Rushing to Disburse
The IMF’s COVID-19 Disbursements to Sub-Saharan Africa, the Fiduciary Environment, and the Governance Safeguards Failure
Executive Summary
Between March 2020 and August 2021, the IMF mobilised approximately US$26 billion in emergency financing for 45 Sub-Saharan African countries. The justification was a projected COVID-19 health catastrophe. Sub-Saharan Africa, with 14 percent of the global population, accounted for roughly 2 percent of confirmed global deaths. The emergency that justified the speed and scale of disbursement was not, in Sub-Saharan Africa, the emergency that materialised. The disbursements went out anyway. The repayment obligations followed.
The governance safeguard framework the Fund deployed was, in the IMF’s own language, a checklist. Fewer than a majority of staff involved in emergency financing said the governance commitments were useful in preventing diversion of funds. They said this to the Fund’s own evaluators. The IEO published their responses. The institution continued to describe the same commitments as safeguards.
This paper documents what that architecture produced across seven country case studies: Malawi (Auditor General found widespread malfeasance); Nigeria (Accountant General convicted for systematic misappropriation; only one of four governance commitments implemented); Kenya (KEMSA procurement scandal; 97 percent of supplies undelivered); South Africa (three special audit reports finding overpricing, unfair practices, and potential fraud); Senegal (ministerial embezzlement; five former ministers charged in May 2025); Togo (court of auditors documented rice scandal; complete absence of procurement framework); Zimbabwe (Draxgate — two-month-old Hungarian shell company received US$60 million contract). Seven countries. Seven documented fiduciary failures.
The repayment dimension completes the picture. The countries received disbursements and repaid them in full, under obligations set at the point of disbursement and not adjusted to reflect the subsequent institutional acknowledgement of design failure. The institution that designed a flawed instrument, accepted unenforceable commitments, and processed the subsequent governance failures without accountability collected full repayment. The borrowers bore the entire cost.
The Epidemiological Record: Africa’s COVID-19 Experience
| Indicator | Sub-Saharan Africa | Global Total | SSA Share (%) |
|---|---|---|---|
| Population (2020) | ~1.12 billion | ~7.79 billion | ~14.4% |
| Confirmed cases (end-2020) | ~1.7 million | ~84.4 million | ~2.0% |
| Confirmed deaths (end-2020) | ~38,000 | ~1.84 million | ~2.1% |
| Confirmed deaths (Apr 2021) | ~100,000 | ~2.85 million | ~3.5% |
| GDP contraction 2020 (actual) | -2.0% | -3.1% | — |
| GDP contraction projected (Apr 2020) | -1.6% to -3.0% | -3.0% | — |
| Country | Pre-COVID Proj. | COVID-era Proj. | Actual 2020 | Variance vs. Projection |
|---|---|---|---|---|
| Burkina Faso | +6.0% | +0.9% (Jun WEO) | +1.9% | +1.0 pp better |
| Côte d’Ivoire | +6.7% | +1.8% (Jun WEO) | +2.0% | +0.2 pp better |
| Malawi | +5.1% | +1.0% (May) | +0.6% | -0.4 pp worse |
| Nigeria | +2.5% | -5.4% (Jun WEO) | -1.8% | +3.6 pp better |
| South Africa | +0.8% | -8.0% (Jun WEO) | -6.4% | +1.6 pp better |
| Zambia | +1.7% | -5.1% | -2.8% | +2.3 pp better |
The emergency disbursement architecture was calibrated to a worst-case epidemiological scenario that did not materialise. SSA accounted for under 4 percent of global COVID-19 deaths while receiving over half of all country-level IMF financing requests in 2020. The Fund’s own forecasting process incorporated a deliberate pessimistic bias, and staff acknowledged the unreliability of the epidemiological data underpinning their projections. The scale of the response was disproportionate to the realised emergency and was not adjusted downward as the actual data emerged.
Scale and Instruments: What Was Released, to Whom, and How Fast
Total Fund financial support to the 45-country AFR region reached approximately US$26 billion during the pandemic period, compared with US$4.6 billion across 2018–19 — a roughly six-fold surge. The August 2021 SDR allocation added a further US$33 billion. The primary instruments were the Rapid Financing Instrument (RFI) for middle-income countries and the Rapid Credit Facility (RCF) for low-income countries — both expressly designed for speed over scrutiny.
| Country | Instrument | Amount (US$m) | % of Quota | % of GDP | Month Approved |
|---|---|---|---|---|---|
| Burkina Faso | RCF + CCRT | 172 | 70% + CCRT | 1.2% | Apr / Nov 2020 |
| Côte d’Ivoire | RCF/RFI blend | 1,164 | 130% | 2.0% | Apr / Nov 2020 |
| Malawi | RCF (×2) + CCRT | 241 | 100% | 2.4% | May / Oct 2020 |
| Nigeria | RFI | 3,400 | 100% | 0.8% | Apr 2020 |
| South Africa | RFI | 4,287 | 100% | 1.1% | Jul 2020 |
| Zambia | None disbursed | — | — | — | — |
IEO data show that COVID-19 financing approved by the World Bank was on average six times higher for AFR countries receiving Fund support than for those without, and AfDB approvals approximately twice as high (IEO BP/23-01/07, para. 87). The finding supports a qualified gatekeeping argument: in the majority of AFR cases, Fund engagement was associated with substantially higher multilateral financing activity, making the adequacy of the Fund’s governance safeguard framework consequential for the broader official creditor response.
The Fiduciary Baseline: Governance Conditions at Point of Disbursement
| Country | TI CPI Rank (2019) | TI CPI Rank (2021) | GHS Index Score | Debt Distress Risk | CPIA Score |
|---|---|---|---|---|---|
| Burkina Faso | 78 / 180 | 78 / 180 | 34.4 / 100 | Moderate | N/A |
| Côte d’Ivoire | 106 / 180 | 105 / 180 | 32.9 / 100 | Moderate | 3.5 / 6 (FM: 4.0) |
| Malawi | 123 / 180 | Last quartile 2013–19 | 27.8 / 100 | High | N/A |
| Nigeria | 146 / 180 | 154 / 180 | 37.0 / 100 | N/A (MAC) | N/A |
| South Africa | 70 / 180 | 70 / 180 | 47.5 / 100 | N/A (MAC) | N/A |
| Zambia | 113 / 180 | 113 / 180 | 28.0 / 100 | High | N/A |
The IEO Evaluation Report provides direct confirmation that governance risk profiles were not constraining access decisions. Analysing Fund financing levels against Transparency International CPI scores across the full emergency financing population, the IEO finds little correlation between countries’ financing levels and external perceptions of corruption. Governance quality was not a meaningful constraint on access. The governance commitment framework was layered on after access decisions were made; it did not constrain them.
The governance and PFM baseline of the majority of emergency financing recipients was poor to very poor at the point of disbursement. In the cases where ex-post audits were conducted — Malawi, Nigeria, South Africa — all three identified significant irregularities. The IEO’s own analysis finds little correlation between countries’ financing levels and external corruption perceptions. Governance quality was not a meaningful constraint on access.
The Governance Safeguard Architecture: Design, Application, and Failure
The Fund’s governance safeguard framework coalesced around four standard commitments formally endorsed by the Board in October 2020: (1) publication of procurement contract information; (2) collection and publication of beneficial ownership information; (3) preparation of a COVID-19-related spending report; and (4) conduct and publication of an ex-post independent audit.
| Country | Contract Publication | Beneficial Ownership | Spending Report | Ex-Post Audit | Overall Status (May 2022) |
|---|---|---|---|---|---|
| Burkina Faso | Partial (with delay) | Circular issued May 2022 | Yes | Yes | Late / Partial |
| Côte d’Ivoire | Yes (public bank website) | Not required (pre-Oct 2020) | Yes | Yes | Largely Met |
| Malawi | Yes | Partial | Yes | Yes — revealed malfeasance | Commitments met; substance failed |
| Nigeria | Yes (1 of 4 fully met) | Not implemented | Partial | Delayed / infeasible | Substantively Failed |
| South Africa | Partial (incomplete) | Directors only (not owners) | Yes | 3 reports, found fraud | Partial / Ongoing |
| Zambia | N/A | N/A | N/A | N/A | No disbursement |
The four-commitment governance safeguard framework was structurally mismatched to the institutional failure modes of recipient countries, was applied as a documentation exercise rather than an operational control mechanism, and demonstrably failed to prevent misappropriation in the three countries where ex-post audits were conducted. The framework’s design reflects assumptions about fiduciary risk profiles that do not hold in the SSA context.
The Staff Survey: Insider Testimony on the Governance Failure
The IEO’s separate staff survey (BP/23-01/06, February 2023) surveyed 1,903 IMF staff in the economist career stream. The response rate was 12.3 percent (234 completed responses). The Fund’s own professional staff, speaking anonymously to its own evaluators, described what they believed was happening to the money they were disbursing.
| Response | Share of Respondents |
|---|---|
| Strongly agree | 13% |
| Agree | 46% |
| Disagree | 24% |
| Strongly disagree | 17% |
| Program Design Element | Strongly Agree | Agree | Disagree | Strongly Disagree |
|---|---|---|---|---|
| Prior Actions | 12% | 54% | 24% | 10% |
| Access Levels | 15% | 59% | 18% | 8% |
| Governance Commitments | 15% | 47% | 25% | 12% |
Forty-one percent of staff directly involved in emergency financing doubted that governance commitments prevented fund diversion. Governance commitment guidance was the weakest-scoring program design category. Approximately 40 percent found epidemiological guidance insufficient. Thirty percent believed access was not even-handed. Fewer than 40 percent felt country teams were adequately resourced. The Fund’s frontline staff knew the framework was inadequate; structural institutional incentives did not translate that knowledge into operational reform before the disbursements occurred.
Country-Level Evidence: Documented Fiduciary Failures
Malawi: Foreseeable and Foreseen — The Cashgate Echo
Malawi received US$241 million in emergency disbursements (100% of quota across two RCF tranches plus CCRT debt relief) against a High Risk debt distress classification and a well-documented institutional history. The 2013 “Cashgate” scandal — systematic looting of the Consolidated Fund through fabricated payment vouchers, estimated at US$32 million over six months — remained a live institutional reference point.
The Audit Findings
A 2021 forensic audit by Malawi’s Auditor General found approximately 6.2 billion Kwacha — a material proportion of the emergency disbursement — had been used irregularly. Specific findings included:
- Unprocedural procurement: contracts awarded without competitive tender, in violation of the Public Procurement and Disposal of Assets Act
- Irregular allowances: per diem payments to officials without supporting documentation or evidence of travel
- Payments for goods never delivered: invoices settled in full with no evidence of goods received, consistent with the phantom-supplier mechanism at the heart of Cashgate
- Wasteful expenditure: procurement at prices materially above market rate, with no documentation of price justification
IMF staff acknowledged in IEO interviews that they were “aware of the considerable risks” of providing light-conditionality financing just ahead of a presidential election, in a country with Malawi’s institutional history. The governance safeguards were subsequently characterised by area department staff as a “checklist exercise.” Sources: Malawi National Audit Office, Special Audit on COVID-19 Funds (2021); IEO BP/23-01/07 (2023).
Nigeria: The Man Running the Treasury — Ahmed Idris and the RFI
Nigeria received US$3.4 billion through the RFI in April 2020. By May 2022, two years post-disbursement, only one of four governance commitments had been fully implemented. The independent audit was formally declared infeasible due to Nigeria’s federal structure.
The Accountant General’s Conviction
On May 16, 2022, Nigeria’s EFCC arrested Ahmed Idris, the serving Accountant General of the Federation. By July 2022, Idris faced 14 counts of theft and criminal breach of trust totalling approximately N109 billion (roughly US$265 million). One count alleged that between February and December 2021 — the COVID emergency spending period — he had accepted over N15 billion in gratifications for accelerating specific financial transfers. He was convicted on multiple counts in 2024.
What the IMF Already Knew
The Fund had available to it before approving the disbursement: a 2019 PEFA assessment documenting low budget credibility, weak procurement, and a finding that the Auditor General lacked independence; and six years of AFRITAC West 2 engagement with Nigerian institutions on precisely those PFM weaknesses.
The Idris prosecution is not a post-hoc revelation. It is a confirmation of conditions the Fund’s own technical staff had spent six years documenting. The governance safeguard framework — with one of four commitments ultimately implemented, the audit declared infeasible, and the oversight institution subsequently prosecuted — was not a safeguard. It was a record of known institutional inadequacy, formalised and then filed. Sources: EFCC press releases (May–July 2022); PEFA Federal Government of Nigeria (2019); mdbreform.com.
Kenya: The KEMSA “Heist”
Kenya received US$739 million under the RFI in April 2020. A 2021 Special Audit by Kenya’s Auditor General examined Kshs 7.8 billion allocated to the Kenya Medical Supplies Authority (KEMSA) for emergency procurement.
The Audit Findings
- Ghost companies: Contracts worth over Kshs 1.25 billion were awarded to companies registered less than one year before the emergency
- Dead stock: 97 percent of procured supplies — valued at Kshs 6.35 billion — remained in KEMSA warehouses at the time of the audit, undelivered to health facilities
- Kshs 2.3 billion direct financial loss quantified by the auditor
- Fund commingling: Public funds allocated under Universal Health Coverage were irregularly merged with COVID-19 capital, obscuring the audit trail
The KEMSA scandal demonstrates that the IMF’s governance safeguard failures were not confined to the six IEO case study countries. They were systemic across the disbursement population. Sources: Kenya National Audit Office, Special Audit Report on KEMSA COVID-19 Funds (2021); IMF Kenya Press Release No. 20/148 (April 2020).
South Africa: Real-Time Audit Failure
South Africa received US$4.3 billion under the RFI in July 2020 — the largest single emergency disbursement in the case studies. Three special audit reports by the Auditor General subsequently found overpricing, unfair practices, and potential fraud across COVID-19 relief spending.
The Audit Findings
- Three Special Reports: AGSA identified contracts awarded at prices materially above market rates, particularly for PPE, where the emergency procurement channel was systematically exploited by politically connected suppliers
- Reporting resistance: Many government departments declined to report COVID-19 expenditure to the National Treasury, rendering the procurement dashboard systematically incomplete
- Nominal beneficial ownership compliance: Director names rather than ultimate beneficial owners were published — defeating the purpose of the requirement
The Fund logged the beneficial ownership commitment as met. The Auditor General documented the fraud. The two conclusions are not contradictory; they describe the same framework operating exactly as designed. Sources: Auditor General South Africa, Special Reports (First, Second, Third, 2020–21); IMF South Africa Press Release No. 20/226 (July 2020).
Senegal: “Pandemic Profiteering” and the Force Covid-19 Fund
Senegal received approximately US$442 million in IMF emergency financing in 2020 and was initially cited as a model of rapid pandemic response. In December 2022, Senegal’s Court of Auditors published a report on the Force Covid-19 relief fund identifying over US$9 million in embezzled or unjustified expenditures. In May 2025, five former ministers under President Macky Sall were formally charged with embezzlement and abuse of office — the most senior-level accountability consequence of any COVID-era emergency fund scandal in the SSA programme population to date.
If over-invoicing and unjustified expenditure of this scale occurred in one of the stronger governance environments in West Africa, the inference for the full population of 45 recipient countries is stark. The IMF’s safeguards did not prevent the fraud; the Court of Auditors documented it two years after disbursement; ministerial prosecutions followed five years later. Sources: Senegal Court of Auditors, Report on the Force Covid-19 Fund (December 2022).
Togo: The Rice and “Ghost” Contracts
Togo received approximately US$131 million in emergency financing in 2020. In February 2023, Togo’s Court of Auditors published a 180-page report on the Covid-19 Response and Solidarity Fund, describing a complete absence of procurement framework for several high-value contracts.
The Audit Findings
- The rice procurement scandal: 31,500 metric tons of rice purchased through emergency channels bypassing competitive bidding, with no reliable record of delivery verification
- Unauthorised incentive bonuses: Tens of millions of CFA francs paid to officials not authorised under the original emergency decrees
- Complete absence of framework: Several high-value contracts executed with no tender documentation, no evaluation committee, no approvals trail
Togo illustrates a failure mode the four-commitment framework was structurally incapable of addressing: when the entire procurement process operates without formal framework, contract publication and beneficial ownership disclosure are moot. Sources: Togo Court of Auditors, Report on the FRSC Covid-19 Fund (February 2023).
Zimbabwe: The “Draxgate” Scandal
Zimbabwe received approximately US$318 million in emergency financing in 2020. In 2020, Zimbabwe’s Health Minister Obadiah Moyo was arrested in connection with a US$60 million contract for COVID-19 test kits awarded to Drax Consult SAGL — a Hungarian shell company incorporated approximately two months before receiving the contract, with no prior history in the medical supply sector.
The Audit Findings
- Shell company: Drax Consult SAGL incorporated in Hungary approximately two months before receiving the US$60 million contract, with no established supply chain capacity
- Extreme price inflation: US$28 per COVID-19 test kit against a prevailing market rate of approximately US$15 — an 87 percent premium
- Procurement bypass: Contract awarded in explicit circumvention of Zimbabwe’s Procurement Regulatory Authority
- Cross-border flagging: Hungarian authorities flagged the transaction as suspicious after disbursement
The Draxgate scandal is the case where the IMF’s beneficial ownership commitment — had it been operationalised to the standard its design implies — should have provided protection. A two-month-old Hungarian shell company with no sectoral track record, receiving a US$60 million contract without competitive tender, is precisely the risk profile the requirement was designed to surface. It did not. Sources: Zimbabwe Anti-Corruption Commission (ZACC) records (2020); Hungarian Financial Intelligence Unit records (2020).
Across seven documented case studies spanning multiple subregions, income levels, and governance profiles, the IMF’s COVID-19 emergency financing generated a convergent pattern of fiduciary failure: procurement bypass under emergency pretext, shell company and over-invoicing fraud, nominal compliance with transparency commitments, and judicial accountability processes that remain active five years after disbursement. These outcomes are not coincidental or country-specific: they reflect the structural properties of a disbursement framework that prioritised speed over fiduciary due diligence, and applied safeguards calibrated for the wrong institutional context.
The Structural Critique: Four Systemic Failures
A. Speed as an Institutional Value Overriding Fiduciary Prudence
The Fund’s emergency financing instruments are designed to prioritise speed — a legitimate institutional choice for a narrow class of crisis where speed is the primary variable affecting outcomes. The application of this logic to broad-based budget support in an environment of weak PFM is a category error. The harm from delayed disbursement (a brief additional contraction) is of a different character than the harm from inappropriate disbursement (misappropriated funds that cannot be recovered, accountability systems damaged, future reform leverage consumed).
B. The Beneficial Ownership Misapplication
The beneficial ownership requirement originated in the OECD/FATF anti-money-laundering framework and is designed to prevent concealment of corrupt payments through opaque corporate structures. In SSA emergency financing, the primary fiduciary risk is not private contractor concealment but direct government misappropriation through procurement systems that lack independent verification capacity. Staff across multiple case studies questioned its relevance. The IEO implicitly agrees: it would have been better for safeguards to have focused on whether the country had a strong overall PFM instead of very specific beneficial ownership requirements.
C. The Consistency Problem: Zambia as Counterfactual
The Fund’s refusal to disburse to Zambia — classified as in debt distress — provides an important institutional counterfactual. The criterion applied was debt sustainability risk to the Fund’s own balance sheet, not fiduciary quality. Zambia’s CPI rank of 113 was better than Nigeria (146) and Malawi (last quartile). The difference that determined the outcome was debt sustainability, not governance. The Fund’s institutional incentive structure is aligned around its own financial exposure, not around the fiduciary protection of beneficiary populations.
The Fund’s emergency financing architecture contains four interacting structural failures: speed as an overriding institutional value that displaces fiduciary prudence; application of a beneficial ownership framework designed for a different governance failure mode; prioritisation of balance sheet protection over governance quality in access decisions (the Zambia counterfactual); and exercise of an undisclosed fiduciary gatekeeping function over a pool of funds many multiples larger than the Fund’s own exposure. These failures are systemic, not episodic.
The Repayment Dimension: Who Paid, and When
The countries that received these disbursements have repaid them, or are in the process of doing so, under GRA and PRGT credit rules that were set at the point of disbursement and have not been adjusted to reflect the subsequent institutional acknowledgement of design failure.
For Nigeria, the repayment cliff ran from July 2023 to April 2025 — coinciding precisely with President Tinubu’s structural reform programme. South Africa’s US$4.3 billion RFI repayment ran concurrently with its Auditor General documenting what the emergency money had actually financed. Malawi, operating under longer-maturity RCF terms, carries its principal obligation into the late 2020s under debt sustainability conditions the Fund itself rates as high risk.
The Executive Board’s Response: Formal Acknowledgment and Institutional Deference
On March 13, 2023, the IMF Executive Board discussed the IEO Evaluation Report. The Board formally acknowledged that governance and safeguards “could have been strengthened sooner”; that concerns about lack of evenhandedness had been raised; and that “the assessment of risks to the Fund’s balance sheet was somewhat limited.” Each of these acknowledgments is substantiated by the evidence in this paper.
On governance safeguards specifically, the Board directed that an ongoing 2018 framework review would “provide an opportunity to strengthen and fine-tune existing initiatives.” This framing — “strengthen and fine-tune” — treats governance safeguard reform as incremental enhancement rather than structural redesign. The problem documented here is architectural: the framework was designed for the wrong failure mode and applied as documentation rather than operational control. Fine-tuning does not address an architectural failure.
The Executive Board’s Summing Up of March 13, 2023 formally acknowledges that governance safeguards could have been strengthened sooner, that risks to the Fund’s balance sheet were insufficiently assessed, that lack of evenhandedness was a concern, and that consultation was inadequate. The Board’s proposed remediation treats structural failures as incremental calibration problems. The institutional response is proportionate to a management challenge; the problem documented by the IEO’s own evidence is systemic.
Conclusions and Reform Agenda
Recommendation 1: PFM Floor as Disbursement Prerequisite
Countries below a defined CPIA or PEFA threshold for budgetary and financial management should face a higher evidentiary burden before rapid, light-conditionality disbursements are approved. PFM assessments should operate as a floor condition, not a background consideration.
Recommendation 2: Tiered Access Linked to Governance Capacity
Governance capacity should be the primary tiering variable, not debt sustainability. Malawi and Nigeria illustrate opposite poles of the debt sustainability spectrum yet share comparable governance failures: the current tiering criterion provides no protection against the fiduciary risks the emergency framework is supposed to address.
Recommendation 3: Replacement of Beneficial Ownership with PFM-Linked Controls
The beneficial ownership requirement should be replaced for SSA emergency financing with controls calibrated to the dominant local failure modes: pre-disbursement verification of single treasury account coverage, real-time commitment registers, independent procurement oversight capacity, and civil society access to spending data.
Recommendation 4: Disclosure of Gatekeeping Function
The Fund’s assessment letter function should be formally acknowledged as a gatekeeping role carrying fiduciary responsibilities that extend to the full pool of funds it unlocks. Certification standards should be published, applied consistently, and subject to ex-post accountability when certified arrangements subsequently produce documented misappropriation.
Recommendation 5: OII Engagement Protocol for Emergency Facilities
The Fund’s Office of Internal Investigations should have a defined engagement protocol for emergency financing operations. The instruments with the least conditionality and fastest disbursement timelines carry the greatest fiduciary exposure, yet receive no attention from the institution’s own anti-corruption function.
The Fund deployed US$26 billion to one of the world’s most institutionally fragile regions at unprecedented speed, under a governance framework its own evaluators describe as mechanical, inconsistently applied, and demonstrably ineffective. The subsequent audit record in Malawi, Nigeria, and South Africa confirms that this was not an administrative oversight but a predictable consequence of institutional design choices that subordinated fiduciary protection to disbursement velocity.
The reform agenda is not complex. It requires the Fund to apply in emergency contexts the same standard of fiduciary due diligence that it routinely demands of the countries it lends to.
The IMF’s Governance Safeguards Checklist: Critical Assessment
| # | Commitment | Operational Standard | Critical Assessment |
|---|---|---|---|
| 1 | Publication of procurement contract information | All contracts related to COVID-19 emergency spending to be published, including contractor name, value, and nature of procurement. | Most commonly met commitment. However, compliance was partial in South Africa (departments not reporting to National Treasury) and delayed in Burkina Faso. Publication without unit price benchmarks limits usefulness as a fraud-detection tool. |
| 2 | Beneficial ownership of contracting parties | Collection and publication of the ultimate beneficial owners of entities receiving COVID-related procurement contracts. | Least relevant commitment in SSA context. Designed for European AML/CFT risk profiles. Not implemented in Nigeria. Met only nominally in South Africa (directors, not beneficial owners). IEO staff confirmed it addressed the wrong failure mode. |
| 3 | Report on COVID-19-related spending | Comprehensive government report documenting total COVID-19 spending by category, sources of financing, and institutional mechanisms used for disbursement. | Generally produced across case studies but of variable quality. In Malawi, production of the report did not prevent the Auditor General’s subsequent malfeasance findings. Report production satisfies the commitment regardless of report quality. |
| 4 | Ex-post independent audit of crisis-related spending | Independent audit conducted by an institution independent of the line ministry responsible for the spending. | Most consequential commitment where implemented. Malawi’s audit revealed widespread malfeasance. South Africa’s three audit reports found overpricing and fraud. Nigeria’s audit declared infeasible — the most significant governance gap in the framework. |
All African COVID-19 Emergency Financing Recipients — Fiduciary Risk Register (Selected)
| Country | Instrument | Amount (US$m) | TI CPI 2019 | Debt Distress | Key Fiduciary Notes |
|---|---|---|---|---|---|
| Nigeria | RFI | 3,400 | 146 → 154 | N/A (MAC) | PEFA 2019. 1 of 4 governance commitments implemented. Audit declared infeasible. Accountant General convicted, N109bn (~US$265m). CBN safeguards gap since 2001. |
| South Africa | RFI | 4,287 | 70 | N/A (MAC) | PEFA 2008 (outdated). 3 Auditor General special reports found overpricing, fraud, unfair practices. Beneficial ownership met nominally only. |
| Kenya | RFI | ~739 | 137 | Moderate | PEFA 2018. KEMSA procurement scandal; Kshs 6.35 billion in dead stock; Kshs 2.3 billion direct loss quantified by Auditor General (2021). |
| Malawi | RCF (×2) + CCRT | 241 | Last quartile | High | PEFA 2017. Cashgate scandal 2013. Auditor General found widespread malfeasance in RCF use (2021). Audit most consequential finding across all case studies. |
| Senegal | RCF | ~442 | 66 | Moderate | PEFA 2015. Force Covid-19 fund: US$9m+ embezzled. Five former ministers charged May 2025. |
| Togo | RCF | ~131 | 130 | Moderate | PEFA 2016. Court of Auditors documented rice scandal, complete absence of procurement framework. |
| Zimbabwe | RCF | ~318 | 158 | In distress | No PEFA. Draxgate: US$60m to Hungarian shell company incorporated 2 months prior. Minister arrested. |
| Somalia | RCF + CCRT | ~52 | 180 (lowest) | High | Lowest CPI rank globally. Fragile state; federal PFM barely functional. Disbursement carried exceptional institutional risk. |
| South Sudan | RCF + CCRT | ~52 | 179 | High | Second-lowest CPI rank globally. PFM almost entirely non-functional. Among highest per-capita fiduciary risk in entire AFR programme. |
| Zambia | None disbursed | — | 113 | In distress | Withheld on debt distress grounds — not governance grounds. CPI rank better than Nigeria and Malawi. Confirms debt sustainability, not governance, determined access. |
| Rwanda | RCF | ~109 | 51 | Moderate | Among strongest PFM environments in SSA. PEFA 2020. Relatively well-managed COVID response. |
| Ethiopia | RCF + CCRT | ~411 | 96 | High | PEFA 2015. Major PFM reform programme underway. Tigray conflict erupted November 2020 — disbursement approved pre-conflict. |
References
Christensen, B.V. et al. (2023). ‘The IMF’s Engagement with Sub-Saharan African Countries During the Pandemic.’ IEO Background Paper BP/23-01/07. IMF, Washington DC.
IMF (2022). ‘Implementation of Governance Measures in Pandemic-Related Spending.’ May 2022.
Koh, C. and Wojnilower, J. (2023). IEO Staff Survey Results. IEO Background Paper BP/23-01/06. February 2, 2023.
IEO (2023). The IMF’s Emergency Response to the COVID-19 Pandemic: Evaluation Report 2023. Washington DC.
Transparency International (2021). ‘IMF COVID-19 Emergency Loans: A View from Four Countries.’ March 2021.
WHO (2021). Weekly Epidemiological Update on COVID-19. Multiple editions, 2020–2021.
World Bank (2019). Country Policy and Institutional Assessment (CPIA) — Africa.