International organisations, bribery and Covid-19: the undecidable problem

Monday 18 May 2020

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Nicola Bonucci
Paul Hastings, Paris


Is the corruption virus spreading under the cover of the more famous Covid-19 virus?

While half the world faces an unprecedented lockdown and governments, as well companies, have nothing else on their minds than make urgent and crucial decisions, international organisations have decided not to remain passive in the face of increasing risks of corruption:

  • On 8 April 2020, three majors non-governmental organisations (NGOs) wrote to the Executive Board of the International Monetary Fund (IMF) on the ‘Urgent need for anti-corruption measures in IMF’s response to Covid-19’.[1] On 5 May, the IMF released a statement explaining how it promotes 'transparent and accountavbe use of Covid-19 financial assistance'.[2]
  • On 21 April 2020, the Council of Europe’s Group of States against Corruption (GRECO) published a set of guidelines addressed to its 50 Member States, aimed at preventing corruption in the context of the health emergency caused by the Covid-19 pandemic.[3]
  • On 22 April 2020, the Organisation for Economic Co-operation and Development (OECD) Working Group on Bribery, the intergovernmental body in charge of monitoring the implementation of the OECD Anti-Bribery Convention issued a unprecedented public statement adopted by consensus entitled ‘The global response to the coronavirus pandemic must not be undermined by bribery’.[4]

In addition, UNDOC has issued a brochure on the allocation and distribution of emergency economic rescue packages during and in the aftermath of the Covid-19 pandemic;[5] while on 1 May, the World Bank Group announced the appointment of Mouhamadou Diagne as Vice-President of Integrity at the World Bank Group.

What strikes any interested observer is that this coincidence in timing gives almost the impression that the actions were coordinated. While I doubt this to be the case, it would be unwise to consider that these international institutions are moving at the same pace and in the same direction only by accident.

News in the media is already highlighting alleged cases of corruption such as the investigations into the Colombian Minister of Agriculture.[6] It is easy to imagine that other cases will be forthcoming over the next few months.

Some may argue that: strong but adaptable internal control and compliance systems; agile, transparent and fair public decision making; and an effective fight against corruption are three sides of an ‘impossible triangle’. However, as Nelson Mandela once said ‘it always seems impossible until it’s done’. Today, the collective responsibility of public authorities, private sector, civil society and international organisations is to prove Nelson Mandela was right.


[1] ‘Re: Urgent need for anti-corruption measures in IMF response to COVID-19 crisis’, joint open letter from Transparency International, Global Witness and Human Rights Watch, 8 April 2020, available at: ://www.transparency.org/files/content/feature/TI_HRW_GW_Letter_IMF_COVID19_Emergency_Funding.pdf, last accessed 12 May 2020.

[2] IMF, 'How the IMF is Promoting Transparent and Accounatble Use of COVID-19 Financial Assistance', available at: www.imf.org/en/About/Factsheets/Sheets/2020/04/30/how-imf-covid19-financial-help-is-used, last accessed 20 May 2020.

[3] ‘Corruption Risks and Useful Legal References in the context of COVID-19’, statement from GRECO, Council of Europe, 15 April 2020, available at: https://rm.coe.int/corruption-risks-and-useful-legal-references-in-the-context-of-covid-1/16809e33e1, last accessed 12 May 2020.

[4] ‘The global response to the coronavirus pandemic must not be undermined by bribery’, statement by the OECD Working Group on Bribery, 22 April 2020, available at: www.oecd.org/corruption/the-global-response-to-the-coronavirus-pandemic-must-not-be-undermined-by-bribery.htm, last accessed 12 May 2020.

[5] ‘Accountability and the prevention of corruption in the allocation and distribution of emergency economic rescue packages in the context and aftermath of the Covid-19 pandemic', United Nations Office on Drugs and Crime, available at: www.unodc.org/documents/Advocacy-Section/COVID-19_and_Anti-Corruption-2.pdf, last accessed 12 May 2020.

[6] Zdravko Ljubas, ‘Colombian Officials Accused of Misusing Covid-19 Funds’, Organized Crime and Corruption Reporting Project, 28 April 2020, available at: www.occrp.org/en/daily/12207-colombian-officials-accused-of-misusing-covid-19-funds, last accessed 12 May 2020.

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