Financial Crime World

Title: Togo’s New Anti-Fraud and Corruption Measures in Millennium Challenge Account Funding

Introduction

Millennium Challenge Account (MCA)-Togo manages $35 million ICT and LRAP projects funded by the United States government through a Threshold Program. MCA-Togo, in partnership with the Millennium Challenge Corporation (MCC), aimed to ensure these funds contribute to reducing poverty in Togo by fostering economic growth without compromising them due to fraud or corruption.

New Anti-Fraud and Corruption (AFC) Action Plan

MCA-Togo has announced new measures outlined in the AFC Action Plan to minimize fraud and corruption risks throughout the programs. The plan provides transparency to various stakeholders to assess the implementation of the AFC Action Plan through semi-annual updates.

  • Recipients of Funding: Applies to MCA-Togo’s board of directors, staff, government entities, consultants, contractors, and grantees.
  • High-risk Areas: Focuses on five high-risk areas where additional preventive measures are required.

High-risk Areas and Preventive Measures

  1. ICT Regulator strengthening

    • Regular engagement with stakeholders
    • Transparency in processes
    • Unannounced monitoring visits

  2. Development of land reform methodologies

    • Implementing an effective land management system
    • Clear communication and transparency
    • Public review and consultation

  3. Submission of fraudulent data for cost savings or time efficiency

    • Implementing a data verification system
    • Regular internal audits and checks
    • Penalties for non-compliance

  4. Uneven representation on Technical Evaluation Panels (TEP)

    • Stakeholder engagement and transparency
    • Establishing a diverse panel
    • Regular assessments

  5. Corruption of contract managers validating erroneous/falsified deliverables

    • Implementing a strong contract management system
      • Transparency and communication
      • Regular performance reviews
      • Penalties for non-compliance

Program-wide Measures

  • Posting of AFC posters at all job sites
  • Training with program grantees
  • Training for new MCA-Togo staff

Partnership and Collaboration

MCA-Togo and MCC, along with various organizations such as the Organization for Economic Cooperation and Development (OECD), the United Nations Office on Drugs and Crime (UNODC), and the World Bank, established an AFC working group to review and discuss the AFC Action Plan using the Anti-Corruption Ethics and Compliance Handbook methodology.

Conclusion

MCA-Togo and MCC continuously provide regular updates on the implementation and revisions to the AFC Action Plan to ensure the highest standards of transparency and accountability.