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Project Case Study

Strengthening Action Against Corruption in Ghana

Increasing the Risks of Engaging in Corruption in Ghana

Strengthening Action Against Corruption (STAAC), a UK-funded £9.7 million programme (2016-2020), was designed to increase the risks of engaging in corrupt behaviour by working simultaneously with anti-corruption institutions and accountability actors in Ghana. STAAC took an approach of tactical support along the anti-corruption chain, recognising that no single agency can tackle corruption alone.

STAAC provided technical support to detection and investigation functions of the state as well as support to prosecution and adjudication functions. It established an issue-based and adaptive collaborative approach with civil society, media and private sector to work with the state and hold it to account on its anti-corruption response. These combined efforts strategically delivered to institutionalise approaches that tackle corruption.

The STAAC Story

Strengthening Action Against Corruption in Ghana (STAAC) was a UK-funded five-year programme that ran between January 2016 and December 2020. It was designed to address concerns that increasing levels of corruption posed a risk to development progress in Ghana. STAAC had a budget of approximately £9.7 million, spread around four technical workstreams and core programme management. On the state side, STAAC followed a chain-linked approach that envisaged anti-corruption as a sequence of functions: detection, investigation, prosecution and adjudication. On the civil society side, STAAC established an Accountability Working Group (AWG) as a collaborative and strategic grant mechanism that assisted civil society partners in targeted advocacy efforts.

STAAC was forced to operate in a political-economy context rife with challenges as well as opportunities.

STAAC’s lessons should resonate beyond Ghana. For the global anti-corruption movement, the programme demonstrated great value – to read about it in detail, please download the full report below.

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STAAC Issues - Learning from the programme

STAAC has drafted several briefing papers on key activities carried out by the programme and its partners over the course of its lifetime. Find out more about STAAC’s work on each of these focal areas below.

Addressing Corruption in Ghana's Upstream Petroleum Contracting

In 2017, Ghana had 16 petroleum agreements with multi-national companies for the purposes of exploration and production and oil, which was discovered commercially in 2006. A lack of information on compliance with contractual terms led STAAC’s partner, the Africa Center for Energy Policy (ACEP), to conduct research and identify a pattern of unmet obligations and unpaid taxes, leading to a loss of revenue.

ACEP created a public online contract monitor and used the evidence to engage stakeholders in a non-adversarial way to improve performance, leading to a recovery of $1.5 million in taxes.

Read more about STAAC and ACEP’s work on addressing corruption in Ghana’s upstream petroleum contracting in this briefing paper.


Developing Ghana's Beneficial Ownership Transparency Regime

Ghana’s commitment to establish a Beneficial Ownership Register was hampered by gaps in legislation, a dearth in technical capacity, and a limited understanding on the part of external actors about the constraints faced by Ghanaian institutions.

STAAC worked with the Registrar General’s Department and key national stakeholders on a multi-layered strategy for advancing Beneficial Ownership Transparency (BOT), including technical capacity-building, brokering of new partnerships with law enforcement, high-level policy engagement, and the drafting of the 2019 Companies Act to provide legal foundations for Ghana’s BOT commitments.

As a result Ghana’s BO register was announced in October 2020, and will support detection of money laundering and corruption for years into the future.

Download the briefing paper to find out more about STAAC’s work on the Beneficial Ownership Register in Ghana.


Strengthening People's Action Against Corruption in Health Care Delivery in Northern Ghana

Informal payments are a widespread corrupt practice in most public health facilities in northern Ghana, one that has denied basic healthcare to poor and vulnerable people. STAAC worked with a group of civil society actors under the SPAAC (Strengthening People’s Action Against Corruption) coalition to tackle petty corruption by increasing the responsiveness of national, regional and local health authorities and institutions.

SPAAC followed a consensus-building approach to engage government stakeholders and build a broad-based citizen constituency, introducing a range of initiatives to improve accountability. As a result, citizens in the northern regions became more vigilant and demanding, leading to increased monitoring of illicit payments by the National Health Insurance Authority.

Read more about the work that STAAC and SPAAC did in strengthening people’s action against in corruption in health care by downloading the briefing paper using the link below.


Building an Adaptive Results Framework

Monitoring, Evaluation and Learning are intrinsic to adaptive management, enabling programmes to gather data, assess contributions, and learn from what works during implementation. 

The STAAC programme was designed to work in a complex and uncertain reform environment but given a results framework that was overly prescriptive and restrictive. 

The team iterated theories of change and logframes until it settled on a flexible, functional approach that did not predetermine partners or intervention areas. 

The adaptive MEL approach enabled the programme to manage its performance and remain accountable whilst its portfolio changed in response to new opportunities, non-performing areas, and changes to the budget and time frame. 

STAAC’s approach was costly in terms of staffing, and hard to communicate, which should remind implementers and donors to adequately resource MEL in adaptive programmes seeking to tackle complex problems.

Read more about STAAC’s adaptive approach to results frameworks in the report below.


Transforming Ghana’s Financial Intelligence Centre

Ghana’s Financial Intelligence Centre (FIC) was established in 2008 to detect and analyse suspicious transactions that could constitute money laundering and other financial crimes.

The FIC relied on manual processes to manage tens of thousands of reports and was unable to support law enforcement with intelligence products.

STAAC partnered with the FIC in 2016 to design and implement a holistic organisational change approach, re-engineering the FIC’s People, Processes, and Technology to deliver on its mandate.

With this support, the FIC became one of West Africa’s most efficient and effective financial intelligence units, overseeing the private sector, interfacing with other financial detection agencies, responding to law enforcement intelligence needs, and coordinating efforts to bring Ghana into compliance with FATF recommendations.

This case demonstrates the value of trust-based partnerships that focus on problem identification and strategic accompaniment to deliver systemic and sustainable impact.

You can read the whole case study by downloading the report below.


Adaptive Mentoring in Financial Crime Investigations

There is significant criminal activity between accomplices based in Ghana and other jurisdictions, and yet Ghanaian law enforcement agencies rarely link crimes or source intelligence from foreign counterparts.

STAAC deployed a Mentor with a context-sensitive and flexible approach to understanding day-to-day practices and identifying opportunities for capacity building.

As new challenges were identified, the Mentor broadened the engagement strategy from a purely tactical focus to working with senior supervisors on strategic organisational challenges.

Through hands-on support to investigators, the Mentor was able to develop systems and collaboration processes for working with other financial intelligence and law enforcement agencies, in Ghana and in the UK, which shortly thereafter yielded life-saving gains for victims of romance-type fraud.

This experience shows the value of combining bottom-up problem identification with top-down trust building, taking a realistic approach to changing organisational culture, and generating momentum for change from within.

To read the full case study, please download the report below.


Brokering state-society collaboration in the establishment of the Office of the Special Prosecutor

The Office of the Special Prosecutor was a campaign promise intended to respond to Ghana’s lacklustre efforts to investigate and prosecute grand corruption.

The new institution would have to be developed in a context of perceived politicisation, limited technical capacity, and concerns about overlap and duplication of functions.

STAAC adopted a two-track approach: working with state institutions to build understanding and support for the OSP and facilitating a consultative process whereby civil society was able to influence the draft bill.

The resulting OSP Act was the first time that proceeds of crime were regulated thoroughly in Ghanaian law, and a demonstration that state and civil society could work together to strengthen proposed governance reforms.

The lacklustre performance of the Office in the years since its creation shows that new legislation is just the beginning for anti-corruption, and that coordinated, technically proficient follow through by civil society and donors is required to ensure governments deliver on their commitments.

To learn more, please download the full case study on the link below.


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