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Compliance and Risk Management in Mongolia: A Focus on Public Financial Management, Procurement, and Anticorruption

In its efforts to improve governance and anti-corruption practices, the Asian Development Bank (ADB) has been implementing a range of measures to strengthen compliance and risk management in countries where it is active. In Mongolia, a sector risk assessment carried out in 2008 highlighted significant vulnerabilities and risks in public financial management, procurement, and anti-corruption.

Public Financial Management Risks

The assessment found that Mongolia’s legal, policy, and institutional frameworks remain inadequate to mitigate or obviate risk in national and sectoral systems. Public finance management is weakened by:

• The lack of medium-term action plans to guide resource allocation
• Local authorities not widely consulted in setting sectoral budgets
• Government limited capacity to implement development policies and reform

Procurement Risks

Procurement risks include:

• Lack of capacity, knowledge, and adequate training to equip professional procurement officers to dispatch their duties fairly and transparently
• Political interference, conflicts of interest, and corruption within national and sectoral procurement systems

Risk Management Plan

To address these risks, the ADB has developed a risk management plan that focuses on public financial management, procurement, and anti-corruption. The plan includes measures such as:

• Providing training in ADB financial management procedures to key staff of the Ministry of Health (MOH)
• Clearly delineating responsibility for project implementation
• Supporting internal audit functions

Procurement Measures

In terms of procurement, the plan requires all procurement to be carried out by MOH, with assistance from the Project Implementation Unit (PIU). The PIU will provide training on procurement processes, supervision, and monitoring for staff involved in procurement. To prevent fraud and corruption:

• Regular reviews of procurement procedures will be conducted
• All contract awards will be made public

Anticorruption Measures

The plan also emphasizes the importance of anti-corruption measures, including:

• Implementation of external monitoring of civil works
• Spot reviews of procurement and financial procedures
• Strengthening internal controls and audit systems to ensure good governance, accountability, and transparency in project operations

Conclusion

Overall, the risk management plan aims to reduce the risk of non-compliance with ADB regulations and processes, while promoting good governance and anti-corruption practices in Mongolia’s health sector.