A National Anti-Fraud And Anti-Corruption Strategy Print E-mail
Written by Nosa Olotu   
Wednesday, 13 June 2007

Corruption by those entrusted to run the country was the major reason put forward by Nigerians for not willing to pay more tax. This was in response to my recent article, Nigerians Need To Pay More Tax", in which I highlight the contradiction between not willing to pay more tax and demanding infrastructure and essential public services. Government on its part has initiated a movement towards fighting corruption by setting up the EFCC.

Some Nigerians have claimed that the EFCC was set up and is being used to fight and discredit government opponents. Others are of the view that EFCC is a fire fighting approach to fraud and corruption and that what is required is an effective anti-fraud and anti-corruption strategy, which:

1.      Has policy and procedures that encourages prevention (i.e. a number of comprehensive and inter-related procedures that are dynamic and designed to frustrate any attempted fraudulent or corrupt act).

2.      Promotes detection through the required audit trail presented by (1) above.

3.      Identifies a clear pathway for investigation of suspected fraud and/or corruption.

4.      Has no distinction made in investigation and action between cases that generate financial gains and those that do not (Note: corruption may not necessarily involve a financial benefit).

The strategy must be clearly understood by everyone both in government (politicians, civil servants and anyone who is paid with taxpayers money) and outside (the public, clients or contractors). What Nigerians expect on propriety and accountability is that all in government at all levels will lead by example in ensuring adherence to legal requirements, rules, procedures and practices. Equally all individuals and organisations (including suppliers and contractors) with whom the government deals will be required (inserted as a paragraph in their contract) to act with integrity and without thought or actions involving fraud and corruption.

In addition, the strategy should recognise and allow for a high degree of external scrutiny of government affairs by bodies such as:

1.      Internal and External Audit

2.      Parliamentary committee

3.      EFCC (requires more powers to carry out value for money audit)

4.      The Press

5.      Voluntary Non-governmental bodies

6.      The general public

A fertile environment for fraud and corruption is one where the government encourages secrecy. Government should pursue a policy that put its citizens first through strict adherence to a culture of openness with the core values of trust, fairness and value embedded within it.

Everyone connected with the government (i.e. political office holders, employees and contractors) should be encouraged to play an important role in maintaining a culture of openness and to raise any concerns (i.e. Speaking-Out Policy) they may have on any aspect of government activities. Government needs to enact a suitable legislation (e.g. Public Interest Disclosure Act) that offers protection to those who speak out. People who have concerns can either report these to appointed senior management responsible for probity, the Police or EFCC.

Nigeria requires an anti-fraud and anti-corruption law that is fairly draconian but provides appropriate protection for the suspects. All elected politicians and all employees should be given a handbook that details the anti-fraud and anti-corruption law, policy and guidance that place a statutory duty on them to act only in the public interest, uphold the law and do whatever they can to ensure that public funds are used in accordance with the law. The declaring of interest is part of this policy and a breach should amount to a criminal offence. The law should prohibit the acceptance of fees or rewards that are not within the normal remuneration and clearly states that failure to disclose an interest or the acceptance of an inappropriate reward will result in criminal liability. The law should make the date of conviction to be the date the person committed the offence or became aware but did not report it; whichever is the earliest. The penalty must be a jail sentence and forfeiture of all assets.

It should be made the responsibility of managers at all levels to communicate and implement the anti-fraud and anti-corruption strategy in their work area. Managers at all levels are also responsible for ensuring that employees in their department, ministry, division, branch or units, are aware of the arrangements to secure effective corporate governance. All managers should endeavour to satisfy themselves that the strategy requirements are being met in their everyday business activities. This may require creating a different or modifying the existing corporate environment such that employees feel able to approach their managers with any concerns that they may have about suspected irregularities. In addition, it should be a requirement that all managers and contractors comply with their professional bodies’ rules of conduct and ethics in the discharge of their duties.

One important factor to remember is that the key measure in the prevention of fraud and corruption is for the government to take effective steps at the employees’ and contractors’ recruitment stage to seek references to establish, as far as possible, the propriety and integrity of potential employees and contractors. This will require laid down procedures for seeking references that must be adhered to in employees and contractors appointments. EFCC needs to maintain a database that can be assessed by all government ministries and corporation, containing details of individuals and contractors found guilty of fraud and/or corruption.

Significant investment of resources needs to be put into promoting deterrence. The federal ministry of information and the press need to optimise the publicity opportunities associated with anti-fraud and anti-corruption activity within government. These will include media coverage of ongoing prosecutions, suspected fraud and any actions taken. Government and the general public should encourage investigative journalism. This can include the honouring through national awards of investigative journalists who have excelled themselves in the discharge of their journalistic responsibilities.

The initial fraud and corruption situation assessment, in most cases, should be the responsibility of management. Often suspicion arises when there appears to be a breach of the internal control system. Although an adequate internal control system is required in any fraud and corruption strategy, it is the employees and the general public alertness to the indicators that enables detection to occur. Anti-fraud and anti-corruption strategy should:

1.      Treat all fraud and corruption information consistently;

2.      Enables a proper and thorough investigation in accordance with the legal requirements;

3.      Ensures the proper implementation of an action plan after the investigation is complete; and

4.      Ensures the optimum protection of government’s interests.

The continuing success of any Anti-Fraud and Anti-Corruption Strategy and its general credibility, will depend largely on the effectiveness of programmed training and the responsiveness of employees throughout government ministries. Politicians, political office holders and employees’ induction and training should re-enforce and highlight their duties and responsibilities under the law.

In conclusion, government ministries should have in place a clear structure of systems and procedures to assist in the fight against fraud and corruption. It is essential that these arrangements be kept under review to ensure that all opportunities to take advantage of developments in techniques for preventing and detecting fraudulent or corrupt activity are maximised. Government should always pride itself on setting and maintaining high standards and a culture of openness, with core values of fairness, trust, dignity and value. The Anti-Fraud and Anti-Corruption Strategy should fully support the government’s desire to maintain such a culture, free from fraud and corruption.

If you devote your time and life to fighting corruption you would have laid a solid foundation for the future generation. People never forget those who give their lives to serve.




RobotRobot is offline 
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 # 1

It should be made the responsibility of managers at all levels to communicate and implement...Read the full article.

Posted by Robot| 14.06.2007 06:56

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Sapele ManSapele Man is offline 
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=Robot;183580>It should be made the responsibility of managers at all levels to communicate and implement...Read the full article.

Others are of the view that EFCC is a fire fighting approach to fraud and corruption and that what is required is an effective anti-fraud and anti-corruption strategy, which:

1. Has policy and procedures that encourages prevention (i.e. a number of comprehensive and inter-related procedures that are dynamic and designed to frustrate any attempted fraudulent or corrupt act).

2. Promotes detection through the required audit trail presented by (1) above.

3. Identifies a clear pathway for investigation of suspected fraud and/or corruption.

4. Has no distinction made in investigation and action between cases that generate financial gains and those that do not (Note: corruption may not necessarily involve a financial benefit).

The strategy must be clearly understood by everyone both in government (politicians, civil servants and anyone who is paid with taxpayers money) and outside (the public, clients or contractors). What Nigerians expect on propriety and accountability is that all in government at all levels will lead by example in ensuring adherence to legal requirements, rules, procedures and practices. Equally all individuals and organisations (including suppliers and contractors) with whom the government deals will be required (inserted as a paragraph in their contract) to act with integrity and without thought or actions involving fraud and corruption.

In addition, the strategy should recognise and allow for a high degree of external scrutiny of government affairs by bodies such as:

1. Internal and External Audit

2. Parliamentary committee

3. EFCC (requires more powers to carry out value for money audit)

4. The Press

5. Voluntary Non-governmental bodies

6. The general public

A fertile environment for fraud and corruption is one where the government encourages secrecy. Government should pursue a policy that put its citizens first through strict adherence to a culture of openness with the core values of trust, fairness and value embedded within it.



Hello Nosa Olotu,

This is another brilliant piece. I hope Yar'Adua reads this.

Posted by Sapele Man| 14.06.2007 13:28

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=Sapele Man;183675>

The strategy must be clearly understood by everyone both in government (politicians, civil servants and anyone who is paid with taxpayers money) and outside (the public, clients or contractors). What Nigerians expect on propriety and accountability is that all in government at all levels will lead by example in ensuring adherence to legal requirements, rules, procedures and practices. Equally all individuals and organisations (including suppliers and contractors) with whom the government deals will be required (inserted as a paragraph in their contract) to act with integrity and without thought or actions involving fraud and corruption.



Hello Nosa Olotu,

This is another brilliant piece. I hope Yar'Adua reads this.




Thank you Sapele Man.

The recent announcement by Yar'Adua that states treasury is empty is an example of the nature of the corruption problem facing Nigeria. It could have been possible to prevent that.

You noticed, even with no money in their treasuries the governors were still awarding contracts! Why? Do they get commission for every contract they awarded? One would then ask, what control mechanism could have been in place so that it could never happen?

Posted by Enforcer| 15.06.2007 22:36

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nigeria we hail thee!nigeria we hail thee! is offline 
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Thanks Nosa for your interesting articles. Let me start with ur first article on Tax...... I agree with you in principle that Nigerians should pay more tax. But it will be a herculean task convincing a man who ekes out a living by hawking 'pure water' to pay more tax when the government cannot create jobs. In the 'West', people pay tax and they see the result of their tax to the extent that people without jobs are paid benefits and provided with accomodation etc. I think the government owes its citizens some responsibility. Its a quid pro quo brother, the government does her own part of the bargain and the citizens will do theirs.

How do you expect somebody to pay tax only for the money to end up in another person's pocket? If it is true that 'Dr' Andy Uba declared an asset of 1.6 trillion naira, how much tax did he pay for the eight years that he made the money and how did he make the money? Nigeria is rich brother with or without Nigerians paying more tax. Where is the justice where a trillionaire in Nigeria pays the same tax as a typical civil servant. Yes, big corporate organisations and those trillionaires in Nigeria should pay more tax because they are milking us dry but am not sure i will say the same thing for the poor masses.

On anti-corruption......, Nigerians are generally good people. Leadership by example will go a long way in checking the nefarious activities in our system. How can Obasanjo preach corruption to a civil servant whereas he cannot explain his source of stupendous wealth? Remember that OBJ raised over 7 billion naira from his presidential libry project. He has what will pass for the biggest farm in Africa; built a private university while in office; sold most government properties to himself/cronies etc. What moral impact do you think this will have on a civil servant? How can you tell the poor police officer in Nigeria not to be corrupt when he knows his IG bought a house worth 450 million naira just by been an IG of police for 2 years? There is so much money in that country brother!

The list can go on and on and on. I remember the days of Buhari, albeit the shortcomings of his tenure, one thing is certain, Nigerians imbibed discipline in themselves. They say the fish starts to decay from its head and this is a classic example of what is happening in Nigeria.

Another way of checking corruption in Nigeria will be by making the police and other anti-corruption agencies to be INDEPENDENT. The EFCC for example should not be tied to the apron strings of the president. Ditto the police etc. A situation where EFCC needs permission from the president before they arrest or prosecute somebody makes mockery of the fight against corruption. Ka Chineke mezie okwu.

Posted by nigeria we hail thee!| 16.06.2007 06:30

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EnforcerEnforcer is offline 
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=nigeria we hail thee!;184140>Thanks Nosa for your interesting articles. Let me start with ur first article on Tax...... I agree with you in principle that Nigerians should pay more tax. But it will be a herculean task convincing a man who ekes out a living by hawking 'pure water' to pay more tax when the government cannot create jobs. ............................................................................................................................................................................................................................................................

On anti-corruption......, Nigerians are generally good people. Leadership by example will go a long way in checking the nefarious activities in our system. How can Obasanjo preach corruption to a civil servant whereas he cannot explain his source of stupendous wealth? Remember that OBJ raised over 7 billion naira from his presidential libry project. He has what will pass for the biggest farm in Africa; built a private university while in office; sold most government properties to himself/cronies etc. What moral impact do you think this will have on a civil servant? How can you tell the poor police officer in Nigeria not to be corrupt when he knows his IG bought a house worth 450 million naira just by been an IG of police for 2 years? There is so much money in that country brother!

................................................................................................................................. Another way of checking corruption in Nigeria will be by making the police and other anti-corruption agencies to be INDEPENDENT. The EFCC for example should not be tied to the apron strings of the president. Ditto the police etc. A situation where EFCC needs permission from the president before they arrest or prosecute somebody makes mockery of the fight against corruption. Ka Chineke mezie okwu.



Dear nigeria we hail thee!

The points you raised are very interesting. Let me start by quoting from the article. "Some Nigerians have claimed that the EFCC was set up and is being used to fight and discredit government opponents. Others are of the view that EFCC is a fire fighting approach to fraud and corruption and that what is required is an effective anti-fraud and anti-corruption strategy, which:
1. Has policy and procedures that encourages prevention (i.e. a number of comprehensive and inter-related procedures that are dynamic and designed to frustrate any attempted fraudulent or corrupt act).
2. Promotes detection through the required audit trail presented by (1) above.
3. Identifies a clear pathway for investigation of suspected fraud and/or corruption.
4. Has no distinction made in investigation and action between cases that generate financial gains and those that do not (Note: corruption may not necessarily involve a financial benefit)."


Don't you believe that if the above was the case in Nigeria, fraud and corruption will be minimised?

Posted by Enforcer| 17.06.2007 04:51

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nigeria we hail thee!nigeria we hail thee! is offline 
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 # 6

Yeah, i concurr with you, we are saying the same thing. There should be a rethink and re-appraisal in the so-called fight agianst corruption. Cheers

Posted by nigeria we hail thee!| 17.06.2007 08:50

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Sapele ManSapele Man is offline 
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=nigeria we hail thee!;184140>.........................................................................................................................................................................................................................................................

On anti-corruption......, Nigerians are generally good people. Leadership by example will go a long way in checking the nefarious activities in our system. How can Obasanjo preach corruption to a civil servant whereas he cannot explain his source of stupendous wealth? Remember that OBJ raised over 7 billion naira from his presidential libry project. He has what will pass for the biggest farm in Africa; built a private university while in office; sold most government properties to himself/cronies etc. What moral impact do you think this will have on a civil servant? How can you tell the poor police officer in Nigeria not to be corrupt when he knows his IG bought a house worth 450 million naira just by been an IG of police for 2 years? There is so much money in that country brother!

The list can go on and on and on. I remember the days of Buhari, albeit the shortcomings of his tenure, one thing is certain, Nigerians imbibed discipline in themselves. They say the fish starts to decay from its head and this is a classic example of what is happening in Nigeria.

Another way of checking corruption in Nigeria will be by making the police and other anti-corruption agencies to be INDEPENDENT. The EFCC for example should not be tied to the apron strings of the president. Ditto the police etc. A situation where EFCC needs permission from the president before they arrest or prosecute somebody makes mockery of the fight against corruption. Ka Chineke mezie okwu.



Hi nigeria we hail thee,

There might not have been any corruption in the process of raising the required funds for the library project. I think OBJ took advantage of the fact that a significant number of Nigerians are bootlickers who will donate to the project to promote their selfish interest.

On the second issue of junior police officers being corrupt because their bosses are does not hold water. It is akin to a child saying he took up stealing because his father is a renowned thief. Neither do I accept that civil servants are corrupt because they are on low income.

Corruption is a consequence of greediness. That is, people wanting to live above their means. It can never be justified.

Posted by Sapele Man| 18.06.2007 17:45

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EnforcerEnforcer is offline 
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=Sapele Man;184805>Hi nigeria we hail thee,

There might not have been any corruption in the process of raising the required funds for the library project. I think OBJ took advantage of the fact that a significant number of Nigerians are bootlickers who will donate to the project to promote their selfish interest.

On the second issue of junior police officers being corrupt because their bosses are does not hold water. It is akin to a child saying he took up stealing because his father is a renowned thief. Neither do I accept that civil servants are corrupt because they are on low income.

Corruption is a consequence of greediness. That is, people wanting to live above their means. It can never be justified.



Sapele Man,

The nature of the police command is that the junior officers have no real choice but to do as told.

Posted by Enforcer| 20.06.2007 03:54

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Sapele ManSapele Man is offline 
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=Enforcer;185232>Sapele Man,

The nature of the police command is that the junior officers have no real choice but to do as told.




The most honourable thing to do therefore is to leave the police force. Eh?

Posted by Sapele Man| 20.06.2007 16:49

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