Anti-corruption and the role of civil society in monitoring IMF emergency funding

99 civil society organizations have urged the IMF to consistently and formally include anti-corruption measures in its COVID-19 pandemic-related emergency funding and take concrete steps to help protect and empower civil society groups to monitor these funds.

Managing Director Kristalina Georgieva International Monetary Fund
700 19th Street NW Washington, DC 20431

Re: Anti-corruption and the role of civil society in monitoring IMF emergency funding

Dear IMF Managing Director Kristalina Georgieva:

We are 99 civil society organizations located around the world and we are writing to request that the International Monetary Fund consistently and formally include anti-corruption measures in its Covid-19 pandemic-related emergency funding and take concrete steps to help protect and empower civil society groups to monitor these funds.

We are profoundly aware of the devastating scale of the global economic crisis due to the Covid-19 pandemic, and the urgency of providing governments the funds they need to effectively respond. As organizations that closely monitor corruption and its impacts, we also know that transparency and accountability are key to making sure the money the IMF is disbursing actually goes to protecting lives and livelihoods.

Recognizing this, you urged governments during the Spring 2020 Meetings to “spend what you   can but make sure to keep the receipts. We don’t want transparency and accountability to take the back seat in this crisis.” However, most IMF loan agreements include few or no government commitments to mitigate the risk of corruption. Instead, the Fund appears to be taking a largely retroactive approach that relies on the good faith of governments and the close eye of independent monitoring groups.

We appreciate that the urgent need for immediate funding and the nature of the Rapid Credit Facility (RCF) and Rapid Financing Instrument (RFI) – the primary instruments for disbursing emergency funding – constrain the Fund’s ability to implement robust anti-corruption measures. However, some governments that have received funds through these mechanisms, such as Gabon,1 have committed to transparency and anti-corruption measures, including:

  • Receiving all emergency funds in a single account with the Treasury and creating a new budget line for coronavirus-related
  • Publishing a procurement plan that includes the names and beneficial ownership information of companies awarded
  • Agreeing to an independent audit within six months of receiving the

The inclusion of these measures in some cases suggests that it is possible to do so without undue delay. The Fund should apply such measures consistently to all emergency funding.

Moreover, as the Fund has acknowledged, even these measures would be insufficient to adequately ensure accountability because emergency funding is provided in lump-sum payments. In our communications with the Fund, both staff and board members have emphasized that they intend for civil society groups to play a vital role in filling that gap by closely monitoring government spending and communicating their concerns to the IMF.

We are grateful that the Fund recognizes the crucial role civil society organizations play in holding their governments accountable, but this is a stopgap measure in the absence of more robust anti- corruption monitoring efforts by the IMF. It would also be imprudent for the Fund to rely on our oversight role without taking concrete steps to protect and strengthen our ability to effectively monitor these funds. Many of our groups work in countries where government spending is opaque, auditors do not exist or are not independent, and authorities do not tolerate criticism. Even where they can operate safely, many groups lack the technical capacity and resources to effectively monitor the billions of dollars in funding that the IMF is disbursing.

To protect and strengthen civil society monitoring of emergency funding, we urge the Fund to take the following measures:

  1. Require transparency. Monitoring groups are neither law enforcement nor the government’s lender, both of which have authority to investigate and control the funds. The Fund should consistently apply transparency and anti-corruption measures to all loans, such as requiring governments to conduct independent audits and publish procurement plans, including the names and beneficial owners of all companies awarded
  1. Protect groups’ ability to operate. Numerous countries have laws that limit freedom of association and expression in ways that undermine the ability of civil society groups to safely operate or effectively monitor IMF funds. For example, Sri Lanka has ordered police to arrest those who criticize government officials involved in the coronavirus response.2 In other cases, there is no law or formal order explicitly prohibiting criticism of government policies, but officials nevertheless retaliate against those who criticize them. The Fund should require governments to commit to respecting the rights of civil society groups and repeal or amend laws that prevent groups from safely monitoring government spending.
  1. Formally recognize the role of monitoring groups. Monitoring groups can provide the Fund with valuable information regarding government spending, but they need a safe and effective channel to do The IMF should formally recognize independent monitoring organizations as stakeholders in loan agreements and establish a channel for them to report allegations of wrongdoing. It should consider engaging select groups as independent monitoring organizations in contexts where corruption risks are especially high.
  1. Strengthen groups’ capacities. The IMF’s unprecedented levels of spending, and the importance of the funding in light of the pandemic’s economic impact, has made monitoring government spending of IMF funds a new priority for many of our organizations. At the same time, the economic crisis means that many of our groups have even fewer resources than usual to The Fund should conduct virtual trainings to help build organizational capacity to monitor funds and consider providing willing groups with necessary resources, especially in countries where there are few well-resourced groups monitoring government spending.

You opened this year’s Spring Meetings by noting that extraordinary times call for extraordinary action. The Fund should apply the same creativity and sense of urgency it has shown to support governments to help civil society groups ensure IMF funds go to the people who need it most.

We would be happy to meet with you to discuss these issues in more detail and would appreciate learning what steps you have taken in this regard.


Abibiman Foundation
AbibiNsroma Foundation (ANF)
2 Human Rights Watch, “Sri Lanka Uses Pandemic to Curtail Free Expression,” April 3, 2020,

Accountability Lab
Actions for Development and Empowerment
Africa Development Interchange Network (ADIN)
Africa Network for Environment and Economic Justice (ANEEJ)
AHAM Humanitarian Resource Center
Alliance Sud
Alyansa Tigil Mina (Alliance to Stop Mining)
American Jewish World Service
Arab Watch Coalition
Asamblea Permanente de Derechos Humanos de Bolivia
Ayiti Nou Vle A
BudgIT Foundation
Buliisa Initiative for Rural Development Organisation (BIRUDO)
Cairo Institute for Human Rights Studies (CIHRS)
Center for International Environmental Law (CIEL)
Center for Social Awareness, Advocacy and Ethics
Center for Democratic Education
Centre for Environmental Justice
Centre for Human Rights and Development
Connected Development
Consumer Unity and Trust Society Zambia
Corporación Acción Ciudadana Colombia - AC-Colombia
Development Alliance NGO
Eastern Social Development Foundation
Ensemble Contre la Corruption-ECC
Environics Trust
Etika Asbl, Luxemburg
Facing Finance
FIDH (International Federation for Human Rights)
First Peoples Worldwide
FORES - Argentina
Foundation for the Conservation of the Earth (FOCONE)
Freedom House

Fundación Ambiente y Recursos Naturales
Gambia Participates
Global Legal Action Network
Global Network for Sustainable Development
Global Witness
Green Advocates International
Heartland Initiative
Human Rights Online Philippines (HRonlinePH)
Human Rights Watch
Indian Social Action Forum
Integrity Initiatives International
Interfaith Center on Corporate Responsibility
International Accountability Project (IAP)
International Campaign for the Rohingya
Jamaa Resource Initiatives
Liberia CSO Anti-Corruption Coalition - LCACC
Living Laudato Si' Philippines
Mongolian Women's Employment Supporting Federation
NGO Forum on ADB
Nigeria Network and Campaign for Peace Education
North East Coordinating Committee
Oil Workers' Rights Protection Organization Public Union
Oyu Tolgoi Watch
PEFA Forum
Phenix Center for Economic Studies
Philippine Misereor Partnership Inc.
Photo Circle
Positivo Malawi
Project Blueprint
Rchard Matey
Réseau Camerounais des Organisations des droits de l'homme
Rights CoLab
Rivers without Boundaries Mongolia

Sano Paila (A Little Step)
Sayanaa Wellbeing Association
Shadow World Investigations (formerly Corruption Watch UK)
Sibuyan Against Mining / Bayay Sibuyanon Inc.
Slums Information Development and Resource Centers (SIDAREC)
Task Force Detainees of the Philippines
The Future We Need
Universal Rights and Development NGO
Witness Radio Organization – Uganda
Women’s Action Network
WoMin African Alliance
YES Project Initiative
Youth Empowerment & Leadership Foundation
Youth Group on Protection of Environment
Zambia National Education Coalition

1 IMF, Gabon: Request for a Purchase Under the Rapid Financing Instrument, April 16, 2020, Under-the-Rapid-Financing-Instrument-Press-Release-Staff-Report-49336.

2 Human Rights Watch, “Sri Lanka Uses Pandemic to Curtail Free Expression,” April 3, 2020,





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