giovedì 14 agosto 2014

A Critical Analysis of Anti-Corruption Agencies [ESSAY]



A critical analysis of anti-corruption agencies
Author: Alessandro D'Alessio


Anti-corruption agencies (ACAs) are public funded bodies that have the specific duty to tackle corruption through both repressive and preventive activities and, in general, are built under acts of an executive or legislature decree[1].

The first ACAs can be traced in the postcolonial period after World War II. European countries decided to create such agencies in order to restore the reputation of their colonial administrators and to establish new authorities free from corrupt practices. Singapore’s Corrupt Practices Investigation Bureau (CPIB), established by the British colonial government in 1952, the Anti-Corruption Agency of Malaysia (ACA) in 1967 and the Hong Kong’s Independent Commission Against Corruption (ICAC), established by Governor Murray MacLehose in 1974, are considered to be the most effective ACAs becoming also role-models for many other agencies all around the globe.

When the Cold War ended the location of such bodies shifted from developing to developed countries because corruption soon became a topic discussed without those stereotyped vision that caused it to be restricted to the southern hemisphere for too many years. The Australian New South Wales Independent Commission Against Corruption (NWS ICAC), born in 1988, as well as the French Service Central de Prévention de la Corruption (SCPC), born in the early nineties, were both a response to a wave of scandals that involved those countries. Moreover the European Union accession process required countries to implement policies against corruption creating specific agencies like the Lithuanian Special Investigation Service (STT) in 1977 and the Croatian Office for the Prevention of Corruption and Organised Crime (USKOK) in 2001. Since corruption was perceived as a global problem, the anti-corruption efforts became global too.

Political consensus often brought to the creation of ACAs especially after crisis or scandals. Governments consider these agencies as the ultimate reaction to corruption also because of the perceived failure of the conventional law enforcement bodies like police, attorney-general offices, courts, etc. However most ACAs, set up in a context of systemic corruption, have miserably failed sometimes because of the lack of management/planning or problems related to their institutional design.

According to the most influential policy analysis of economic literature, corruption is a “principal-agent” problem[2]. In order to act in their interests, principals have to choose, motivate and monitor their agents. Anti-corruption reforms involve a re-alignment of incentives, an establishment of new and appropriate equilibrium of punishment and reward to foster agents’ behaviour as well as an enhancement of information systems. Other social sciences disciplines consider corruption as something that’s “within parallel structures of organisation and allegiance that have only a tangential relationship to formal state structures. […] Networks and alliances rely on exchanges to meet their objectives – and they may use elements of the state and the political system to mediate these exchanges. Many such exchanges are corrupt, in that they violate norms proscribing the use of public power for private gain”[3]. So institutions themselves can be corrupt, facilitating irregular exchanges and creating a vicious cycle where causes and consequences are strongly intertwined and solutions for corruption are difficult to find. If politicians are corrupt they would probably weaken the effectiveness of the judicial system which in turn causes more corruption. Therefore anti-corruption efforts should involve as much people and institutions as possible, also beyond traditional fences.
If governments want to tackle corruption they should publicly recognise the problem trying also to build bridges with the opposition in order to introduce a comprehensive anti-corruption plan; members of the opposition could become members of watchdog bodies supervising the institutional reform process. Governments should cooperate with NGOs too in order to bring the most influential of them on their side adopting a “non-confrontational” stance. In this way the phenomenon of corruption is depoliticised, gaining greater chances of success. The executive power has to establish a good relationship with the media, for example involving the police and the prosecutors to investigate public persons, including members of the governing party. The government has to deal with the business sector too and, in order to ensure support, the best strategy is to downsize the state or to low taxes as well as to avoid instability and political crisis that can be very harmful for the economic actors[4]. On their side, it’s fundamental for ACAs to remain as much as possible outside of the political dispute, so as to maintain a bipartisan support.

Each anti-corruption agency is unique in the sense that its creation is the product of specific legal and institutional patterns. Some countries provide them with prosecution and investigative powers while others choose a more educational, informative and preventive role. There has been also an increasing transfer of knowledge among countries. However governments have too often just copied the “successful models” showing no interest in the specific cultural and institutional context in which they would operate. In fact, ACAs encounter a set of difficulties in their action because of problems related also to the revelation of corrupt activities via complaints as well as obtaining information about corruption from other state agencies[5]. These aspects may considerably affect the effectiveness of their activities.

There are a series of requisites that classify an agency as an ACA. The first one is “distinctiveness” which means the agency has to be clearly different from other enforcement bodies in terms of competences as ACAs’ main objective is primarily to combat corruption. Both the development of “preventive and/or repressive” dimensions of control and the “durability” feature are other important requisites. An ACA needs also to have “powers to centralise information” (collection, storage, processing, diffusion; information hub) and an interface that allows the “articulation” of initiatives undertaken by other control actors. Other fundamental requisites are “knowledge production and transfer” (role of research, membership of and participation in international forums and networks) and the “rule of law” (accountability to sovereign authority, checks and balances). However practically just a few ACAs succeed in fulfilling all these requirements because a standard model still doesn’t exist.

ACAs are also increasingly intertwined with the international levels since world institutions have always recommended the creation of such agencies as a fundamental part of the grand strategy against corruption.
The Organisation for Economic Co-operation and Development (OECD) strongly implemented “ethics infrastructures” within member states suggesting the creation of specialised and independent agencies while, in 1997, the Committee of Ministers of the Council of Europe, through the Resolution (97) 24 on the Twenty Guiding Principles for the Fight Against Corruption, drew the attention to the need “to ensure that those in charge of the prevention, investigation, prosecution and adjudication of corruption offences enjoy the independence and autonomy appropriate to their functions” as well as the need of specialised and trained people[6].
On their side the Inter-American Convention against Corruption (IACAC), the African Union Convention on Preventing and Combating Corruption and the United Nations Convention against Corruption (UNCAC) suggested the creation of these agencies too.

In 2007 the OECD produced a document entitled “Specialised Anti-Corruption Institutions: Review of Models” attempting to identify three different types of agencies:

1)   The “Multi-purpose Agencies with Law Enforcement Powers” that can be described as anti-corruption agencies stricto senso with repressive and preventive powers like technical assistance in prevention, information, public outreach, investigation and monitoring. In order to preserve checks and balances the prosecution power is often separated and this is also due to the independency and range of powers of this ACA model. Examples of this type are the Hong Kong Independent Commission Against Corruption (ICAC), the Singapore Corrupt Practices Investigation Bureau (CPIB) and the New South Wales Independent Commission Against Corruption (NSW ICAC).

2)   The “Law Enforcement Type Institutions” is the most common model in Western Europe and is characterised by a mix of prosecution, investigation and specialised anti-corruption detection competences, including research, prevention and coordination activities. Examples are the United Kingdom Metropolitan Police/Anti-corruption Command, the Spanish Fiscalía Anticorrupción and the Romanian National Anti-Corruption Directorate (DNA).

3)   The “Preventive and Policy Co-ordination Institutions” is a model that includes mainly preventive competences. The ACA can also have responsibilities related to researches in the anti-corruption field as well as assessing the risk of corruption, coordinating and monitoring local and national anti-corruption strategies, implementing codes of ethics and promoting cooperation with the civil society. Examples are the France’s Service Central de Prévention de la Corruption (SCPC), the Permanent Commission against Corruption in Malta and the United States Office of Government Ethics[7].

Despite all these differences there are some common recognisable features among all the anti-corruption agencies. The “independence” which is mainly referred to ACAs’ operational autonomy since they have to be free from political interferences in order to tackle corruption properly; the “inter-institutional cooperation and networking” because ACAs are part of a control system, sharing competences with other national bodies, but also part of international networks. Such networks are important to transfer knowledge across institutions; organisations like the Group of States Against Corruption (GRECO) of the Council of Europe, the International Association of Anti-Corruption Authorities (IAACA) and OLAF’s Anti-Fraud Communicators Network are considered to be professional networks offering also training to ACAs officials and promoting best practices. “Recruitment and specialisation” and “wide competences and special powers” on their side are necessary because the main reason of ACAs’ existence is often the inadequacy of legal and criminal provisions in force, so their mission is to go beyond and fight also those behaviours that are reprehensible but not unlawful. “The role of research” is another fundamental characteristic that can be extremely useful to guarantee a knowledge-based approach in tackling corruption, carrying out empirical researches about different aspects of the phenomenon, while “durability” is relevant for an agency because it can assure its effectiveness as well as a long-lasting existence[8].

ACAs must be clear in defining their focus. Indeed it’s important for them to choose specific activities such as prevention, monitoring or choosing cases through different criteria. The Hong Kong agency has a prospective jurisdiction, concerned only with past cases; all the cases are referred to the Operations Managers Committee, within the ICAC itself, after an evaluation made by an Assessment Panel. The Anti Corruption Office (ACO)[9] of Argentina is based on pre-defined standards, choosing cases selectively; while others like the United States agency deals only with the honesty of the public service. On the other side the Singapore’s CPIB has the power to investigate crimes without selection criteria; while, according to the 1987 Philippines Constitution, the Office of the Ombudsman can “investigate and prosecute on its own or on complaint by any person, any act or omission of any public officer or employee, office or agency, when such act or omission appears to be illegal, unjust, improper or inefficient”[10].

The Argentine ACO introduced a new way to pursue cases based on three criteria: economic, institutional and social[11].
The economic one is based on the analysis of the amount involved in the case, i.e. the investigation starts only if such amount affects the functioning of a government institution; the institutional criterion is based on a qualitative analysis and the cases are investigated only when they can prevent the accomplishment of institutional functions of government institutions; finally, following the social criterion, a case needs to be investigated when a corrupt act can prevent a great number of people from receiving public services.

Jeremy Pope, co-founder of Transparency International (TI), believed that the most important elements that make an effective ACA are its preventive activities, the monitoring of the government’s anti-corruption policies, the right to access documents and witnesses, power to seize travel documents and freeze assets as well as the ability to protect informants. He also suggested that ACAs’ tasks should concern only small investigations and monitoring units, keeping their size at a minimum level. Pope was concerned with the independence of ACAs and recommended a few structural protections like placing the ACA in a position where it is not directly subject to political or ministerial dictates, the provisions for appointment and removal of senior ACA officials and a direct role for public stakeholders who provide a discrete political base for the agency[12]. Petter Langseth, International Good Governance and Anti Corruption Consultant, proposed that agencies should have some sort of legislative role too, submitting reform bills to the parliament. He also underlines the importance of including the creation of an ACA in a wider national anti-corruption strategy[13].

Alan Doig, senior coordinator for programmes & activities at the International Anti-Corruption Academy (IACA), considers an ACA to be an “island of competence” in the public sector, suggesting that they have the possibility to solve only few specific problems like officials’ ethical honesty and government’s credibility. Doig believes that the ideal anti-corruption agency model should primarily link evaluations and research to a long-term agenda of reforms and capacity building[14]. Other observers, like Kaufmann, stress the importance of the reorganisation of the public and economic sectors in order to achieve a better implementation of the anti-corruption policies[15].

What are the main activities of an ACA? Due to their heterogeneity, it is difficult to give a unique answer; for this reasons, in this evaluation I have considered three ACAs (the Hong Kong ICAC, the Philippines Ombudsman[16] and the Argentinian Anti Corruption Office, ACO), for which seven tasks can be identified:

·      Managing information on corruption. An ACA centralises all information and intelligence about corruption and, through vertical integration, solves coordination issues, asserting leadership. The number of successful prosecutions as well as the number and quality of institutional reforms designed to combat corruption and the intensity of anti-corruption activities across society are indicators of the so called “intermediate outcomes” of an ACA. These outcomes are linked to how well certain core anti-corruption activities are performed – the “output measure”.

·      Receive and respond to complaints. A typical and demanding task for the ACAs is their relationship with citizens and firms. The ICAC in 2012 registered 3932 complaints, 63% of them were related to the private sector, 30% concerned with government departments and 7% with public bodies. In the last few years over 70% of the complainants who decided to report corrupt activities were willing to reveal their identities[17]. In 2013 the Office of the Ombudsman in the Philippines received 6158 complaints, 87% of which were evaluated[18]; while the Anti Corruption Office (ACO) in Argentina recorded 615 complaints even though to 86% of them didn’t follow a judicial proceeding[19].

·      Intelligence and monitoring. Almost all agencies provide data regarding this area although such information shows very little about the quality of the efforts. Argentina ACO has the competence to evaluate and monitor the content of sworn declarations of public officers and situations that could bring to illicit enrichment or incompatibility within the full use of their powers. The Philippines Ombudsman Estela Perlas-Bernabe launched a Complaint and Case Monitoring System and she has the competence to monitor the submission of Statements of Assets, Net Worth of government officials and Liabilities. The Hong Kong ICAC, instead, controls its activities through the adoption of a partnership approach. Such method is characterised by the mobilisation of many different sectors against corruption and, in the case of the ICAC, the government agencies are the most important strategic partners[20].

·      Prosecutions and administrative orders. Holding a trial against a person who is accused of a corruption crime is not an activity conducted by every ACA, indeed most of them can only investigate while other institutions carry out the prosecution. The Argentinian ACO performance data show that around 2000 investigations started between 1999 and 2002, 82% of which were solved while 18% were still going [21] [22]. The Philippines Ombudsman exceeds all other countries in terms of number of prosecutions (around 7000 in 2012) although there’s a serious comparability problem since the agency is the only one having powers to prosecute on its own. The Hong Kong ICAC statistics show that 111 cases were prosecuted in 2012, with a person-based conviction rate of 78% and a case-based conviction rate of 84%[23]. However it’s difficult to comment further such rates without knowing the quality of the proceedings.

·      Preventive research, analysis, and technical assistance. An important task of ACAs concerns the research and the analysis about the diffusion and the forms assumed by the phenomenon, as well as the technical assistance to public and private bodies that want to adopt anti-corruption measures. For example the Argentina ACO elaborates programmes of corruption prevention and promotion of transparency of public governance and it is also integrated with the “Centro de Investigación y Prevención de la Criminalidad Económica” an NGO concerned with the investigation and prevention of economic crimes[24]. The Office of the Ombudsman is assisted by the Corruption Prevention Units, which are civil society organisations, in disclosing corrupt activities in the bureaucracy, and by the Junior Graftwatch Units that helps the Ombudsman through the introduction of honesty and efficiency in the society as well as awakening young citizens’ consciousness[25]. On its side the Hong Kong ICAC has a statutory duty to check procedures and practices of public bodies and government departments and the law requires the Commission to provide corruption prevention assistance on request to any member of the public.

·      Ethics policy guidance and compliance review. Anti-corruption behaviours can be promoted by means of several further tools. For example the ICAC, through the Ethics Development Centre, promotes business and professional ethics on a long-term basis[26]; it also provides a series of documents like “Ethics In Practice-A Practical Guide for Professional Engineers” or “Our Statement Of Business Ethics-ICAC” that provide guidance for different sectors of the society, explaining why ethics standard are important and furnishing a guide for good professional practices[27]. Among the powers hold by the Office of the Ombudsman there’s also the “the observance of high standards of ethics and efficiency” and the need “to serve as a model in promoting the highest standards of ethics in the entire government bureaucracy”[28] [29]. The ACO, on its side, not only reports an almost perfect compliance rate (“99.9% compliance rate by the civil servants required to file a financial disclosure statement”, 1999-2002)[30] but provides ethics guidelines through several publications like “Ética, transparencia y lucha contra la corrupciòn en la administraciòn pùblica. Manual para el ejercicio de la funciòn pùblica”[31], which is concerned with ethics standards provided to tackle corruption in the public administrations, and “Guìa para el docente” that is an educational tool provided by the British Embassy, the United Nations Development Programme (UNDP) and the ACO for teachers[32].

·      Public information, education and outreach. The Community Relations Department is the body in charge of the ICAC for the education of the public and a recent annual opinion survey shows that 98% of respondents believed that the ICAC deserved their help[33]. The education and promotion aspects of the Philippines Ombudsman are concerned with regular updates for employees and officials through Strategic Planning Seminars, Research Symposium, Teaching Exemplars, Ehem Aha Seminars, Orientation Lectures and Briefing, Research/Thesis Assistance Program as well as projects related to the public such as: a radio program called “Magsumbong sa Ombudsman”; a television program called “Ombudsman: Kakampi mo Laban sa Katiwalian”; publication of anti-corruption materials and a nationwide accessibility of the services (website, hotlines and e-mails)[34]. The Argentinian ACO provides education about prevention and transparency through a series of publications that can be also downloaded from their website[35].

Measuring the performance of ACAs is important but very complicated. In fact, evaluating the results of the above tasks can be tricky because data might be inconsistent or just untrustworthy. For example, it’s not clear if an increase of complaints is a good indicator, as people trusts institutions and reports corruption crimes more than before, or bad, as a result of wider corruption activities. Moreover data about various activities of ACAs tell us more about the quantity of activities rather than the quality of the efforts implemented by the agencies and the effectiveness of its activity in terms of outcomes (the reduction of the corruption). That’s why it’s better to rely on more indicators, also external ones like the Transparency International Corruption Perception Index (CPI), and different performance data. Among the above mentioned ACAs, the Hong Kong ICAC seems to report better data on outcomes.
According to the senior programme coordinator of Transparency International Ran Liao, the levels of corruption of Hong Kong in the 1970s can be compared to the ones of Argentina today. While in the CPI 2013 Hong Kong scores 75[36] out of 100[37], so it’s perceived to be less corrupt than United States and France; Monica Yu, executive director of the Hong Kong Ethics Development Centre (an ICAC division), affirmed that the people of Hong Kong nowadays will never tolerate corruption and that there’s a lot of cooperation in terms of reporting cases to the ICAC[38].

It’s important to understand why some anti-corruption agencies have been successful and why others have failed.
In general the success of an ACA does depend on many different factors such as: a wide anti-corruption strategy, performance measurement, strong political backing and realistic expectations. Another fundamental element that can lead an ACA to success is the cross-agency relationships. Since ACAs operate along with sister agencies it’s appropriate to secure cooperation among them to maximise the efforts. For example both the Australia NSW ICAC and the Uganda IGG cooperate with other bodies to improve their effectiveness while the Argentina ACO had to face serious problems related to its relationships with the President, the Congress and the courts too.

Moreover there are also a series of conditions like political stability, public order, the absence of macroeconomic crisis, a link between anti-corruption success and political gain along with some basic features of the rule of law[39] that need to co-exist in order to tackle corruption efficiently and maximise ACAs’ efforts. However, these conditions cannot be found in most poor countries and overwhelming dimensions of corruption can make any anti-corruption effort useless. In a deeply corrupt environment maybe short-term successes are still achievable through an anti-corruption agency but structural problems cannot.

The experiences of the Hong Kong ICAC and Singapore CPIB agencies, both considered to be very successful[40] [41], were born from a crisis of legitimacy that caused serious threats to political stability and investors confidence. The reaction to such a situation was the creation of new institutions with enough powers to tackle corruption; indeed ICAC and CPIB present many common elements but also some important differences. The first one’s budget is approximately around $90 million[42] and it’s used to follow up all allegations and complaints linked with preventive measures and the development of reforms as well as to a program of community outreach. On the other side the CPIB is much smaller with a budget of only $4 million[43] even though the investigative mandate of the agency is as broad as that of ICAC.

The Hong Kong ICAC succeeded in doing investigations that lead to prosecution and conviction of powerful businessmen and senior officials, it caused the “ethics climate” to change through education, outreach and example, along with citizens’ help in overseeing and reporting corruption cases. Starting the fight against corruption with effective enforcement on major targets is extremely useful to show the government’s determination to the public. This latter, in fact, would be reluctant in reporting corrupt activities, that’s why every successful anti-corruption set of actions must include this implementation that acts also as a deterrent[44]. The ICAC adopts a three pronged strategy based on: 1) deterrence, through the Operations Department, 2) prevention, through the Corruption Prevention Department, and 3) education where the Community Relations Department conducts activities that lead the public to a deeper knowledge of the phenomenon of corruption[45].
The Hong Kong ICAC model has had a huge influence on other agencies around the world. Among these there are the Australia NSW ICAC, created in 1988, and the Botswana DCEC, born in 1994. The DCEC, although has adopted the ICAC design almost completely, presents some differences with the Hong Kong original since its jurisdiction to take white-collar crimes is expanded but it has far more modest resources causing its effectiveness to be severely limited.
Many other agencies have been inspired by the ICAC embodying also many innovations. For example, the Uganda IGG implemented public sector codes of conduct while Ecuador CCCC delineates citizen oversight through a board chosen by civic bodies.

The Singapore CPIB is also considered to be a great success because of the investigations of many “big fish” including MPs, senior directors in companies and ministers as well as the setting of a new moral tone of government that caused the creation of a very clean administration. Other reasons that explain the success of this ACA are: extremely disposable officers towards the public especially when people needs to complain corruption or give information; the effectiveness of the anti-corruption law; a mature society that reports corruption with no fear of reprisal as well as a general anti-corruption feeling[46]. The Singapore CPIB represents also an example of how strategy is important. Indeed, in 1960, the CPIB was reformed in a comprehensive anti-corruption strategy that combined deterrence and removal of opportunities through heavier penalties and preventive actions.

The Philippines Ombudsman has shown instead some problems related to lack of independence towards the President as well as a low conviction rate especially during the last years when the Office has been headed by Merceditas N. Gutierrez[47] (2005-2011). However we can consider the overall results quite satisfactory particularly during the Simeon V. Marcelo era (2002-2005) when the former President Joseph Estrada was also convicted for plunder because of investigations started by the legal team of the Ombudsman[48]. The Argentina ACO showed some successes during its early years but it has recently drawn some criticism; that’s because of its low performance in prosecution[49] and, since it’s subordinate to the government, it lacks of independence[50].

The Organisation for Security and Co-operation in Europe (OSCE) in 2004 affirmed that generally ACAs had obtained poor results with just a few exceptions like the ICAC and the CPIB. The reasons why ACAs have been more successful in East Asia are still not totally clear apart from the fact that in those countries the agencies have a strong political and public support as well as meticulous investigative methods, research abilities, innovative programmes of public education and prevention. Alan Doig shows that having an ACA presents some advantages, for example the government can send signals to the public showing how much is taking the problem of corruption seriously or the achievement of high levels of expertise. Doig underlines that there are also some disadvantages like higher administrative costs or the creation of potential rivalries among institutions. He also suggests some complementary institutional reforms that can reinforce the performance of anti-corruption incentives like the establishment of independent investigators and prosecutors, a transparent system to get rid of privileges, mechanisms that can protect whistle-blowers, civil penalties and blacklisting of corrupt companies.    

Anti-corruption agencies were born because of governments will to tackle corruption. This essential reason means that there is an official recognition of the problem and that ACAs represent the official response of the State to corruption. Unfortunately many governments do not seem to be able to put up an efficient and effective agency for their country. Indeed, for governments is important to take into account the specific context in which the ACA has to work. This means they have to consider, among other factors, also culture and, sometimes, all those peculiar behaviours that are very close to a corrupt activity (e.g. the “Guanxi”[51] in China). Changing cultures and especially rooted traditions is a long-term and difficult task and it’s achievable through educational programmes. However, in order to fulfil such improvements, governments need to be strongly determined and have enough money to invest.
An ACA alone is not enough. It has to be supported by a clear national and local anti-corruption plan to put the country on a virtuous cycle and slowly eradicating, or drastically reducing, the problem; so a wide anti-corruption strategy is the necessary step forward and, if correctly embedded in its country’s reality, good results can be obtained.
Since some agencies are relatively recent, for example the Argentina ACO was founded only in 1999, it is sometimes too early to affirm whether they’ve been successful, also because it can take a while before those optimal conditions that lead to a decline of the levels of corruption occur; that’s why in such cases the analysis should be repeated in the future and the present results taken cautiously.
                                                                







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[1] de Sousa L., Hindess B., Larmour P., (2012), “Governments, NGOs and Anti-Corruption: The New Integrity Warriors”, Routledge, p. 8
[2] Rose-Ackerman, S., (1978), “Corruption: A Study in Political Economy”, New York: Academic Press.
[3] Meagher P., (2005), “Anti-corruption Agencies: Rhetoric Versus Reality”, The Journal of Policy Reform Vol. 8, No. 1, 69–103, March 2005, p. 77
[4] de Sousa L., Hindess B., Larmour P., (2012), “Governments, NGOs and Anti-Corruption: The New Integrity Warriors”, Routledge, pp. 92-94
[5] de Sousa L., (2009), “Anti-corruption agencies: between empowerment and irrelevance”, Springer Science + Business Media B.V. pp. 5-11
[6] http://www.coe.int/t/dghl/monitoring/greco/documents/Resolution(97)24_EN.pdf
[7] OECD, (2007), “Specialised Anti-Corruption Institutions - Review Models”, Anti-Corruption Network for Eastern Europe and Central Asia.
[8] De Sousa L., (2009), “Anti-corruption agencies: between empowerment and irrelevance”, Springer Science + Business Media B.V. pp. 13-18
[9] The Argentine Anti-Corruption Office (ACO) was founded in 1999, replacing an ineffective predecessor agency.
[11] Meagher P., (2005), “Anti-corruption Agencies: Rhetoric Versus Reality”, The Journal of Policy Reform Vol. 8, No. 1, 69–103, March 2005, pp. 69-73
[12] Pope, J. (1999), “The need for, and role of, an independent anti-corruption agency prepared for Transparency International (TI)”, 13 August.
[13] Langseth, P, (2001), “Anti-corruption agencies, experts meeting, National Integrity Steering Committee (NISC)”, 22 January.
[14] Doig, A., (1995), “Good government and sustainable anti-corruption strategies: a role for independent anti-corruption agencies?”, Public Administration and Development, May, pp. 151–165.
[15] Kaufmann, D. (1998), “Revisiting anti-corruption strategies: tilt towards incentive-driven approaches, Corruption & Integrity Improvement Initiatives in Developing Countries”, UNDP.
[16] Created in 1987, it has the task to control all three branches of the government. The Offices of the Ombudsman includes the Ombudsman's own office as well as offices for a team composed of a Sheriff, the Ombudsman's second in command, and 6 other deputies who lead their respective divisions.
[21] The ACO website doesn’t provide more recent performance data.
[30] Meagher P., (2005), “Anti-corruption Agencies: Rhetoric Versus Reality”, The Journal of Policy Reform Vol. 8, No. 1, 69–103, March 2005, pp. 82-85
[37] The Index scores 177 countries and territories on a scale from 0 (highly corrupt) to 100 (very clean).
[39] Kaufmann, D., (1998), “Revisiting anti-corruption strategies: tilt towards incentive-driven approaches, Corruption & Integrity Improvement Initiatives in Developing Countries”, UNDP.
[41] Research in Public Policy Analysis and Management,(2008),“Comparative Governance Reform in Asia: Democracy, Corruption, and Government Trust”, Emerald Group Publishing Limited.
[49] The ACO can only investigate but if there is evidence of a crime it can request the prosecution through the Department for Investigations.
[51] “A Chinese term meaning networks or connections, understood to be a network of relationships designed to provide support and cooperation among the parties involved in doing business[…]”. Guanxi can be best understood by the old axiom, "it's not what you know, but who you know that's important”. http://www.investopedia.com/terms/g/guanxi.asp, 13/5/14

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