Why we need to 'mainstream' corruption


By Les Dobie, CIPFA's Head of Counter Fraud Training

CIPFA's recent international conference was hosted in partnership with the Center of Excellence in Finance (CEF) in Skopje, Macedonia and online at the end of June. The conference brought together renowned international and regional experts, including CIPFA's head of counter fraud training, Les Dobie. Les spoke about anti-corruption, the need for professional training and our new international anti-corruption training programmes. His remarks are below.

For many around the world, corruption is a mainstream issue – one which is widespread and commonplace. We know that in many countries, corruption dominates and damages the political process, society and people's lives. But what is not mainstream is how it is tackled, and there are, in my view, a number of reasons and excuses why this is so.

Firstly, there is the well-known difficulty of framing corruption into a single definition. I would question the validity of this, as the United Nations Convention Against Corruption (UNCAC) is quite clear on what corrupt behaviours are and almost every country in the world, if not all countries, have anti-corruption laws in place that define what constitutes corruption.

Secondly, corruption is primarily looked at through the lens of criminality and law enforcement. This is understandable, as a large number of corrupt behaviours, though not all, are criminal acts. Focusing on the legal view of corruption is problematic for a number of reasons:

  • It can give licence to organisations and professionals to avoid confronting their own responsibilities in tackling corruption. It's easy to say, "it's a law enforcement issue and therefore not our responsibility to deal with it and we're not the experts anyway." It is also true that dealing with incidences of corruption can be difficult, unpleasant, and in some cases risky – more understandable reasons why people tend to steer clear of it.
  • Another issue is that law enforcement agencies are largely reactive. By the time a case of corruption comes to them it's too late – the deed and the damage has been done and unwinding this can be costly, time consuming and the result uncertain. 
  • Finally, like all public sector organisations, law enforcement has finite resources even if the agency is solely dedicated to anti-corruption. Where corruption is widespread, there will not be the resources to investigate it. Figures from the last crime survey of England and Wales, covering 2020, help illustrate this. The survey states that there were almost 3.5 million cases of fraud, which includes incidences of corruption such as bribery, embezzlement and money laundering. It is said about 0.5% of law enforcement manpower in England and Wales is solely dedicated to combatting the fraud problem, which is roughly around 500 men and women. So that's 7,000 cases per person per annum – an impossible task.

What, then, is the solution? A former commissioner of the City of London Police says that law enforcement cannot investigate or arrest its way out of the UK's fraud problem, and it is up to individuals, businesses and organisations to help themselves. As in all but the most serious cases, law enforcement will probably not step in. I believe the same approach applies to corruption across the world. There simply isn't enough law enforcement to effectively tackle it and we therefore must help ourselves. In other words, instead of treating the threat at arms-length or something we feel isn't our business, we need to 'mainstream' corruption into our day-to-day activities and treat it as a business-as-usual issue.

Reassuringly, some initial steps have already been taken in this direction. On 3 June 2021, the Office of the President of the United States issued the 'Memorandum on Establishing the Fight Against Corruption as a Core United States National Security Interest', also known as 'The Biden Memo'. This means that, as far as the US is concerned, combating corruption, particularly the prevention of corruption, is not just about financial misconduct. It is now a core national security issue. It is interesting to note from the memo that while some of the agencies that are helping to build the strategy going forward are law enforcement, others, such as departments for energy and commerce are not. This supports the notion that corruption is not just a law enforcement issue.

The memo also talks about bolstering capacity and capabilities of government departments to combat corruption. This raises the question of how? At CIPFA, we believe there is an alternative to the usual top-down approach characterised by demonstrating anti-corruption credentials through the signing of conventions like UNCAC and OECD, and making well-intended declarations of zero tolerance.

Instead, we want to see more of a bottom-up approach involving the empowering of individuals - those on the ground who are close to where the problem is happening, who are often the targets of the corrupt and where the transactions are occurring. The aim is to try and stop the problem upstream and at source; applying what is called 'Sutton's Law': to consider the obvious first (Willie Sutton, the famous US bank robber, when asked why he kept robbing banks is alleged to have replied 'That's where the money is').

Being more proactive and focusing on individuals is what we are now trying to achieve at CIPFA. We want to create a global cadre of anti-corruption specialists within public bodies whose responsibility will be to champion the anti-corruption cause and be the experts in corruption risk assessment and prevention and, if it comes to it, investigation as well. CIPFA champions common standards in public sector accounting in the UK and across the globe. This has created a common language and understanding of accounting, which brings with it many benefits. We want to replicate this when it comes to anti-corruption, creating consistency of approach and a common language. In essence, we want to professionalise anti-corruption.

The foundation of any profession is, of course, education and standardised training. Under CIPFA's royal charter, which gives us the licence to advance the science and study of public finance, accountancy and cognate subjects in the public interest, we are creating two certified anti-corruption qualifications. One is focused on the professional investigation of corruption to a standard that would be recognised by law enforcement and courts of law and is currently being piloted in an east African country with several government agencies. The other focuses on corruption risk assessment and prevention, and is scheduled for launch at the end of this year when we hope to showcase it at the Conference of State Parties to the UNCAC being held in Egypt.

The purpose of the risk assessment qualification is essentially to train employees to implement a corruption management system across an organisation – a whole system approach. These individuals will have an expert understanding of what corruption is from a risk perspective and how to mitigate those risks before they crystalise into corruption events. Put simply, it's the operationalisation of Chapter II of UNCAC, which is the chapter that talks about prevention.

Of course, training in and of itself isn't the complete answer as there must also be systems and processes in place to support the work of the anti-corruption specialist and that's something we can work with organisations to help establish. We are currently working on plans to pilot this approach, again in East Africa, to create a 'whole-government' approach to anti-corruption, starting with the appointment within government departments of Integrity Focal Persons, the chosen name for their anti-corruption champions, which brings us back to the importance of 'mainstreaming' corruption.

In summary, through professional training and ongoing development in specialist corruption-related subjects, such as anti-money laundering, procurement, licensing and so on, CIPFA's aim is to empower individuals to try and stop the corruption problem upstream and at source, bringing it into the mainstream, day-to-day activities of organisations and treating it as a business-as-usual issue. We believe this is an essential step in the right direction and we are now exploring what additional support we can provide to help create and sustain the network of anti-corruption professionals we are seeking to establish.

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