GFAR Principles in Action: the MANTRA Project's Monitoring of the Disbursement of Abacha II funds in Nigeria

At the Global Forum on Asset Recovery (GFAR) held at the World Bank in December 2017, Nigeria, Switzerland, and the World Bank signed an MOU on the return of $321 million in funds stolen by President Abacha and his family to Nigeria (“Abacha II”). Under the agreement, the World Bank is monitoring the disbursement of the funds which are being used for a direct cash transfer program under the National Social Safety Net Project (NSSNP). As of May 2019, good progress has been reported and the funds are indeed reaching targeted poor households, with $37 million of stolen funds already disbursed to over 300,000 households and a further $50 million in stolen assets requested for disbursement.[1]
 
In line with Principles 4 and 10 of the GFAR Principles, which, respectively, call for transparency and accountability in the return and disposition of recovered assets and encourage the inclusion of civil society, non-governmental and community-based organizations in the asset return process, Nigerian civil society organizations played a prominent role in the negotiations leading up the MOU and in the monitoring of the disbursed funds.

The Africa Network for Environment and Economic Justice (ANEEJ), with financial support from DfID, is leading an impressive effort to monitor the disbursement and end-use of returned assets, called the MANTRA project (Monitoring of Recovered Assets through Transparency and Accountability). Under their first round of monitoring, a group of 35 civil society partner organizations dispatched over 500 monitors to the field to verify the reported data, survey beneficiaries, and witness cash disbursements first hand.

The initial results of this monitoring exercise are promising. While there is certainly room for improvements in the project implementation (and the report makes a few helpful suggestions in this regard), the monitoring shows that, by and large, disbursements are on track and are successful in directly reaching poor households in Nigeria. Spot checks confirmed enrolled participants in all 11 states and over 90% of monitored beneficiaries reported having received at least the base transfer of 5,000 Naira per household per month (around US$16).

This monitoring effort is exactly the kind of commitment to transparency, accountability and inclusion of non-governmental stakeholders in asset returns that was envisaged in GFAR Principles 4 and 10 and that we need to see happen more routinely for returns of stolen assets around the world.
 
See below the executive summary of ANEEJ’s detailed report on the MANTRA project. The full report is available on ANEEJ’s website. The MANTRA website has more materials on the field monitoring project.


[1] “World Bank Monitoring Role in the Return of Stolen Funds to the Federal Republic of Nigeria”, UNODC International Expert Meeting on the Return of Stolen Assets, Addis Ababa, May 2019
 

“Tackling Poverty With Recovered Assets: The MANTRA Model”, ANEEJ, January 2019

Executive Summary

The 2015 Sustainable development Goals (SDGs) identify the need for the prevention of illicit financial flows and the recovery of stolen assets as essential for development. The SDGs further recommend that funds recovered in asset recovery interventions are invested in social safety net programmes in the country of origin.[1]

Nigeria has recorded successes in asset recovery efforts with the repatriation of $752 million of the Abacha loot from Switzerland to Nigeria in 2005 and 2006 (World Bank, Federal Ministry of Finance, December 2006).The Swiss authorities also returned $322.5 million dollars of the Abacha loot to Nigeria in 2017.

In 2005, the Memorandum of Understanding (MOU) between Switzerland and Nigeria mandated that the recovered funds were to be spent on MDG-based interventions and this was spent on 5 sectors (Health, Education, Water, Electricity and Roads) and the process was monitored by CSOs in Nigeria (World Bank, Federal Ministry Of Finance, December 2006). In 2017, the MOU between both countries specified the funds should be spent on the poor through the existing social safety net programmes and monitored by civil society groups and the World Bank.

The Federal Ministry of Justice, in January 2017, signed an MOU with the African Network for Economic and Social Justice (ANEEJ) for the monitoring of the $322.5 million recovered Abacha loot. ANEEJ commenced the ‘’Monitoring of Recovered Assets through Transparency and Accountability’’ (MANTRA) project in 2018 with funding from the British government's Department for International Development (DfID) under the Anti-Corruption in Nigeria (ACORN) programme to carry out the monitoring of the disbursement of the recovered assets in one of Nigeria’s social safety net programmes, the National Cash Transfer Programme (NCTP). MANTRA was designed to address issues of corruption within the broader objectives of the ACORN programme which aims to strengthen the anticorruption regime in Nigeria. The MANTRA project also aims to ensure that assets recovered are disbursed or invested in programmes for the poor and vulnerable in line with the SDGs.

ANEEJ's first monitoring exercise held in December 2018, in partnership with 6 regional civil society organization (CSO) who took the lead in their regions to engage  a total of 35 CSOs, over 500 monitors and 44 Supervisors for the exercise in 5 geopolitical zones of the country.

The specific objectives for the August/September 2018 monitoring exercise were:
  • To verify that the data reported for the August/September 2018 payment period (number of households enrolled, number of households benefiting from the conditional cash transfer, total funds disbursed and the proportion of grievances reported that was resolved).
  • To verify that the data generated are fit for decision making and cannot be manipulated for personal interest.
  • To assess and identify potential challenges to data quality that the data management and reporting systems may create at all levels.
  • To develop recommendations to improve the gaps identified.

The methodology utilized was a data quality assessment (DQA) process. The DQA is a form of assessment that reviews data on services rendered at a point of service and through reporting levels in a system with multiple reporting levels. The monitoring exercise conducted spot checks on the funds disbursed in the August to September payment cycle to 30,846 beneficiaries in 11 states across 5 geopolitical zones of Nigeria. The exercise spanned 2 weeks and was conducted across reporting levels of the National Cash Transfer Office (NCTO) and the National Social Safety Net Coordinating Offices (NASSCO). Data was also reviewed from the Central Bank of Nigeria (CBN), World Bank, National Cash Transfer Programme (NCTP), and the National Beneficiary Register (NBR). 

The data sets reviewed by the monitoring exercise were:
  • Number of households enrolled for the August/September 2018 payment round
  • Total number of households benefiting from the conditional cash transfer programme in the August/September 2018 payment round
  • Proportion of grievances resolved for the August/September 2018 payment round
  • Total funds disbursed for the August/September 2018 payment round
Records obtained from the National Cash Transfer Office indicate that about 2,418,430,000 Naira was paid to 241,843 beneficiaries in 19 states for the August/September payment round. The monitoring confirmed that 1,509,490,000 Naira was disbursed to 150,949 beneficiaries in 11 States monitored for the August/September payment round. The funds disbursed from the Abacha loot comprised 80% of the total funds paid at the August/September payment cycle while the other 20% represented funds from the World Bank loan facility for the National Cash Transfer Programme.

 About 28,131 households representing 91.2% of respondents reported receiving at least the base amount 5000 Naira while 2,715 households representing 8.8% of respondents had not been paid as at the time of monitoring. State-level data on total funds disbursed and total individuals paid were available at national level and in 6 States. 5 out of the 11 states assessed could not provide this required information for their state at state level. State-level information on enrollment and payment were presented in different formats by all states assessed.

Findings on grievances from beneficiaries revealed 29,722 (96.4%) of all beneficiaries were satisfied with the method of registering grievances in the programme. However, grievances in the programme are underreported and the local government authority-level team reported delays in the feedback timeline from the NCTO and the State Cash Transfer Offices on grievances reported. A software application is being designed to address these challenges.

Key challenges to data quality and reporting identified were:
  • Absence of a standardized process for State Cash Transfer Offices to collate and report on total funds disbursed and total persons paid at each round in the respective states
  • Delay in national level reconciliation process on total individuals paid
  • Unavailability of information on total beneficiaries paid and unpaid at ward and community levels at the time of the monitoring
  • Underreporting on grievances in the programme
  • Issues with the sharing of timely information to the general public on program data to improve transparency and accountability of the institution and ensure improved public trust in the programme,
  • Delay in the onset of payment on payment days which sometimes delays payment until late at night
  • Issues with updates to beneficiary information resulting in removal of beneficiaries from the beneficiary list and problems with dissemination of information on payments. 4,214 (13.7%) of beneficiaries monitored were not informed on time of the August/September payment.
  • Marking of beneficiary household in some community violates confidentiality standards in the programme
 Some key recommendations for improving the programme were:
  • Improving timeliness of information to the beneficiaries on the timing of disbursement and eligible beneficiaries
  • Making payments to beneficiaries in electronic format
  • Standardized process for reporting at state and ward level to properly report on total funds paid in the programme at the NCTO and local government authority at each payment round
  • A reporting format on the total amount of funds and beneficiaries paid in each state to be designed, possibly with infographics, for dissemination to CSOs and the general public to increase confidence in the process. This can be done quarterly, reflecting data for each payment round, including a reflection on specific information on total funds disbursed from the Abacha loot.
  • Improvements need to be made in the national-level reconciliation process on total individuals paid in the programme at every point in time.

  1. SDG 16 places emphasis on the need for ‘’effective, accountable and inclusive institutions at all levels’’ Target 16.4 specifies ‘’by 2030, significantly reduced illicit financial and arms flows, strengthen the recovery and return of stolen assets and combat all forms of organized crimes’’

 

See the October 2019 newsletter for more articles