Washington, DC: On December 7, 2022, the Executive Board of the International Monetary
Fund (IMF) concluded a periodic review of the safeguards assessments
policy.
The review covered experience with the policy since the last review in
2015, and included a staff paper, Safeguards Assessments – 2022 Review of Experience, and an independent report by an external panel of experts, Safeguards Assessments – 2022 External Expert Panel’s Advisory Report. The safeguards assessments policy’s main objective is to minimize the
possibility of misreporting of information under IMF lending arrangements
and misuse of IMF resources.
Safeguards assessments seek to provide reasonable assurance to the IMF that
central banks of member countries using IMF resources have adequate
governance and control frameworks to manage their resources and IMF
purchases or disbursements. The assessments cover the following key areas
of central bank operations: the external audit mechanism, the legal
structure and autonomy, the financial reporting framework, the internal
audit mechanism, and the system of internal controls. In addition, the
assessments will now cover the governance arrangements at the central bank
as a separate pillar in the safeguards framework. The policy continues to
require that central banks publish their financial statements that have
been independently audited by external auditors in accordance with
internationally accepted auditing standards.
The external panel of experts comprised: Mr. Mohammed Nyaoga (Chair),
Chairman of the Central Bank of Kenya Board of Directors and a Senior
Counsel and Senior Partner of Mohammed/Muigai LLP Advocates; Professor
Blanaid Clarke, the McCann FitzGerald Chair in Corporate Law, Trinity
College Dublin and a former member of the Irish Central Bank Commission;
Dr. Maher Sheikh Hasan, the Counsellor and Chief Economist of the Arab
Monetary Fund, and a former Deputy Governor of the Central Bank of Jordan;
and Mr. Brian Wynter, a former Governor of Bank of Jamaica, and the past
founding CEO of Jamaica’s Financial Services Commission.
Executive Board Assessment
[1]
Executive Directors welcomed the opportunity to review the experience with
the safeguards assessments policy since the last review in 2015. They noted
that the policy remains an important and integral part of the Fund’s
overall risk management framework. Directors expressed their appreciation
to the external panel of experts for their independent appraisal of the
safeguards assessments policy and their conclusions and recommendations to
enhance the safeguards framework.
Directors recognized the importance of the safeguards assessments policy to
help mitigate the risks of misreporting and misuse of Fund resources. They
welcomed the findings that the policy continues to play an important role
to meet these objectives and to maintain the Fund’s reputation as a prudent
lender. Directors noted positively that in cases where central banks have
been subject to more than one assessment, there has broadly been an
improvement in the governance and control frameworks, notwithstanding
challenges.
Directors agreed that the existing framework for the assessment and
monitoring of central banks’ governance and control mechanisms remains
broadly appropriate. They welcomed the proposals for further enhancements
to keep pace with evolving developments, including establishment of a
separate pillar on governance in the safeguards assessments framework to
facilitate broader coverage and discussion of the board oversight role and
the division of responsibilities among key decision-making bodies to
preserve accountability. Directors also recognized the continuing
importance of integrated risk management in strengthening central banks’
control frameworks and supported the broader coverage of financial risks in
risk management functions, taking into account the technical capacity of
each central bank.
Directors noted the developments in issuance of central bank digital
currencies in some member countries and broadly supported safeguards
coverage of these activities in a systematic and consistent approach. This
would help ensure that appropriate oversight and technical and operational
aspects are in place to manage the specific risks arising from these
activities. Directors also welcomed staff’s plans to expand its outreach to
central banks through regional governance events and by disseminating
operational guidelines to central banks to help build awareness of the
safeguards process and leading practices and international standards.
Directors emphasized the importance of monitoring and capacity development
in improving implementation of safeguards recommendations.
Directors noted staff’s experience with the fiscal safeguards reviews
(FSRs) conducted to date and welcomed the proposals to strengthen the
modalities for the reviews, including in-person or hybrid engagement,
review processes with management approvals, and a formal mechanism for
staff to follow up on recommendations. Directors also welcomed the proposal
to require FSRs for High Combined Credit Exposure (HCCE) cases with at
least 25 percent of resources directed to budget financing. Given the scope
and resource challenges, Directors broadly agreed that the existing
threshold for FSRs remains appropriate and covered a significant proportion
of Fund resources disbursed for budget financing during the review period.
A number of Directors, however, felt that there is value to increasing the
number of FSRs, and encouraged staff to explore alternative thresholds at
the next review of the safeguards policy.
Directors generally agreed that the safeguards assessments policy would
apply to new requests for Resilience and Sustainability Facility (RSF)
arrangements by members that seek access to the Resilience and
Sustainability Trust (RST) resources through a concurrent program supported
by the Policy Coordination Instrument (PCI) or the Policy Support
Instrument (PSI). It was noted that the safeguards framework is
sufficiently flexible and would continue to take into account
country-specific circumstances, including for small states that seek access
to the RST and have limited capacity.
Many Directors were willing or open to support the staff’s proposal to
introduce an exceptional event clause in the safeguards policy in the event
of a future global crisis that leads to similar unprecedented demands for
Fund financing (as during the pandemic, which resulted in a large pipeline
of safeguards assessments), noting that in such an event, management
approval, followed by a staff paper to the Board for a decision to activate
the clause for a pre-defined period would be required. Many other
Directors, however, expressed reservations or disagreed with the proposal
and cautioned that delaying safeguards assessments is not to be undertaken
lightly, given that timely assessments are crucial to identifying
vulnerabilities, and that defining criteria for such a clause ex ante is
difficult. Some Directors argued for a risk-based approach to the
exceptional event clause, allowing the extended flexibility only for
lower-risk cases. A few Directors also suggested that utilizing any such
flexibility should be based on an assessment of the workload, and not on
global economic developments. In the end, Directors underscored that
allocating appropriate resources for safeguards assessments is crucial.
Directors urged staff to carefully monitor the resource needs for the work
on safeguards assessments. They noted that structural resource requirements
would need to be considered in the context of the budget discussions.