## NIGER — NAVIGATING THE CHALLENGES OF GOVERNANCE IN NIGER

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### A. Background
- Progress and remaining challenges:
  - Over the past few years, Niger has made significant headway in improving governance and strengthening its anti-corruption framework; gaps remain and implementation poses major challenges.
  - Definition: corruption = the abuse of public office for private gain (IMF, 1997).
  - President Issoufou’s “Maïboulala” anti-corruption drive (start of second mandate in 2013) exposed financial malpractices in public enterprises, favoritism in customs, ghost contractual workers, and irregular recruitments in education and health sectors.
- Survey and perception findings:
  - 86 percent of respondents recognized widespread corruption in Niger (recent government survey); customs and tax administrations perceived most corrupt, followed by the police and public procurement services.
  - Corruption ranked fourth among main obstacles in the business environment (World Bank enterprise survey, 2017).
  - Afrobarometer: 62 percent of respondents in Niger felt corruption increased over the past year (against 46 and 51 percent for the WAEMU and SSA respectively on average).
  - Niger performs above the SSA average on TI-CPI and WGI-CCI, but below the WAEMU average according to V-Dem, except for judicial corruption measures.
- Identified drivers of corruption:
  - Politicization of public services.
  - Lack of administrative controls.
  - Weaknesses in the judicial system, including limited capacity to enforce the law.
  - Low public-sector salaries, poor professional integrity, and deteriorating civic values.
- Macroeconomic implications (literature summary):
  - Corruption can lower the volume and quality of public and private investment, undermine revenue-raising and provision of public services, distort use of public funds, and hinder monetary and financial stability and trust in public institutions.

### B. The Anti-Corruption Framework: Progress So Far and Challenges Ahead
- International and regional commitments:
  - Party to UNCAC, AUCPCC, and ECOWAS Protocol on the Fight Against Corruption.
- National legal and institutional measures:
  - Combatting corruption mandated under the 2010 Constitution.
  - Criminal Code penalizes graft, trading in influence, and misappropriation of public funds.
  - 2011 decree created HALCIA; 2016 organic law granted HALCIA investigative powers, referral powers to the Public Prosecutor, and witness protection mechanisms.
  - Ligne Verte (anti-corruption hotline) opened in 2011 within the Ministry of Justice.
  - January 2018: National Anti-Corruption Strategy (NACS) — a three-year action plan focused on prevention, repression, and coordination; anti-corruption awareness campaigns stepped-up since April 2018.
- Audit and oversight bodies:
  - Audit Court is the supreme audit institution (SAI).
  - Office of the state inspector general (IGE) under the President.
  - Inspector general of administrative governance (IGGA) reports to the Prime Minister.
  - Finance inspector general (IGF) operates within the Ministry of Finance.
  - Each ministry has a technical inspectors’ office.
  - DCMP/EFE and ARMP oversee public procurement processes.
  - Dedicated chambers for misappropriation of public funds exist within the Commercial Court of Niamey and the Appeals Court.
- Implementation and enforcement challenges:
  - UNCAC implementation review (2016) identified deficiencies (e.g., lack of criminalization of active bribery of foreign public officials; absence of provisions for joint investigations with other states).
  - HALCIA remains attached to the Office of the President, lacks financial autonomy, and faces constraints in financial and human resources; despite many cases received, only a handful referred to the Public Prosecutor.
  - Sanctions poorly enforced: only three cases have led to convictions to date; anecdotal evidence suggests offenders often released if able to pay back embezzled funds.
  - Ligne Verte is underfunded and none of its recorded complaints have had legal consequences.
  - Multiplicity and overlap of oversight actors conflict with limited resources available to audit bodies.

### C. Asset Declaration
- Coverage and legal gaps:
  - Coverage of high-ranking public officials required to declare assets is incomplete; key subordinate legislation to define further coverage has not been adopted.
  - Constitution mandates asset disclosure for the President of the Republic, members of the government, the presidents of the other institutions of the Republic, and heads of independent administrative authorities.
  - Law n°2002-003 under the previous Constitution enumerated other officials but did not prioritize high-risk individuals; current regime results in a long list of filers relative to processing capacity.
  - Family members and close associates are not included in asset declaration requirements.
- Content and form deficiencies:
  - Law fails to specify the list of assets to be declared; underlying legislation formally establishing required disclosures is missing.
  - Audit Court expects immovable and movable assets—including animals—and bank accounts to be declared, but absence of formal legal text leads to disparities across submitted forms.
  - Law is silent on declaration of beneficial ownership domestically and abroad.
- Frequency and deadlines (per Constitution and Audit Court’s 2012 organic law):
  - President must disclose assets within 48 hours following investiture; declaration received by the Constitutional Court and communicated to the Audit Court and tax authorities.
  - Prime Minister, Ministers, presidents of other institutions of the Republic, heads of independent administrative authorities and other officials subject to disclosure must submit declarations to the Audit Court within 7 days after the start of their mandate.
  - Annual updates should be submitted to the SAI within the first month following the anniversary of the initial declaration; discrepancies must be justified.
  - Declarations at termination of service are due during the month following the date of leaving office.
  - Exception: the President of the Republic’s submission deadline at exit from office is missing.
- Verification and sanctions:
  - Audit Court verifies accuracy and completeness of asset declarations of all public officials, including the President.
  - SAI can investigate and request information from the financial sector, tax authorities, and property registries; verification is carried out for all declarations and is solely offsite.
  - Criminal sanctions for inaccurate or false disclosures: imprisonment between 5 and 10 years and a fine of CFAF 20,000 to CFAF 1 million (Criminal Code).
  - Non-compliance sanctions gap: failure to file, late submissions, and incomplete filings are not sanctioned by law.
  - SAI publishes lists of non-filers in annual general reports; publication has little deterrent effect.

### Asset declarations and public access
- Law mandates public access to initial declarations, updates, and exit declarations to be published in the Official Gazette and by way of press.
- Implementation gaps:
  - Audit Court website is not functional.
  - Only the President’s asset disclosures are up-to-date and accessible on the Constitutional Court’s website.
  - Declarations of the Prime Minister and Ministers are available only through 2008.
  - Declarations of presidents of other institutions and heads of independent administrative authorities are missing.
- Note: The Constitutional Court also controls the asset declaration of the President of the Republic.

### AML/CFT framework and financial sector oversight
- Legal alignment and assessments:
  - Niger updated and aligned its AML/CFT framework with FATF standards, transposing WAEMU 2015 uniform law into national legislation in 2016.
  - Formal assessment of compliance with the 2012 FATF standards planned by GIABA in January 2020.
- Recent legislative and regulatory measures:
  - Revision of Criminal Code to introduce illicit enrichment and abuse of office.
  - Revision of Code of Criminal Procedures to empower judiciary on asset tracking, freezing, seizure, and recovery.
  - Decrees on administrative freezing of funds and assets.
  - Creation of Central Agency for the Management of Seized, Confiscated, Frozen, and Recovered Assets; director general appointed.
  - 2018 provisions obligating real estate sector, business introducer profession, and public notaries to participate in AML/CFT effort.
- CENTIF (Cellule Nationale de Traitement des Informations Financières):
  - Created in 2004 within the Ministry of Finance; member of the Egmont Group.
  - Organizes capacity building and involved in AML/CFT guidelines for financial institutions and DNFBPs.
- Operational challenges:
  - Only the banking system has been carrying out customer due diligence and transmitting STRs.
  - By end-2018, only two out of the 33 cases referred to the Public Prosecutor since CENTIF’s inception led to a conviction despite several indictments.
  - WAMU Banking Commission reported visiting only one bank and two microfinance institutions in Niger during 2016-18; weak collaboration with regional regulator.
- National risk assessment (NRA):
  - Launched in November 2016 with World Bank and GIABA support.
  - Identifies corruption as a predicate offence to money laundering.
  - Early results highlight vulnerabilities: large informal sector, cash-based economy, poor border control and enforcement, weak supervision and sanction of financial institutions and DNFBPs.

### Public sector governance reforms that reduce corruption vulnerabilities
- Treasury and revenue administration reforms under IMF’s ECF arrangement:
  - Treasury Single Account (TSA) once fully implemented should enhance oversight by transferring accounts of public entities to a designated account at the central bank and the treasury.
  - Computerization: rollout of SISIC in tax administration; increased utilization of ASYCUDA in customs; phasing out of cash payments of taxes and customs duties.
  - Since early 2019, salaries of civil servants and government employees have been paid through banks and the post office or with mobile money.
  - Linking tax and customs IT systems to detect and combat fraud.
  - Implementation of transaction valuation of imports and adoption of risk-based inspection regime emphasizing post-clearance audits.
  - Planned consolidation and streamlining of tax exemptions and improved management.
  - Civil service law emphasizing performance-based management, ethics, and human resource management; ongoing biometric census of civil servants, contractual government workers, and scholarship recipients to identify ghost workers and duplicate payments.

### State-owned enterprises (SOEs) governance weaknesses
- Legal and institutional weaknesses:
  - 1986 legal framework regulating SOEs is outdated.
  - DEP/PE within Ministry of Finance exercises financial supervision of SOEs, but mandate not defined by law and limited resources hamper activities.
  - Supervision fragmented between Ministry of Finance and line ministries; lack of coordination.
  - Lack of comprehensive and reliable statistics and poor IT systems hinder assessment of SOE performance and tracking of financial operations.
  - Board appointments rarely consultative or transparent; absence of objective selection criteria; performance seldom assessed; compensation packages opaquely negotiated.
  - Audits are not always carried out, of low quality, or delayed; results rarely shared with DEP/PE. Online publication of financial statements is not mandatory.

### Public procurement and public investment management shortcomings
- Public procurement:
  - Legal/regulatory framework broadly conforms with WAEMU directives and international standards (OECD/DAC diagnostic).
  - In practice, one third of public procurement is single sourced or awarded by restricted tendering, well above WAEMU norm of 10 percent.
  - Excessive derogations from advertising tenders within legally prescribed timelines; lack of public access to tender results and statistics.
  - Processing times longer than national and regional norms; ARMP does not consistently maintain procurement records.
  - Annual procurement audits are backlogged and recommendations seldom implemented.
  - Internal and external control by IGF, IGE, and the Audit Court are poor due to inadequate human resources; staff lacks training and performance assessment; recruitments not always competitive and transparent.
  - Lack of sanctions for corrupt public procurement officials and insufficient empowerment to report mal-practices.
- Public investment management (PIMA findings):
  - Deficiencies in project appraisal and selection: committees often select projects without rigorous feasibility and impact evaluations.
  - Weak budgeting for capital spending and inadequate mechanisms to protect ongoing investment projects.
  - Limited coordination between Ministry of Finance, Ministry of Planning, subnational governments, and PPP oversight entities.
  - Ex-post controls of domestically-financed projects not systematically carried out.
  - Externally-financed projects mostly audited by donors; Audit Court constrained to a restricted number of ex-post controls whose results are neither published nor shared with the National Assembly.

### PPPs and extractive sector governance
- PPPs:
  - Modern PPP law exists and favors BOT operations free of government financing or guarantees.
  - Implementation weaknesses: predominance of spontaneous offers not opened to competition (allowed only under special circumstances); direct negotiations vulnerable to overpricing and kick-backs.
- Extractive industries:
  - Constitution provides for high degree of transparency and mandates disclosure of contracts.
  - Progress: modernization of mining cadaster and publishing conventions.
  - Remaining gaps: disclosure of revenues not systematic; publication of annual audit reports of government’s natural resource revenue collection is delayed; extractive companies’ payments to SOEs are not published.
  - Local governments statutorily entitled to 15 percent of all mining and petroleum royalties are typically not made and not disclosed.
  - Niger quit EITI in 2017 when suspension was looming but has since undertaken steps to rejoin.

### Fiscal transparency
- Niger recorded the lowest score on the 2017 readings of the Open Budget Index.
- Survey findings:
  - Budget audit reports are inexistent.
  - Budget proposals and year-end reports produced for internal use only.
  - Enacted budget published with excessive delay.
  - Executive, legislature, and SAI do not provide public opportunities to engage in the budget process.
  - WAEMU Commission flagged lack of public debates on quarterly budget executions.
- Recent efforts:
  - Publication of the 2019 draft budget submitted to Parliament.
  - Government committed to introducing legal requirements for timely publication of key documents: budget outturns, draft and approved budgets (including supplementary ones), a citizen budget, major conventions with foreign investors, PPP contracts, and tender awards.

### Implications for business environment and private-sector performance
- Empirical evidence and firm-level consequences:
  - Firms more likely to participate in public procurement markets when procurement information is complete, reliable, and timely.
  - Less kick-backs when exceptions to open competition in tendering must be explicitly justified and when independent complaint mechanisms exist.
  - Burdensome customs procedures reduce export volumes.
  - Senior management time spent dealing with regulations and inspections stunts employment growth.
  - Corruption reduces sales growth; firms that pay bribes suffer more from bureaucratic red tape.
  - Firms confronted with bribe requests take longer to get construction permits, operating licenses, electrical connections, and to clear customs; exporters faced with bribe demands less likely to continue selling abroad.
- Burdensome regulatory procedures in Niger:
  - It takes on average 44 days to obtain a construction permit in Niger, against 62 days for the WAEMU region.
  - Delays in obtaining an import license and senior management time spent dealing with regulatory compliance are longer than on average in SSA.
  - Twice as many firms report bribe requests to obtain an operating license than in SSA on average.
  - Exposure to corruption particularly pronounced for firms trying to secure government contracts.
- Recent administrative simplification and judicial reforms:
  - One-stop shop in the Niamey Enterprise House to simplify creation of new companies.
  - Better processing of construction permits and reduced associated fees.
  - Commercial Court of Niamey started operations in 2016, increasingly settling commercial disputes typically within a few weeks; draft legislation updating Commercial Court law adopted recently.
  - Updates to Code of Civil Procedure to expedite claims and increased use of computerization to limit face-to-face contact.
  - Recourse to arbitration and mediation for commercial disputes now available.
  - Institution of additional courts across the country intended to ensure more timely and effective proceedings.

### Corruption and private-sector performance: descriptive and regression findings
- Sample:
  - Unbalanced sample of 302 firms operating in manufacturing and services sectors in the years 2005, 2009 and 2017.
  - Firms reporting at least one bribe payment request across public transactions classified as subject to corruption.
- Descriptive comparisons:
  - Exporters that pay bribes record on average a negative sales growth of -20.5 percent against +6.6 percent for those trading in a “clean” environment.
  - Young firms (in operation for less than 5 years) register average sales growth of 28.7 percent in the absence of corruption, against 7.4 percent otherwise.
- Main regression results (Annex Table 1):
  - Bribery coefficient on Sales growth: -0.086** (standard error (0.036))
  - Bribery coefficient on Employment growth: 0.006 (standard error (0.038))
  - Bribery coefficient on Productivity growth: -0.120** (standard error (0.050))
  - Young: 0.239** on Sales growth; 0.613*** on Employment growth; 0.225* on Productivity growth.
  - Observations: Sales growth 161; Employment growth 192; Productivity growth 127.
  - R-squared: Sales 0.242; Employment 0.574; Productivity 0.190.
  - Notes: Standard errors clustered by sector; *** p<0.01, ** p<0.05, * p<0.1.
- Interpretation in main text:
  - Sales of firms confronted with bribe requests grow 9 percentage points less than those that are not, and their productivity growth is 12 percentage points lower.
  - Public-sector rent-seeking hurts disproportionately more young firms and exporters.
- Regression discontinuity results (Annex Table 2):
  - Firms whose share of annual bribe payments in total sales is above the sector average record sales and employment growth rates between 8 and 9 percentage points less than firms below the sector average.
  - Selected RDD estimates:
    - Panel A parametric: Sales growth -0.154* and -0.160**; Productivity growth -0.169*** / -0.190***.
    - Panel B non-parametric bias-corrected: Sales growth -0.093** / -0.088*; Productivity growth -0.085*** / -0.083***.
  - Main/bias bandwidths reported: 4.450 / 5.578; 3.804 / 5.578; 4.441 / 7.170; 3.805 / 7.170; 2.464 / 4.246; 2.111 / 4.246.
  - Examples of # obs. left/right of cutoff: 97 / 51; 113 / 61; 76 / 42.
  - Notes: Standard errors clustered by sector; *** p<0.01, ** p<0.05, * p<0.10, † p<0.13.

### The Way Forward: priority reforms and policy recommendations
- Asset declaration regime:
  - Identify high-ranking officials beyond those in the Constitution to be subject to asset declaration; streamline list to target high-risk individuals and align with Audit Court and Constitutional Court capacities.
  - Expand disclosure to cover close associates and family members, possibly under a simplified regime.
  - Clearly define assets to be declared, including movable and immovable assets, income, stocks and securities, liabilities, gifts, cash, and interests outside public office; require declaration of assets actually used or controlled by officials even if in third-party names.
  - Set a user-friendly declaration form by decree; consider electronic filing later.
  - Control all declarations for completeness; verification of accuracy should be risk-based (complaints/allegations, red flags, media reports, referrals).
  - Set dissuasive administrative sanctions for non-compliance (fines, suspension, removal from office); fines could amount to the national daily minimum wage applied each day until remedial action; apply sanctions incrementally distinguishing initial and repeated offenses.
  - Post declarations on a public website; Audit Court to disclose verification statistics and sanctions imposed.
- Stepping up implementation and enforcement:
  - Strengthen anti-corruption institutions: bolster independence and provide sufficient human, physical, and financial resources; augment budgetary resources via donor financing and technical assistance.
  - For HALCIA: prioritize strengthening independence and establish dedicated fund for its financing as mandated by law; publish annual reports and number/progression of cases.
  - For CENTIF: upgrade capacity; finalize acquisition of automated software for processing STRs.
  - Launch collaborative platform between HALCIA and the judiciary to improve corruption case processing.
- Improving judiciary integrity and efficiency:
  - Create an independent body for recruitment, appointment, evaluation, promotion, transfer, dismissal, and disciplinary sanctions for all judges.
  - Reduce case backlogs and guarantee timely justice.
  - Publish and provide online access to all court decisions timely.
  - Digitalize filing of legal actions to reduce face-to-face contact.
- Advancing AML/CFT agenda:
  - Increase participation of DNFBPs in reporting suspicious activity.
  - CENTIF to intensify capacity-building, awareness-raising, and dissemination of guidelines to DNFBPs.
  - Improve supervision of banks and DNFBPs and strengthen coordination between WAMU Banking Commission and CENTIF; involve CENTIF in local banks’ on-site inspections.
  - Accelerate creation of common IT platform centralizing WAEMU FIUs’ STRs.
- Supporting public-sector governance through enhanced transparency:
  - Modernize revenue administrations and enhance spending quality using IT and digitalization to reduce face-to-face interaction, improve recording, limit discretion, and improve transparency.
  - Reinforce SOE governance: update SOE legislation; conduct audits and implement a three-year procurement action plan; professionalize boards; use performance contracts; publish audit reports and salaries/benefits of board members and high-level officials.
  - Address public procurement weaknesses: make competitive bidding the norm; limit single-sourced procurement; publish tender award results; ensure timely processing and auditing; operationalize SIGMAP II and set stage for e-procurement; revive toll-free reporting number.
  - Strengthen public investment management: require completed feasibility studies; strengthen ex-post assessment using risk-based approach targeting large projects; publish audit results.
  - Reduce reliance on unsolicited PPPs: make tendered PPPs the norm; open spontaneous PPPs to competition where possible; publicly disclose all PPP contracts.
- Fiscal transparency for extractive industries:
  - Re-join EITI and follow its recommendations (disclose tax payments, licenses, contracts, production; maintain a license register).
  - Consider building a live database of conventions related to natural resource exploration and exploitation.
  - Audit Court to ensure timely publication of audits of government extractive revenues collection.
  - Enforce legal public disclosure requirements for draft and approved budgets, budget outturns and audits, citizen budgets, PPP conventions, SOE financial statements and audits, statistics on tender awards and procurement oversight, ex-post assessments of large investment projects, and make the government gazette available online free of charge.
- Modernizing revenue administrations and customs:
  - Shift from systematic physical controls at customs to risk-based checks; develop internal and ex-post controls and post-clearance audits.
  - Consider introducing status of authorized economic operators for low-risk operators to expedite clearance.
  - Renew performance management: renew revenue administrations’ performance plans; introduce performance-based pay/contracts for customs inspectors; design performance contracts with objective indicators (speed of clearance, efficiency of customs control, revenues, fraud detection); reward good performance and sanction poor performance.
  - Use ASYCUDA World data for monitoring; reform HR management in customs to address misaligned incentives and high turnover.
- Securing stakeholder participation:
  - Require strong political commitment and involve civil society, media, private sector, regional entities, and donors.
  - Ensure timely access to information (court decisions, anti-corruption institution reports) to empower civil society and media.
  - Sensitize and deter private actors from facilitating corruption.
  - Donors to provide capacity building and financial assistance.

*Source: Content from "NAVIGATING THE CHALLENGES OF GOVERNANCE IN NIGER", June 13, 2019.*

### References ___________________________________________________________________________ 23

### NIGER — NAVIGATING THE CHALLENGES OF GOVERNANCE IN NIGER

### A. Background
- Over the past few years, Niger has made significant headway in improving governance and strengthening its anti-corruption framework; gaps remain and implementation poses major challenges.
- Definition: corruption = the abuse of public office for private gain (IMF, 1997).
- President Issoufou’s “Maïboulala” anti-corruption drive (start of second mandate in 2013) exposed financial malpractices in public enterprises, favoritism in customs, ghost contractual workers, and irregular recruitments in education and health sectors.
- Survey and perception findings:
  - A recent government survey found that 86 percent of respondents recognized widespread corruption in Niger, with customs and tax administrations perceived to be the most corrupt, followed by the police and public procurement services.
  - Corruption ranked fourth among the main obstacles in the business environment according to the World Bank enterprise survey conducted in 2017.
  - Afrobarometer: 62 percent of respondents in Niger felt that the level of corruption in the country increased over the past year (against 46 and 51 percent for the WAEMU and SSA respectively on average).
  - Niger performs above the SSA average on TI-CPI and WGI-CCI, but below the WAEMU average according to V-Dem, except for judicial corruption measures.
- Identified drivers of corruption in Niger:
  - Politicization of public services.
  - Lack of administrative controls.
  - Weaknesses in the judicial system, including limited capacity to enforce the law.
  - Low public-sector salaries, poor professional integrity, and deteriorating civic values.
- Macroeconomic implications (literature summary):
  - Corruption can lower the volume and quality of public and private investment, undermine revenue-raising and provision of public services, distort use of public funds, and hinder monetary and financial stability and trust in public institutions.

### B. The Anti-Corruption Framework: Progress So Far and Challenges Ahead
- International and regional commitments:
  - Niger is a party to the United Nations Convention Against Corruption (UNCAC), the African Union Convention on Preventing and Combatting Corruption (AUCPCC), and the ECOWAS Protocol on the Fight Against Corruption.
- National legal and institutional measures:
  - Combatting corruption is mandated under the 2010 Constitution.
  - The Criminal Code penalizes graft, trading in influence, and the misappropriation of public funds.
  - 2011 decree created HALCIA (High Authority to Combat Corruption and Related Infractions); reinforced by 2016 organic law granting HALCIA investigative powers, referral powers to the Public Prosecutor, and witness protection mechanisms.
  - An anti-corruption hotline—Ligne Verte—opened in 2011 within the Ministry of Justice to record and investigate corruption offences in the judiciary.
  - January 2018: National Anti-Corruption Strategy (NACS)—a three-year action plan focused on prevention, repression, and coordination; anti-corruption awareness campaigns stepped-up since April 2018.
- Audit and oversight bodies:
  - Audit Court is the supreme audit institution (SAI) responsible for scrutinizing lawful collection and use of public resources.
  - Office of the state inspector general (IGE) under the President oversees proper use of public funds.
  - Inspector general of administrative governance (IGGA) reports to the Prime Minister and monitors compliance in public administrations.
  - Finance inspector general (IGF) operates within the Ministry of Finance.
  - Each ministry hosts a technical inspectors’ office to ensure compliance with procedures and regulations.
  - DCMP/EFE and ARMP oversee public procurement processes.
  - Dedicated chambers for misappropriation of public funds exist within the Commercial Court of Niamey and the Appeals Court.
- Implementation and enforcement challenges:
  - UNCAC implementation review (2016) identified deficiencies, including lack of criminalization of active bribery of foreign public officials and absence of provisions for joint investigations with other states.
  - HALCIA remains attached to the Office of the President, lacks financial autonomy, and faces constraints in financial and human resources limiting independence and activity; despite many cases received, only a handful have been referred to the Public Prosecutor.
  - Sanctions are poorly enforced: only three cases have led to convictions to date; anecdotal evidence suggests offenders often released if able to pay back embezzled funds.
  - Ligne Verte is underfunded and none of its recorded complaints have had legal consequences.
  - Multiplicity and overlap of oversight actors conflict with limited resources available to audit bodies.

### C. Asset Declaration
- Coverage and legal gaps:
  - Coverage of high-ranking public officials required to declare assets is incomplete; key subordinate legislation to define further coverage has not been adopted.
  - Constitution mandates asset disclosure for the President of the Republic, members of the government, the presidents of the other institutions of the Republic, and heads of independent administrative authorities.
  - Law n°2002-003 under the previous Constitution enumerated other officials but did not prioritize high-risk individuals; current regime results in a long list of filers relative to processing capacity.
  - Family members and close associates are not included in the asset declaration requirements.
- Content and form deficiencies:
  - The law fails to specify the list of assets to be declared; underlying legislation formally establishing required disclosures is missing.
  - According to the Audit Court, high-level public officials are expected to declare immovable and movable assets—including animals possessed—and bank accounts, but absence of formal legal text leads to disparities across submitted forms.
  - The law is silent on declaration of beneficial ownership domestically and abroad, leaving large loopholes.
- Frequency and deadlines:
  - Submission deadlines are regulated by the Constitution and the Audit Court’s 2012 organic law:
    - The President must disclose assets within 48 hours following investiture; declaration received by the Constitutional Court and communicated to the Audit Court and tax authorities.
    - Prime Minister, Ministers, presidents of other institutions of the Republic, heads of independent administrative authorities and other officials subject to disclosure must submit declarations to the Audit Court within 7 days after the start of their mandate.
    - Annual updates should be submitted to the SAI within the first month following the anniversary of the initial declaration; discrepancies between initial declaration and updates must be justified.
    - Declarations at termination of service are due during the month following the date of leaving office.
  - Exception: the President of the Republic’s submission deadline at exit from office is missing.
- Verification and sanctions:
  - The Audit Court is responsible for verifying accuracy and completeness of asset declarations of all public officials, including the President.
  - The SAI can investigate asset declarations and request information from the financial sector, tax authorities, and property registries; verification is carried out for all declarations and is solely offsite.
  - Criminal sanctions for inaccurate or false disclosures: imprisonment between 5 and 10 years and a fine of CFAF 20,000 to CFAF 1 million (Criminal Code).
  - Non-compliance sanctions gap: failure to file, late submissions, and incomplete filings are not sanctioned by law, resulting in a relatively high prevalence of non-compliance among officials covered by the Constitution.
  - The SAI publishes lists of non-filers in its annual general reports, but publication has little deterrent effect; non-filers often continue to violate disclosure requirements in subsequent years.

*Source: Content from "NAVIGATING THE CHALLENGES OF GOVERNANCE IN NIGER", June 13, 2019.*

### 14.      Consistent with international standards, the law mandates public access to

### 1nerea2019002 - 14.      Consistent with international standards, the law mandates public access to

### Asset declarations and public access
- Law mandates public access to government officials’ asset declarations (initial, updates, and at exit from office) to be published in the Official Gazette and by way of press.
- Intended benefits: facilitate scrutiny by civil society, ease information sharing with foreign authorities, facilitate customer due diligence by local and foreign banks.
- Implementation gaps:
  - Audit Court website is not functional.
  - Only the President of the Republic’s asset disclosures are up-to-date and accessible on the Constitutional Court’s website.
  - Declarations of the Prime Minister and Ministers are only available through 2008.
  - Asset declarations of presidents of other institutions of the Republic and heads of independent administrative authorities are missing.
- Note: The Constitutional Court also controls the asset declaration of the President of the Republic.

### AML/CFT framework and financial sector oversight
- Niger has updated and aligned its AML/CFT framework with FATF standards, including transposing the WAEMU 2015 uniform law into national legislation in 2016.
- Formal assessment of compliance with the 2012 FATF standards planned by GIABA in January 2020.
- Recent legislative and regulatory measures:
  - Revision of the Criminal Code to introduce new criminal offences, such as illicit enrichment and abuse of office.
  - Revision of the Code of Criminal Procedures to empower the judiciary regarding asset tracking, freezing, seizure, and recovery.
  - Decrees on the administrative freezing of funds and assets.
  - Creation of the Central Agency for the Management of Seized, Confiscated, Frozen, and Recovered Assets, with appointment of its director general.
  - 2018 provisions obligating the real estate sector, the business introducer profession, and public notaries to participate in the AML/CFT effort.
- CENTIF (Cellule Nationale de Traitement des Informations Financières):
  - Created in 2004 within the Ministry of Finance; member of the Egmont Group.
  - Organizes capacity building, training workshops, and awareness-raising seminars.
  - Involved in elaboration and validation of AML/CFT guidelines for financial institutions and DNFBPs.
- Operational challenges:
  - Only the banking system has been carrying out customer due diligence and transmitting suspicious transactions reports (STRs).
  - By end-2018, only two out of the 33 cases referred to the Public Prosecutor since CENTIF’s inception has led to a conviction despite several indictments.
  - Weak collaboration with regional regulator: WAMU Banking Commission does not share outcomes of supervisory activities with the FIU and reported having visited only one bank and two microfinance institutions in Niger during 2016-18.
- National risk assessment (NRA):
  - Launched in November 2016 with World Bank and GIABA support.
  - Identifies corruption as a predicate offence to money laundering.
  - Early results highlight vulnerabilities: large informal sector, cash-based economy, poor border control and enforcement, weak supervision and sanction of financial institutions and DNFBPs.

### Public sector governance reforms that reduce corruption vulnerabilities
- Treasury and revenue administration reforms under the IMF’s ECF arrangement:
  - Treasury Single Account (TSA) once fully implemented should enhance oversight by transferring accounts of public entities to a designated account at the central bank and the treasury.
  - Computerization of revenue administrations: rollout of SISIC in tax administration, increased utilization of ASYCUDA in customs, phasing out of cash payments of taxes and customs duties.
  - Since early 2019, salaries of civil servants and government employees have been paid through banks and the post office or with mobile money.
  - Linking tax and customs IT systems to detect and combat fraud.
  - Implementation of transaction valuation of imports and adoption of a risk-based inspection regime emphasizing post-clearance audits.
  - Planned consolidation and streamlining of tax exemptions and improved management.
  - Civil service law emphasizing performance-based management, ethics, and human resource management; ongoing biometric census of civil servants, contractual government workers, and recipients of scholarships to establish a comprehensive registry to help identify ghost workers and duplicate payments.

### State-owned enterprises (SOEs) governance weaknesses
- Legal and institutional weaknesses creating corruption vulnerabilities:
  - 1986 legal framework regulating SOEs is outdated, creating legal gaps and inconsistencies.
  - DEP/PE within the Ministry of Finance exercises financial supervision of SOEs, but its mandate is not defined by law and limited resources hamper its activities.
  - Supervision is fragmented between the Ministry of Finance and line ministries; several directorates within the Ministry of Finance are involved without systematic coordination.
  - Lack of comprehensive and reliable statistics and poor IT systems hinder assessment of SOE performance and tracking of financial operations.
  - Board appointments are rarely consultative and transparent; absence of objective selection criteria; performance seldom assessed; compensation packages opaquely negotiated; board reports not systematically transmitted to supervising ministries nor made publicly available.
  - Audits are not always carried out, of low quality, or performed with delay; results rarely shared with DEP/PE. Online publication of financial statements is not mandatory.

### Public procurement and public investment management shortcomings
- Public procurement:
  - Legal and regulatory framework broadly conforms with WAEMU directives and international standards per an OECD/DAC diagnostic.
  - In practice, a third of public procurement is single sourced or awarded by restricted tendering, well above the WAEMU norm of 10 percent.
  - Excessive recourse to derogations from advertising tenders within legally prescribed timelines; lack of public access to tender results and statistics.
  - Processing times longer than national and regional norms; ARMP does not consistently maintain procurement records.
  - Annual procurement audits are backlogged and recommendations seldom implemented.
  - Internal and external control by IGF, IGE, and the Audit Court are poor due to inadequate human resources; staff lacks training and performance assessment; recruitments not always competitive and transparent.
  - Lack of sanctions for corrupt public procurement officials and insufficient empowerment of participants to report mal-practices.
- Public investment management (PIMA findings):
  - Deficiencies in project appraisal and selection: committee often selects projects without rigorous feasibility and impact evaluations.
  - Weak budgeting for capital spending and inadequate mechanisms to protect ongoing investment projects.
  - Limited coordination between Ministry of Finance, Ministry of Planning, subnational governments, and PPP oversight entities.
  - Ex-post controls of domestically-financed projects not systematically carried out.
  - Externally-financed projects mostly audited by donors; limited resources constrain the Audit Court to a restricted number of ex-post controls whose results are neither published nor shared with the National Assembly.

### PPPs and extractive sector governance
- PPPs:
  - Modern PPP law exists and favors BOT operations free of government financing or guarantees.
  - Implementation weaknesses: predominance of spontaneous offers not opened to competition (allowed only under special circumstances), direct negotiations vulnerable to overpricing and kick-backs.
- Extractive industries:
  - Constitution provides for high degree of transparency and mandates disclosure of contracts.
  - Progress: modernization of mining cadaster and publishing conventions.
  - Remaining gaps: disclosure of revenues related to extractive industries is not systematic; publication of annual audit reports of government’s natural resource revenue collection is delayed; extractive companies’ payments to SOEs are not published.
  - Local governments statutorily entitled to 15 percent of all mining and petroleum royalties are typically not made and not disclosed.
  - Niger quit the Extractive Industry Transparency Initiative (EITI) in 2017 when suspension was looming but has since undertaken steps to rejoin.

### Fiscal transparency
- Niger recorded the lowest score on the 2017 readings of the Open Budget Index.
- Findings from the survey:
  - Budget audit reports are inexistent.
  - Budget proposals and year-end reports are produced for internal use only.
  - Enacted budget is published with an excessive delay.
  - Executive, legislature, and SAI do not provide the public opportunities to engage in the budget process.
  - WAEMU Commission flagged a lack of public debates on quarterly budget executions.
- Recent efforts:
  - Publication of the 2019 draft budget submitted to Parliament.
  - Government committed to introducing legal requirements for timely publication of key documents: budget outturns, draft and approved budgets (including supplementary ones), a citizen budget, major conventions with foreign investors, PPP contracts, and tender awards.

### Implications for business environment and private-sector performance
- Empirical evidence on adverse effects of poor transparency, bureaucracy, and corruption:
  - Firms more likely to participate in public procurement markets when procurement information is complete, reliable, and timely (Knack et al., 2019).
  - Less kick-backs when exceptions to open competition in tendering must be explicitly justified and when independent complaint mechanisms exist.
  - Burdensome customs procedures reduce export volumes (Djankov et al., 2010).
  - Senior management time spent dealing with regulations and inspections stunts employment growth (Aterido et al., 2011).
  - Corruption reduces sales growth; firms that pay bribes suffer more from bureaucratic red tape (Fisman and Svensson, 2007; Kaufman and Wei, 1999).
  - Firms confronted with bribe requests take longer to get construction permits, operating licenses, electrical connections, and to clear customs (Freund et al., 2015); exporters faced with bribe demands less likely to continue selling abroad (Vijil et al., 2019).
- Burdensome regulatory procedures in Niger:
  - It takes on average 44 days to obtain a construction permit in Niger, against 62 days for the WAEMU region.
  - Delays in obtaining an import license and senior management time spent dealing with regulatory compliance are longer than on average in SSA.
  - Twice as many firms report bribe requests to obtain an operating license than in SSA on average.
  - Exposure to corruption particularly pronounced for firms trying to secure government contracts.
- Recent administrative simplification and judicial reforms:
  - One-stop shop in the Niamey Enterprise House to simplify creation of new companies.
  - Better processing of construction permits and reduced associated fees.
  - Commercial Court of Niamey started operations in 2016, increasingly settling commercial disputes typically within a few weeks; draft legislation updating Commercial Court law adopted recently.
  - Updates to Code of Civil Procedure to expedite claims and increased use of computerization to limit face-to-face contact.
  - Recourse to arbitration and mediation for commercial disputes now available.
  - Institution of additional courts across the country intended to ensure more timely and effective proceedings.

*Source: IMF staff report content as provided in the supplied PDF chapter/section.*

### 30.      Descriptive statistics based on the World Bank Enterprise Surveys illustrate the

### 1nerea2019002 - 30.      Descriptive statistics based on the World Bank Enterprise Surveys illustrate the

### Corruption and private-sector performance: descriptive findings
- Sample: unbalanced sample of 302 firms operating in manufacturing and services sectors in the years 2005, 2009 and 2017.
- Definition: firms that reported at least one bribe payment request across public transactions (paying taxes, obtaining permits or licenses, and utility connections) are classified as subject to corruption.
- Performance proxies: sales growth, employment growth, productivity growth.
- Key descriptive comparisons:
  - Exporters that pay bribes record on average a negative sales growth of -20.5 percent against +6.6 percent for those trading in a “clean” environment.
  - Young firms (in operation for less than 5 years) register an average sales growth rate of 28.7 percent in the absence of corruption, against 7.4 percent otherwise.
  - The negative association between bribery and performance is also verified for older firms and non-exporters, and when using productivity growth as a performance measure.

### Regression analysis and robustness (Annex I)
- Main regression results (Annex Table 1):
  - Bribery coefficient on Sales growth: -0.086** (standard error (0.036))
  - Bribery coefficient on Employment growth: 0.006 (standard error (0.038))
  - Bribery coefficient on Productivity growth: -0.120** (standard error (0.050))
  - Young: 0.239** on Sales growth; 0.613*** on Employment growth; 0.225* on Productivity growth.
  - Observations: Sales growth 161; Employment growth 192; Productivity growth 127.
  - R-squared: Sales 0.242; Employment 0.574; Productivity 0.190.
  - Notes: Standard errors clustered by sector; *** p<0.01, ** p<0.05, * p<0.1. Bribery is a dummy variable taking one if the firm reported at least one bribe payment request across public transactions dealing with utilities access, permits, licenses, taxes and trade.
- Interpretation reported in main text:
  - Sales of firms confronted with bribe requests grow 9 percentage points less than those that are not, and their productivity growth is 12 percentage points lower (Table Annex 1).
  - Public-sector rent-seeking hurts disproportionately more young firms and exporters.
- Regression discontinuity results (Annex Table 2):
  - Firms whose share of annual bribe payments in total sales is above the sector average record sales and employment growth rates between 8 and 9 percentage points less than firms below the sector average (Table Annex 2).
  - Selected RDD estimates (Panel A parametric, Panel B non-parametric bias-corrected / robust):
    - Panel A parametric frontier dummy: Sales growth -0.154* (column 1), -0.160** (column 2); Productivity growth -0.169*** / -0.190*** (columns 5-6).
    - Panel B non-parametric bias-corrected: Sales growth -0.093** / -0.088*; Productivity growth -0.085*** / -0.083***.
  - Main/bias bandwidths reported: 4.450 / 5.578; 3.804 / 5.578; 4.441 / 7.170; 3.805 / 7.170; 2.464 / 4.246; 2.111 / 4.246.
  - # obs. left/right of cutoff examples: 97 / 51; 113 / 61; 76 / 42.
  - Notes: Standard errors clustered by sector; *** p<0.01, ** p<0.05, * p<0.10, † p<0.13. Average bribe payment measured at the sector-year level. Frontier dummy takes one if firm’s share of total annual sales paid as informal payment is above the sector-year average.

### The Way Forward: priority reforms and policy recommendations
- Addressing gaps in anti-corruption legislation (asset declaration regime)
  - Filers: identify high-ranking officials (beyond those in the Constitution) to be subject to asset declaration; streamline list to target high-risk individuals and align with Audit Court and Constitutional Court capacities; expand disclosure to cover close associates and family members, possibly under a simplified regime.
  - Assets: clearly define assets to be declared, including movable and immovable assets, income, stocks and securities, liabilities, gifts, cash, and interests outside public office; require declaration of assets actually used or controlled by officials even if in third-party names.
  - Submission: set a user-friendly declaration form by decree; consider electronic filing later.
  - Verification: control all declarations for completeness; verification of accuracy should be risk-based (complaints/allegations, red flags, media reports, referrals).
  - Sanctions: set dissuasive administrative sanctions for non-compliance (fines, suspension, removal from office); fines could amount to the national daily minimum wage applied each day until remedial action; apply sanctions incrementally distinguishing initial and repeated offenses.
  - Publication: post declarations on a public website; Audit Court to disclose verification statistics and sanctions imposed.
- Stepping up implementation and enforcement
  - Strengthening anti-corruption institutions:
    - Bolster independence and provide sufficient human, physical, and financial resources.
    - Augment budgetary resources via donor financing and technical assistance.
    - For HALCIA: prioritize strengthening independence and establish the fund dedicated to its financing as mandated by law; publish annual reports and number/progression of cases.
    - For CENTIF: upgrade capacity, finalize acquisition of automated software for processing STRs.
    - Launch collaborative platform between HALCIA and the judiciary to improve corruption case processing.
  - Improving judiciary integrity and efficiency:
    - Create an independent body for recruitment, appointment, evaluation, promotion, transfer, dismissal, and disciplinary sanctions for all judges.
    - Reduce case backlogs and guarantee timely justice.
    - Publish and provide online access to all court decisions timely.
    - Digitalize filing of legal actions to reduce face-to-face contact.
  - Advancing the AML/CFT agenda:
    - Increase participation of non-financial entities (DNFBPs) in reporting suspicious activity.
    - CENTIF to intensify capacity-building, awareness-raising, and dissemination of guidelines to DNFBPs.
    - Improve supervision of banks and DNFBPs and strengthen coordination between the WAMU Banking Commission and CENTIF; involve CENTIF in local banks’ on-site inspections.
    - Accelerate creation of the common IT platform centralizing WAEMU FIUs’ STRs.
- Supporting public-sector governance through enhanced transparency
  - Modernize revenue administrations and enhance spending quality using IT and digitalization to reduce face-to-face interaction, improve recording, limit discretion, and improve transparency.
  - Reinforce SOE governance:
    - Update SOE legislation to clarify Minister of Finance and line ministries roles.
    - Conduct audits and implement a three-year procurement action plan.
    - Professionalize boards, use performance contracts, strengthen financial oversight and audit, and publish audit reports and salaries/benefits of board members and high-level officials.
  - Address weaknesses in public procurement:
    - Make competitive bidding the norm; limit single-sourced procurement to exceptional circumstances.
    - Publish tender award results; ensure timely processing and auditing of procurement; maintain comprehensive records at ARMP and set staffing competency guidelines.
    - Operationalize procurement monitoring system SIGMAP II and set stage for e-procurement.
    - Revive toll-free number for denouncing fraud and corruption in public procurement.
  - Strengthen public investment management and efficiency:
    - Consider only proposals with completed feasibility studies.
    - Strengthen ex-post assessment using risk-based approach targeting large investment projects; publish audit results.
  - Reduce reliance on unsolicited PPPs:
    - Make tendered PPPs the norm; open spontaneous PPPs to competition where possible; publicly disclose all PPP contracts.
- Fiscal transparency for extractive industries
  - Re-join EITI and follow its recommendations (disclose tax payments, licenses, contracts, production; maintain a license register with details on license holder and dates).
  - Consider building a live database of conventions related to natural resource exploration and exploitation.
  - Audit Court to ensure timely publication of audits of government extractive revenues collection.
  - Enforce legal public disclosure requirements for draft and approved budgets, budget outturns and audits, citizen budgets, PPP conventions, SOE financial statements and audits, statistics on tender awards and procurement oversight, ex-post assessments of large investment projects, and make the government gazette available online free of charge.
- Modernizing revenue administrations and customs
  - Shift from systematic physical controls at customs to risk-based checks; develop internal and ex-post controls and post-clearance audits.
  - Consider introducing status of authorized economic operators for low-risk operators to expedite clearance.
  - Renew performance management:
    - Renew revenue administrations’ performance plans.
    - Introduce performance-based pay/contracts for customs inspectors (experience cited from Madagascar and Cameroon).
    - Design performance contracts with objective indicators (speed of clearance, efficiency of customs control, revenues, fraud detection); reward good performance and sanction poor performance.
    - Use ASYCUDA World data for monitoring; reform HR management in customs to address misaligned incentives and high turnover.
- Securing stakeholder participation
  - Require strong political commitment and involve various stakeholders including civil society, media, private sector, regional entities, and donors.
  - Ensure timely access to information (court decisions, anti-corruption institution reports) to empower civil society and media to expose corrupt practices.
  - Sensitize and deter private actors from facilitating corruption.
  - Donors to provide capacity building and financial assistance.

*Source: INTERNATIONAL MONETARY FUND.*

### References

### References

### Academic articles and working papers
- Aterido, R., M. Hallward-Driemeier, and C. Pages (2011). “Big Constraints to Small Firms’ Growth? Business Environment and Employment Growth across Firms”, Economic Development and Cultural Change 59 (3): 609–48.
- Djankov, S., C. Freund, and S. C. Pham (2010). “Trading on Time”, Review of Economics and Statistics, 92 (1): 166–73.
- Fisman, R., and J. Svensson (2007). Are Corruption and Taxation Really Harmful to Growth? Firm Level Evidence, Journal of Development Economics 83 (1): 63–75.
- Freund, C., M. Hallward-Driemeier and B, Rijkers (2015). Deals and Delays: Firm-Level Evidence on Corruption and Policy Implementation Times, The World Bank Economic Review, pp. 1-29.
- Kaufmann, D., and S. J. Wei. (1999). “Does ‘Grease Money’ Speed up the Wheels of Commerce?” NBER, Working Paper 7093, National Bureau of Economic Research, Inc., Cambridge, MA.
- Knack, S., N. Biletska and K. Kacker (2019). Deterring Kickbacks and Encouraging Entry in Public Procurement Markets: Evidence from Firm Surveys in 90 Developing Countries, The World Bank Economic Review, 1-23.
- Laajaj, R., M. Eslava and T. Kinda (2018). “The Costs of Bureaucracy and Corruption at Customs: Evidence from the Computerization of Imports in Columbia”, Working paper.
- Okunogbe, O. and V. Pouliquen (2018). “Technology, Taxation and Corruption: Evidence from the Introduction of Electronic Tax Filing”, World Bank Policy Research Working Paper 8452, World Bank.
- Raballand, G., C. Chalendard, A. Fernandes, A. Mattoo and B. Rijkers (2017). Customs Reforms and Performance Contracts: Early Results from Madagascar, Governance Notes N° 2, September 2017, The World Bank.
- Raballand, G., M. Mallberg and J-C. Maur (2017). Informal Trade and Customs Revenue Losses in Niger, P160841, The World Bank.
- Rossi, Ivana M., Laura Pop, and Tammar Berger. (2017). Getting the Full Picture on Public Officials: A How-To Guide for Effective Financial Disclosure. Stolen Asset Recovery (StAR) Series. Washington, DC: World Bank.
- Vijil, M., L. Wagner and M.T. Woldemichael (2019). “Import Uncertainty and Export Dynamics”, World Bank Policy Research Working Paper 8793, World Bank.
- Laajaj, R., M. Eslava and T. Kinda (2018). “The Costs of Bureaucracy and Corruption at Customs: Evidence from the Computerization of Imports in Columbia”, Working paper.

### IMF, World Bank, and multilateral reports
- Badet, G., L. Damiba, S.B. Engueléguélé, E. Gaima, C.K. Iwuamadi, S. Ndiaye and S. Williams (2016). Effectiveness of Anti-Corruption Agencies in West Africa – Benin, Liberia, Niger, Nigeria, Senegal and Sierra Leone: A Review by Open Society Initiative for West Africa, Open Society Foundations.
- FMI (2019). Niger – Évaluation de la gestion des investissements publics (PIMA), rapport technique (version provisoire), Mars 2019.
- GIABA (2018). Secretariat’s Analysis, Tenth Follow-up Report of Niger, GIABA’s 30th Technical Commission/Plenary Meeting, November 11-16, 2018.
- IMF (2016). Corruption: Costs and Mitigating Strategies, IMF Staff Discussion Note, May 2016, SDN/16/05.
- IMF (1997). The Role of the Fund in Governance Issues – Guidance Note, Washington DC.
- IMF (2017). Madagascar, Selected Issues – Governance and Corruption, July 2017, IMF Country Report No 17/224.
- IMF (2018). Nigeria, Selected Issues – Strengthening Transparency and Governance in Nigeria, February 2018, IMF Country Report No 18/64.
- IMF (2018). Review of 1997 Guidance Note on Governance – A Proposed Framework for Enhanced Fund Engagement, April 2018, IMF Policy Paper.
- IMF (2018). Angola, Selected Issues – Governance and Economic Performance in Angola, June 2018, IMF Country Report No 18/57.
- IMF (2018). Second Review under the Extended Credit Facility Arrangement, and Request for Modification of a Performance Criterion, Niger, June 2018, IMF Country Report No. 18/166.
- IMF (2018). Third Review under the Extended Credit Facility Arrangement, Request for Waiver for Nonobservance of Performance Criterion, and Request for Augmentation of Access, Niger, December 2018, IMF Country Report No. 18/372.
- IMF (2019). Central African Economic and Monetary Community, Selected Issues – A Regional Approach to Enhancing Governance and Reducing the Potential for Corruption, January 2019, IMF Country Report No 19/2.
- IMF (2019). Curbing Corruption, Fiscal Monitor, Chapter 2, April 2019.
- IMF (2019). West African Economic and Monetary Union, Selected Issues – The WAEMU Surveillance Framework: Reforms to Foster Public Debt Sustainability, March 2019, IMF Country Report No 19/91.
- Banque mondiale (2018). Gouvernance des entreprises publiques et des agences publiques en République du Niger, Practice Globale Gouvernance, Juin 2018.
- Freund, C., M. Hallward-Driemeier and B, Rijkers (2015). Deals and Delays: Firm-Level Evidence on Corruption and Policy Implementation Times, The World Bank Economic Review, pp. 1-29.

### Regional, national, and legal documents relating to Niger
- CENTIF – Rapports annuels 2016, 2017 et 2018.
- Chêne, M. (2017). Niger: Overview of Corruption and Anti-Corruption, No. 2, January, Transparency International, U4 Anti-Corruption Resource Center.
- Ministère des Finances et Commission UEMOA (2018). Mission d’évaluation technique de la transposition et de la mise en œuvre des directives des finances publiques, Aide-mémoire, Niamey, les 12 et 13 juillet 2018.
- Niger – Arrêté n°56 MJ/GS/PPG du 12 août 2011 portant création d’un Bureau Informations-Réclamations, Lutte contre la Corruption et le Trafic d’Influence (BIRLCTI).
- Niger – Constitution de la 7ème République, 2010.
- Niger – Décret n°2018-007/PRN du 5 janvier 2018 portant adoption du document de Stratégie Nationale de lutte contre la Corruption et son Plan d’Actions.
- Niger – Loi n°003-2002 du 8 février 2002 déterminant les autres agents publics assujettis à l’obligation de déclaration des biens.
- Niger – Loi n°2016-33 du 31 octobre 2016 relative à la lutte contre le blanchiment des capitaux et le financement du terrorisme.
- Niger – Loi n°2016-44 du 6 décembre 2016 portant création, missions, attributions, composition, organisation et fonctionnement de la Haute Autorité de Lutte contre la Corruption et les Infractions Assimilées.
- Niger – Loi organique n°2012-08 du 26 mars 2012 déterminant les attributions, la composition, l’organisation et le fonctionnement de la Cour des Comptes.
- Knack, S., N. Biletska and K. Kacker (2019). Deterring Kickbacks and Encouraging Entry in Public Procurement Markets: Evidence from Firm Surveys in 90 Developing Countries, The World Bank Economic Review, 1-23.

### Other studies and sector-specific analyses
- Badet, G., L. Damiba, S.B. Engueléguélé, E. Gaima, C.K. Iwuamadi, S. Ndiaye and S. Williams (2016). Effectiveness of Anti-Corruption Agencies in West Africa – Benin, Liberia, Niger, Nigeria, Senegal and Sierra Leone: A Review by Open Society Initiative for West Africa, Open Society Foundations.
- Laajaj, R., M. Eslava and T. Kinda (2018). “The Costs of Bureaucracy and Corruption at Customs: Evidence from the Computerization of Imports in Columbia”, Working paper.
- Raballand, G., M. Mallberg and J-C. Maur (2017). Informal Trade and Customs Revenue Losses in Niger, P160841, The World Bank.
- Vijil, M., L. Wagner and M.T. Woldemichael (2019). “Import Uncertainty and Export Dynamics”, World Bank Policy Research Working Paper 8793, World Bank.
- Okunogbe, O. and V. Pouliquen (2018). “Technology, Taxation and Corruption: Evidence from the Introduction of Electronic Tax Filing”, World Bank Policy Research Working Paper 8452, World Bank.

*Content derived from the referenced list in 1nerea2019002 - References*

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_Source: https://www.imf.org/-/media/files/publications/cr/2019/1nerea2019002.pdf_
