalition for Accountability and Integrity – AMAN 2018: 6).

Accountability has also increased on a civil society level, with the Civil Society Team for Budget Transparency continuing “to review, analyse and disseminate information concerning management of public funds, and in particular in regard to revenues and expenditures stated in the public budget” (Coalition for Accountability and Integrity – AMAN 2018). Opportunities for citizen participation were also improved through the establishment of more online complaints mechanisms in several public institutions that are directly linked to the central governmental complaints system at the Secretariat of the Council of Ministers (Coalition for Accountability and Integrity – AMAN 2018).

Remaining challenges

A particular challenge in the Palestinian Territories has been that of public service delivery, particularly on health, electricity, and water and sanitation. It is difficult to disentangle to what extent corruption is to blame for inefficiencies, considering the particular political and economic situation of the region that makes service delivery a challenge (Kukutschka 2018). Electricity provision remains one of the key challenges in this regard. Effective service delivery has been hampered both by the occupation, an inability to collect fees and a misappropriation of revenues, leading to extended blackouts, especially in Gaza (Kukutschka 2018). A financially and administratively independent Electricity Sector Regulatory Council has been inaugurated with the aim of providing oversight, though concerns remain regarding how active it is (Coalition for Accountability and Integrity – AMAN 2018 and Kukutschka 2018).

Success factors and impact evaluation in anti-corruption programming

This Helpdesk review has come across very few impact evaluations on anti-corruption programming in the MENA region.

Some donor agencies have attempted to assess the effectiveness of their anti-corruption work in retrospect (DFID 2015; NORAD 2011; USAID 2014) or have derived generalised lessons from past practice (Canadian International Development Agency 2000, Council of Europe 2013). However, even here, concrete and measurable impact indicators had not been built into the programme initially, so any attempt at measuring impact retroactively comes with challenges.

Because most assessment reports come from international donor agencies, a “failure” of a specific measure might also be due to its inadequate implementation or because of unmet donor requirements, and does not necessarily confirm the inadequacy of the measure itself.

According to an evaluation of prior research by Johnsøn, Taxell and Zaum (2012), a reason for insufficient studies on the effect of interventions on corruption lies in the difficulty of measuring corruption and changes in corruption levels. Even where corruption levels are measured, establishing causality with an intervention can be difficult.

The following section summarises some general lessons to successfully conduct anti-corruption programming and looks at what factors to consider when conducting monitoring and impact assessments.

Design and implementation

Design challenges

Corruption can be understood both as a failure of institutions and legal frameworks that need reforming and as an inadequate enabling environment stemming from challenges related to socio-economic and political factors (Canadian International Development Agency 2000). Efforts to tackle corruption are thus most likely to be successful if embedded into a broader approach of institutional reform and surrounded by supporting measures (DFID 2015).

Additionally, practitioners are also advised to design approaches in a manner that is specific, and defines clear outputs and outcomes, which is especially relevant to measure impact (Canadian International Development Agency 2000; Heeks 2011). Furthermore, results should not be expected too quickly as some of the fundamental changes may take a substantial time to yield results and progress is likely to be uneven. Over-expectation is a common factor leading to programme failure according to Heeks (2011): “Anti-corruption initiatives fail because of over-large ‘design-reality gaps’; that is, too great a mismatch between the expectations built into their design as compared to on-the-ground realities in the context of their deployment”.

This can be a conundrum for policymakers. For the sake of clarity and ease of implementation, and to demonstrate successes later, very specific interventions that match the implementer’s capacity and resources are preferable. At the same time, individual initiatives that are not embedded in a more structural approach – which might well be out of the donor agencies’ control – are more likely to fail.

Generally speaking, a challenge both in the design and implementation as well as the evaluation of anti-corruption initiatives is the discrepancy between wishing to identify general road maps and component checklists, while at the same time acknowledging that there is no one size fits all and that local circumstances need to be taken into account (Heeks 2011). Where the designers of an initiative are external to the context in which it is to be implemented, careful consideration of a possible “design-reality gap” is crucial (Heeks 2011: 2).

Scharbatke-Church & Chigas (2016) have argued that designers of anti-corruption programmes too often fail to recognise the root causes of corruption and instead focus on corruption risk factors, such as opportunities or gaps in a system. They contend that while opportunities to bribe (e.g. a public official with no oversight and high discretion) will surely facilitate corruption going unchecked, they are not the reason someone pays a bribe. Anti-corruption programmes that focus only on the individual transaction and the individual culprit will fail to understand and address the diverse interacting drivers of corruption.

Design requirements

General success factors for policy and programme implementation include commitment and (political) will from the relevant stakeholders, addressing relevant needs and an efficient management of the programme (Canadian International Development Agency 2000 and Council of Europe 2013). Based on the Council of Europe’s experience of implementing anti-corruption policies, especially in Eastern Europe, recommendations include:

1. Keep policies and strategies brief and to the point so that they are manageable, accessible to the public and able to clearly identify priority areas.
2. Focus not so much on preventing corruption directly but rather focus on building a broader framework of good governance.
3. To know whether an intervention was successful and to understand whether it is contributing to its stated goals, its impact needs to be measured. Unfortunately, properly implemented monitoring and evaluation is still rare in the field. This is often due to vaguely formulated indicators. To be able to measure a programme’s impact, concrete and measurable indicators are paramount (see below).
4. Engage relevant stakeholders from the public and civil society sectors to increase legitimacy of the programme. Continuous support and engagement of relevant stakeholders and institutions is crucial to ensure buy-in.
5. Progress should be monitored and results of such monitoring should be publically available to increase accountability of the programme

In terms of process, the Council of Europe (Council of Europe 2013) recommends a thorough needs assessment before going into programme design. A needs assessment is paramount to ensure the programme responds to the challenges. Even where international experiences or frameworks are used, it is essential to adapt them to the local context. A needs or risk assessment should look at the extent and form of the challenge as well as the state and capacity of institutions and policies currently in place to tackle it.

This is a point echoed by Scharbatke-Church and Chigas (2016), who emphasise the need for a “broader and more systemic analysis” that takes into account how the different drivers of corruption interact in a given socio-economic context, considers the resilience of corruption and accounts for unintended consequences of the intervention. Such an approach would include looking at social norms that drive corruption and consider the function of corruption in political culture.

To design a robust programme that adequately addresses the complex challenge of corruption in complex environments requires, among others: the programme to be relevant based on a careful analysis of context; a definition of clear goals and theories of change across its implementation, including measurable and testable assumptions; and staying flexible and adaptive by including regular feedback loops (Scharbatke-Church and Chigas 2016: 16).

Monitoring and evaluation

Once a programme is implemented, its success should be measured based on defined outputs and indicators built into the programme.

In the absence of intervention-specific indicators, it will be impossible to attribute any possible changes to the intervention. Especially if the intervention is implemented as part of a broader framework of reforms (Johnsøn et al. 2012).

When defining indicators, the European Commission (2013)advises practitioners to:

1. consider available resources (both financial resources and capacity) when defining a monitoring strategy
2. avoid indicators of non-immediate impact (e.g. reduced levels of corruption, greater awareness) as those are very hard to measure
3. choose concrete, clear and assessable indicators (several clear indicators to measure a certain impact are preferable to one vague one)
4. be aware of the limitations of outputs and quantitative measures only in assessing success or impact

Indicators need to be tailored to the intervention and measurable to be able to attribute intervention results to changes in indicators. Using changes in external indices, such as the CPI or World Bank indicators, has often proved unsuccessful as it is generally not possible to attribute intervention outcomes to changes in those indices (USAID 2014).

From an individual practitioner’s perspective, a challenge can be the bridging of two competing truths: the literature suggests that anti-corruption programming should be focused and accompanied by measurable and achievable indicators to be able to demonstrate impact. At the same time, it is increasingly recognised that the problem of corruption will not be solved with small-scale efforts tackling just one aspect of the problem.

Anti-corruption programming will thus always need to find a balance between thinking about the big picture while designing concrete immediate interventions (Canadian International Development Agency 2000).

Conclusion

A key obstacle to the design and implementation of evidence-based anti-corruption programming is the lack of reliable research assessing its effectiveness and impact.

This lack of research stems in part from a lack of underlying data, because too few anti-corruption programmes have included clear and actionable impact indicators in their programme design, thus giving researchers little to work with (DFID 2015; Hanna et al. 2011; Heeks 2011, Johnsøn et al. 2012; NORAD 2011 and USAID 2014).

In future, robust impact assessments should be included in anti-corruption programming stating a clear theory of change and identifying measurable indicators to allow for more research in the field. This will make it possible to put future anti-corruption programming on a more evidence-based footing.

Evaluations of anti-corruption programming should also keep cost-benefit analyses in mind. Implementing organisations will need to know what works, but they will also need to know how much it will cost. Even the best-designed approach will fail if the implementing organisation does not have the capacities and resources to carry out and sustain its activities (Hanna et al. 2011; Heeks 2011). This is particularly relevant in developing and emerging market economies where many implementing organisations are dependent on external funds to execute their programmes.

While more studies on the effectiveness of different anti-corruption interventions are needed, the adequacy of common interventions themselves may also need revision.

The limited success of direct interventions has already led to a change in approach towards more mainstreaming and a more indirect approach to anti-corruption (DFID 2015 and Johnsøn et al. 2012). Little dedicated research has been done on these newer approaches to assess if they have been able to overcome some of the challenges of traditional anti-corruption programming.

New programmes and initiatives to counter corruption always need to ensure context is taken into account. Even a generally effective measure can fail when applied in the wrong context, or even exacerbate the situation. Understanding the dynamics of a given setting and developing comprehensive and inclusive programmes is thus paramount, irrespective of the type of intervention chosen. (Canadian International Development Agency 2000; Heeks 2011; Johnsøn et al. 2012; Scharbatke-Church & Chigas 2016).