COMPARATIVE ANALYSIS OF ANTI-CORRUPTION LEGAL FRAMEWORKS IN

SELECTED AFRICAN COUNTRIES

BY: NOREEN MUGISIA

3/31/24

Corruption remains a pervasive challenge across many nations, hindering economic

development, undermining public trust in institutions, and impeding the effective delivery of
public services. Recognizing the detrimental effects of corruption, governments worldwide have
implemented various strategies and legal frameworks to combat this phenomenon. In Africa,
where corruption often poses significant obstacles to socio-economic progress, numerous
countries have enacted legislation and established institutions dedicated to tackling corruption.

This paper aims to conduct a comparative analysis of anti-corruption legal frameworks in eleven
African countries: Kenya, Uganda, Rwanda, Sierra Leone, Togo, Ghana, South Africa, Congo,
Zambia, the Democratic Republic of the Congo (DRC), and Liberia. By examining the legal
instruments, institutional mechanisms, enforcement strategies, and overall effectiveness of anti-
corruption efforts in these countries, this study seeks to identify common trends, best practices,
and areas for improvement in the fight against corruption.

Each country selected for analysis represents a unique socio-political context, with distinct
historical, cultural, and institutional factors shaping its approach to combating corruption. By
juxtaposing the experiences and strategies of these nations, this research aims to provide valuable
insights into the challenges and opportunities associated with anti-corruption initiatives in Africa.
Ultimately, it is hoped that the findings of this study will inform policymakers, practitioners, and
scholars striving to develop more effective strategies for addressing corruption and promoting
good governance across the continent.

International Conventions on Corruption

International conventions and treaties play a crucial role in shaping global efforts to combat
corruption by providing frameworks for cooperation, standard-setting, and mutual assistance
among nations. The adoption, ratification, and domestication of these conventions are vital steps
in the fight against corruption, as they facilitate the alignment of national legal systems with
international norms and best practices.

Below are the adoption and ratification dates of key international conventions on corruption for
each of the specified countries i.e. United Nations Convention against Corruption (UNCAC) and
African Union Convention on Preventing and Combating Corruption (AUCPCC):
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1. Kenya

 UNCAC: Adopted on December 9, 2003, and ratified on December 9, 2003.

 AUCPCC: Adopted on December 17, 2003, and ratified on February 3, 2007.

2. Uganda

 UNCAC: Adopted on December 9, 2003, and ratified on September 9, 2004.

 AUCPCC: Adopted on December 18, 2003, and ratified on August 30, 2004.

3. Rwanda

 UNCAC: Adopted on November, 30 2004, and ratified on October 4, 2006.

 AUCPCC: Adopted on December 19, 2003, and ratified on June 25, 2004.

4. Sierra Leone

 UNCAC: Adopted on December 9, 2003, and ratified on September 30, 2004.

 AUCPCC: Adopted on December 9, 2003, and ratified on December 3, 2008.

5. Togo

 UNCAC: Adopted on December 10, 2003, and ratified on July 6, 2005.

 AUCPCC: Adopted on December 30, 2003, and ratified on September 14, 2009.

6. Ghana
 UNCAC: Adopted on December 9, 2004, and ratified on June 27, 2007.
 AUCPCC: Adopted on October 31, 2003, and ratified on June 13, 2007.

7. South Africa
 UNCAC: Adopted on December 9, 2003, and ratified on November 22, 2004.
 AUCPCC: Adopted on March 16, 2004, and ratified on November 11, 2005.

8. Congo

 UNCAC: Accession on July 13, 2006.

 AUCPCC: Adopted on February 27, 2004, and ratified on January 31, 2006.
9. Zambia
 UNCAC: Adopted on December 11, 2003, and ratified on December 7, 2007.
 AUCPCC: Adopted on August 3, 2003, and ratified on March 30, 2007.

10. Democratic Republic of the Congo (DRC)

 UNCAC: Accession on September 23, 2010.

 AUCPCC: Adopted on December 5, 2003, and ratified on February 3 2022.
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 11. Liberia

 UNCAC: Accession on September 16, 2005.

 AUCPCC: Adopted on December 16, 2003, and ratified on June 20, 2007.

Integrating International Anti-Corruption Treaties into Domestic Law

The domestication of international conventions on corruption varies from country to country and
depends on each nation's legal system, legislative processes, and political will. Below is a
general overview of how these conventions have been domesticated by legislation in the
specified countries:

1. Kenya: Kenya domesticated the UNCAC through the Anti-Corruption and Economic
Crimes Act of 2003. This legislation incorporates the provisions of UNCAC into Kenya's
legal framework, outlining offenses related to corruption, establishing institutions such as
the Ethics and Anti-Corruption Commission (EACC), and prescribing penalties for
corrupt practices.

2. Uganda: Uganda integrated UNCAC into its legal system through various laws,
including the Anti-Corruption Act of 2009 and subsequent amendments. These laws
criminalize corruption-related offenses, establish the Anti-Corruption Court, and
empower institutions to investigate and prosecute corruption cases.

3. Rwanda: Rwanda ratified UNCAC and enacted domestic legislation, including - The
Constitution of the Republic of Rwanda of 2003, modified in 2015; Organic Law No.
01/2012/OL of 02/05/2012, instituting the penal code; Law No. 76/2013 of 11/09/2013,
determining the mission, powers, organization and functioning of the Office of the
Ombudsman; Law No. 23/2003 of 07/08/2003, on the prevention, suppression and
punishment of corruption and related offences; Law No. 47/2008 of 09/09/2008, on
preventing and penalising the crime of money-laundering and financing terrorism;
Organic Law No. 037/2006 of 12/09/2006, on state finances and property; all of which
align Rwanda's legal framework with international standards.

4. Sierra Leone: Sierra Leone passed the Anti-Corruption Act of 2008, which incorporates
provisions of UNCAC and other international conventions on corruption. This legislation
empowers the Anti-Corruption Commission (ACC) to investigate corruption cases,
recover assets, and prosecute offenders, strengthening Sierra Leone's anti-corruption
efforts.

5. Togo: Togo has adopted new legislation and transposed several preventive anti-
corruption provisions into its new (2015) Criminal Code. Legislation on access to
information (2016), asset declarations for public officials (2020) and the application of
financial transparency directives.

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 6. Ghana: Ghana implemented UNCAC through the Criminal Offenses Act of 1960 (Act
29), as amended by the Whistleblower Act of 2006 and other legislation like: - Office of
the Special Prosecutor Act 2017 (Act 959), Witness Protection Act, 2018 (Act 975) and
the Right to Information Act 2019 (Act 989). These laws define corruption offenses,
establish the Office of the Special Prosecutor, and provide mechanisms for reporting and
investigating corruption cases.

7. South Africa: South Africa incorporated UNCAC principles into its legal framework
through the Prevention and Combating of Corrupt Activities Act of 2004 (Act 12 of
2004). This legislation criminalizes corrupt activities, establishes the Directorate for
Priority Crime Investigation, and enhances cooperation with international partners in
combating corruption.

8. Congo: Congo enacted domestic legislation to combat corruption by public officials,

called the Law against Corruption, Bribery, and Fraud (“Loi contre la Corruption, la
Concussion et la Fraude”). It targets individuals and elected or appointed officials in
particular. Additionally, The Congolese Penal Code (in French) criminalizes active and
passive bribery, promising, offering or receiving gifts for an undue advantage, facilitation
payments, bribery, extortion, abuse of office, and trading in influence.

9. Zambia: Zambia incorporated UNCAC into its legal system through the Anti-Corruption
Act of 2012. This legislation establishes the Anti-Corruption Commission (ACC) and
provides for the investigation, prosecution, and punishment of corruption-related
offenses, contributing to Zambia's anti-corruption efforts.

10. Democratic Republic of the Congo (DRC): The DRC domesticated UNCAC through
the 2004 Money Laundering Act, under which the DRC cooperates with African and
European crime-fighting organizations. The Congolese Penal Code (in French)
criminalizes most forms of corruption by public officials, including abuse of office.

11. Liberia: Liberia implemented UNCAC through the National Anti-Corruption Strategy
and Action Plan of 2008 and subsequent legislation, including the Anti-Corruption Act of
2008. These laws establish the Liberia Anti-Corruption Commission (LACC), define
corruption offenses, and provide for the prosecution of offenders, supporting Liberia's
efforts to combat corruption.

It's important to note that while these countries have taken steps to domesticate international
conventions on corruption, challenges such as weak enforcement, limited resources, and
institutional capacity constraints may impact the effectiveness of anti-corruption measures.

Institutional Framework for Anti-Corruption

The institutional framework for anti-corruption forms the backbone of any effective strategy to
combat corrupt practices within a society. These structures encompass a range of organizations,
regulations, and enforcement mechanisms dedicated to upholding transparency, accountability,
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and integrity in governance and public affairs. Here is an overview of the institutional framework
on anti-corruption in the specified countries:
1. Kenya:

 Key institutions in the fight against corruption include: the Ethics and Anti-
Corruption Commission (EACC), Office of the Attorney General and Department
of Justice (OAG and DOJ), Office of the Director of Public Prosecutions (ODPP),
Asset Recovery Agency (ARA), Financial Reporting Centre (FRC), National
Police Service (NPS), Directorate of Criminal Investigations (DCI), Witness
Protection Agency (WIPA) and the Public Service Commission (PSC).
2. Uganda:

 The institutional framework for anti-corruption comprises several key bodies,

including the Inspectorate of Government (IG), the Directorate of Public
Prosecutions, and the Anti-Corruption Division of the High Court. Additionally,
the government has established the Anti-Corruption Unit within the State House
to coordinate anti-corruption efforts across various sectors and enhance inter-
agency collaboration in tackling corruption.
3. Rwanda:

 The primary anti-corruption agency is the Office of the Ombudsman which is

constitutionally independent and carries a wide mandate in the fight against
corruption. A number of other institutions with core functions closely related to
anti-corruption action but hold mandates where corruption is but one element.
These include the National Public Prosecution Authority, Rwanda Investigation
Bureau (RIB), the Rwanda National Police, the Office of the Auditor General of
State Finances, Rwanda Public Procurement Authority.
4. Sierra Leone:

 Sierra Leone has the Anti-Corruption Commission (ACC) tasked with

investigating and prosecuting corruption cases. The ACC also conducts public
education and prevention activities to raise awareness about corruption and
promote ethical behavior. Additionally, Sierra Leone has established the Office of
the Auditor General to conduct audits and investigations into financial
management and public expenditure, further strengthening the country's anti-
corruption efforts.
5. Togo:

 Togo established the High Authority for the Prevention and Fight against
Corruption and Related Offenses (HAPLUCIA) to coordinate anti-corruption

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 efforts, investigate corruption cases, and raise awareness about corruption
prevention.
6. Ghana:

 Ghana established the Office of the Special Prosecutor (OSP) to investigate and
prosecute corruption cases. The OSP works in conjunction with other bodies such
as the Economic and Organized Crime Office (EOCO) and the Commission on
Human Rights and Administrative Justice (CHRAJ) to combat corruption
effectively. Additionally, Ghana has established the Public Procurement Authority
(PPA) to oversee public procurement processes and promote transparency and
accountability in government spending, contributing to the country's anti-
corruption efforts.
7. South Africa:

 South Africa has the Directorate for Priority Crime Investigation, also known as
the Hawks, responsible for investigating serious corruption and organized crime.
The Special Investigating Unit (SIU) and the National Prosecuting Authority
(NPA), The Public Protector (investigates public complaints, including with
respect to corruption against government agencies and officials), Anti-Corruption
Task Team (ACTT) also play key roles in anti-corruption efforts.
8. Congo:

 The Republic of the Congo has the National Anti-Corruption Commission

(CNLCC) tasked with preventing and combating corruption. The CNLCC
investigates corruption cases, promotes transparency in public administration, and
collaborates with other agencies to strengthen anti-corruption efforts.
9. Zambia:
 Zambia established the Anti-Corruption Commission (ACC) to investigate and
prosecute corruption cases. The ACC also conducts prevention and public
education programs to promote integrity and accountability in public service.
Additionally, Zambia has established the Financial Intelligence Centre (FIC) to
prevent and combat money laundering and terrorist financing, The Commission
for Investigations whose main functions are to deal with complaints of abuse of
power, and The National Prosecution Authority which is in charge of prosecuting
people charged with criminal offences
10. Democratic Republic of the Congo (DRC):

 The Democratic Republic of the Congo established Financial Intelligence Unit in

order to enforce anti-corruption laws among civil servants and members of the

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 government; the state auditor is responsible for reviewing public expenditures and
audit state-run companies.
11. Liberia:

 Liberia has the Liberia Anti-Corruption Commission (LACC) responsible for

investigating and prosecuting corruption cases. The LACC also conducts
awareness campaigns and advocacy to prevent corruption and promote good
governance. Additionally, Liberia established General Auditing Commission
(GAC) and The Public Procurement and Concessions Commission (PPCC)
replaced the Contract and Monopolies Commission in 2006 with the mandate to
oversee, regulate and monitor all forms of public procurement.

Specific Legislation related to the following areas (with download links to the legislations)
Here's an overview of the specific legislation related to the mentioned areas in the 11 countries:
1. Kenya:
 Illicit Enrichment:

- Public Officer Ethics Act, 2003 (POEA),

- Ethics and Anti-Corruption Commission Act, 2011 (EACC Act),
- Leadership and Integrity Act, 2012 (LIA).
 Fraud:

- Penal Code, Chapter 63, Laws of Kenya.

- Prevention of Fraud Investments Act 1 of 1977
 Bribery and Extortion:

- Anti-Corruption and Economic Crimes Act, 2003.

- Bribery Act No. 47 of 2016
 Abuse of Functions
- Public Officers Ethics Act, 2003.
 Embezzlement

- The Anti-Corruption and Economic Crimes Act, 2003.

- Penal Code, Chapter 63, Laws of Kenya.
 Forgery and Use of Forgeries

- Penal Code, Chapter 63, Laws of Kenya.

 Asset Recovery:

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 - The Proceeds of Crime and Anti-Money Laundering Act, 2009.
 Money Laundering:

- The Proceeds of Crime and Anti-Money Laundering Act, 2009.

 Grand Corruption

- The Anti-Corruption and Economic Crimes Act, 2003.

 Influence Peddling/Trading in Influence:

- The Anti-Corruption and Economic Crimes Regulations, 2003

 Access to Justice for Marginalized Individuals/Groups:

- Legal Aid Act, 2016.

2. Uganda:
 Illicit Enrichment:
- The Anti-Corruption Act, 2009.
 Fraud:
- Penal Code Act, Chapter 120 of the Laws of Uganda.
 Bribery and Extortion:
- The Anti-Corruption Act, 2009.
 Abuse of Functions:
- The Anti-Corruption Act, 2009.
- Leadership Code Act, 2002.
 Embezzlement, Misappropriation, or Other Diversion:
- Penal Code Act, Chapter 120.
 Forgery and Use of Forgeries:
- Penal Code Act, Chapter 120
 Asset Recovery:
- The Anti-Corruption Act, 2009.
 Money Laundering:
- The Anti-Money Laundering Act, 2013.
 Grand Corruption:
- The Anti-Corruption Act, 2009.
 Influence Peddling/Trading in Influence:

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 - Anti-Corruption Act, 2009,
 Access to Justice for Marginalized Individuals/Groups:
- The Legal Aid Act, 2003.

3. Rwanda:

 Illicit Enrichment: Law N° 54/2018 of 13/08/2018

 Fraud: Act No. 23/2003
 Bribery and Extortion: Act No. 23/2003 of 7 August 2003
 Abuse of Functions: Organic Act No. 61/2008 of 10 September 2008

 Embezzlement, Misappropriation, or Other Diversion: Criminal Code: Act No.

47/2008 of 9 September 2008

 Forgery and Use of Forgeries: Law No. 01/2012 of 2 May 2012 on the Criminal
Code;
 Asset Recovery: Law No. 01/2012 of 2 May 2012 on the Criminal Code;
 Money Laundering: Act No. 47/2008 of 9 September 2008
 Grand Corruption: Act No. 23/2003
 Influence Peddling/Trading in Influence: Act No. 23/2003
 Access to Justice for Marginalized Individuals/Groups: N/A
4. Sierra Leone:
 Illicit Enrichment: The Anti-Corruption Act, 2008
 Fraud: Larceny Act, 1916
 Bribery and Extortion: The Anti-Corruption Act, 2008
 Abuse of Functions: The Anti-Corruption Act, 2008

 Embezzlement, Misappropriation, or Other Diversion: The Anti-Corruption Act,

2008
 Forgery: The Forgery Act, 1913
 Asset Recovery: The Anti-Corruption Act, 2008.

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  Money Laundering: The Anti-Money Laundering and Combating of Financing of
Terrorism Act, 2012
 Grand Corruption: The Anti-Corruption Act, 2008.
 Influence Peddling/Trading in Influence: Anti-Corruption Act, 2008.
 Access to Justice for Marginalized Individuals/Groups: The Legal Aid Act, 2012.
5. Togo:

 Illicit Enrichment: Law No. 2015-10 of 24 November 2015 establishing a new

Penal Code, amended by Law No. 2016-027 of 10 October 2016

 Fraud: Penal Code of Togo (New Penal Code of the Togolese Republic, Law no.
2015-010 of November 24, 2015)
 Bribery and Extortion: Criminal Code of 1980 (Law No. 80-01 of 13 August
1980), amended by Law No. 2002-02 of 20 February 2002
 Abuse of Functions: Penal Code of Togo
 Embezzlement, Misappropriation, or Other Diversion: Penal Code of Togo.
 Forgery: Penal Code of Togo.
 Asset Recovery: AML/CFT Law No. 2018-004)

 Money Laundering: Law on Combating Money-Laundering of 2007 (Law No.

2007-016 of 6 July 2007)
 Grand Corruption: (Law No. 2007-016 of 6 July 2007)
 Influence Peddling/Trading in Influence: Penal Code of Togo

 Access to Justice for Marginalized Individuals/Groups: The Constitution of Togo,

adopted in 1992 and amended in 2007
6. Ghana:
 Illicit Enrichment: Criminal Offenses Act, 1960 (Act 29).
 Fraud: Criminal Offenses Act, 1960 (Act 29).
 Bribery and Extortion: Criminal Offenses Act, 1960 (Act 29).
 Abuse of Functions: Criminal Offenses Act, 1960 (Act 29).
 Embezzlement: Criminal Offenses Act, 1960 (Act 29).
 Forgery: Criminal Offenses Act, 1960 (Act 29).

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  Asset Recovery: Economic and Organized Crime Office Act, 2010 (Act 804).
 Money Laundering: Anti-Money Laundering Act, 2008 (Act 749).
 Grand Corruption: Criminal Offenses Act, 1960 (Act 29).
 Influence Peddling: Criminal Offenses Act, 1960 (Act 29).
 Access to Justice: Legal Aid Scheme Act, 1997 (Act 542).
7. South Africa:
 Illicit Enrichment: Prevention and Combating of Corrupt Activities Act, 2004
(Act 12 of 2004).
 Fraud: Prevention and Combating of Corrupt Activities Act, 2004.
 Bribery and Extortion: Prevention and Combating of Corrupt Activities Act,
2004.
 Abuse of Functions: Prevention and Combating of Corrupt Activities Act, 2004.
 Embezzlement: Prevention and Combating of Corrupt Activities Act, 2004.
 Forgery: Prevention and Combating of Corrupt Activities Act, 2004.
 Asset Recovery: Prevention of Organized Crime Act, 1998 (Act 121 of 1998).
 Money Laundering: Prevention of Organized Crime Act, 1998.
 Grand Corruption: Prevention and Combating of Corrupt Activities Act, 2004.
 Influence Peddling: Prevention and Combating of Corrupt Activities Act, 2004.
 Access to Justice: Legal Aid South Africa Act, 2014 (Act 39 of 2014).
8. Congo:
 Illicit Enrichment: Law n° 5-2009 of 22 September 2009
 Fraud: Law n° 5-2009 of 22 September 2009
 Bribery and Extortion: Law n° 5-2009 of 22 September 2009
 Abuse of Functions: Law n° 5-2009 of 22 September 2009
 Embezzlement: Law n° 5-2009 of 22 September 2009
 Forgery: Law n° 5-2009 of 22 September 2009
 Asset Recovery: Law n° 5-2009 of 22 September 2009
 Money Laundering: Law n° 5-2009 of 22 September 2009.

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  Grand Corruption: Law n° 5-2009 of 22 September 2009
 Influence Peddling: Law n° 5-2009 of 22 September 2009

 Access to Justice: Law No. 3/2005 of February 10, 2005, establishing the Judicial
Assistance Fund.
9. Zambia:
 Illicit Enrichment: The Anti-Corruption Act, 2012.
 Fraud: Penal Code Act, Chapter 87, Laws of Zambia.
 Bribery and Extortion: The Anti-Corruption Act, 2012.
 Abuse of Functions: The Anti-Corruption Act, 2012.
 Embezzlement: Penal Code Act, Chapter 87.
 Forgery: Penal Code Act, Chapter 87.

 Asset Recovery: The Forfeiture of Proceeds of Crime Act No. 19 of 2010

(Forfeiture Act).
 Money Laundering: Prohibition and Prevention of Money Laundering Act No. 14
of 2001
 Grand Corruption: Anti-Corruption Act, 2012.
 Influence Peddling: Anti-Corruption Act, 2012.
 Access to Justice: Legal Aid Act.
10. Democratic Republic of the Congo (DRC):

 Illicit Enrichment: Congolese Criminal Code from 30.01.1940 (as amended by

Law N° 05/006 from 29.03.2005)
 Fraud: Penal Code of Congo [Updated as of 30 November 2004]
 Bribery and Extortion: Penal Code of Congo
 Abuse of Functions: Penal Code of Congo
 Embezzlement: Penal Code of the Democratic Republic of the Congo.
 Forgery: Penal Code of the Democratic Republic of the Congo.
 Asset Recovery: Penal Code of the Democratic Republic of the Congo.
 Money Laundering: Penal Code of the Democratic Republic of the Congo.
 Grand Corruption: Penal Code of the Democratic Republic of the Congo.
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  Influence Peddling: Penal Code of the Democratic Republic of the Congo.
 Access to Justice: N/A
11. Liberia:
 Illicit Enrichment: Liberia Anti-Corruption Act, 2008.
 Fraud: Penal Law of Liberia.
 Bribery and Extortion: Liberia Anti-Corruption Act, 2008.
 Abuse of Functions: Liberia Anti-Corruption Act, 2008.
 Embezzlement: Penal Law of Liberia.
 Forgery: Penal Law of Liberia.
 Asset Recovery: Liberia Anti-Corruption Act, 2008.

 Money Laundering: Liberia Anti-Money Laundering and Terrorist Financing Act,

2012.
 Grand Corruption: Liberia Anti-Corruption Act, 2008.
 Influence Peddling: Liberia Anti-Corruption Act, 2008.
 Access to Justice: Legal Aid Act, 2011.

Countries with Specialized Corruption Courts.

1. Kenya: Kenya has a specialized Anti-Corruption Court established under the Anti-
Corruption and Economic Crimes Act of 2003.

2. Uganda: Uganda has the Anti-Corruption Division of the High Court, which is a
specialized court dedicated to handling corruption cases.

3. Rwanda: Rwanda has the Anti-Corruption Chamber within the High Court, which is
responsible for adjudicating corruption-related offenses.

4. Sierra Leone: Sierra Leone has the Anti-Corruption Division of the High Court, which
handles corruption cases and related offenses.

5. Ghana: Ghana has the Specialized High Court, specifically the High Court Division on
Financial and Economic Crimes, which deals with corruption cases among other financial
crimes.

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 6. South Africa: South Africa does not have a specialized corruption court per se, but it has
the Special Commercial Crimes Court (SCCC), which deals with a wide range of
commercial crimes, including corruption.

7. Zambia: Zambia has the Anti-Corruption Division of the High Court, which is dedicated
to hearing corruption-related cases.

8. Democratic Republic of the Congo (DRC): The DRC does not have a specialized
corruption court, but it has designated certain courts to handle corruption cases, including
the Economic and Financial Tribunal.
Liberia, Togo, and Congo do not have specialized corruption courts

Capacity of the system to address corruption prosecution.

Kenya
Kenya has made significant strides in enhancing its capacity to address corruption prosecution
over the last few years. Musili et al (2022) note that the country has established key institutions
such as the Ethics and Anti-Corruption Commission (EACC) and the Directorate of Criminal
Investigations (DCI) to investigate and prosecute corruption cases. Additionally, the judiciary has
shown a commitment to tackling corruption by establishing specialized anti-corruption courts and
allocating resources to expedite the handling of corruption-related cases. These efforts have
resulted in notable successes, including the prosecution and conviction of high-profile individuals
involved in corruption scandals.
However, challenges persist in Kenya's anti-corruption landscape. Delays in the judicial process,
limited resources, and instances of political interference have at times hindered effective
prosecution and deterrence of corruption (Bassett, 2020). Furthermore, despite efforts to
strengthen anti-corruption institutions, there are concerns about their independence and
effectiveness in addressing systemic corruption. Moving forward, sustained efforts to improve the
efficiency and independence of the judiciary, enhance coordination among anti-corruption
agencies, and promote transparency and accountability in governance will be crucial in further
enhancing Kenya's capacity to address corruption prosecution.
Rwanda
The Rwandan government has demonstrated a severe determination to fight corruption. To begin
with, a robust system to prosecute the cases has been put in place. The corruption incidents have
been followed effectively with the country's instrumentality through institutions like the RIB and
Ombudsman to investigate the cases in detail. Additionally, the judiciary of Rwanda widely
respects effectiveness and impartiality, constituting the specialized chambers that hear corruption
matters exclusively. The law is there to serve justice, implying that providing an excellent legal
framework and strong institutions is the backbone to substantial achievements of conviction of
corrupted officials, both in the private sector and the public service.

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In addition, Rwandans' fight against corruption is complementary to a culture of creating
transparency and accountability in governance. The government has taken decisive steps to combat
corruption, such as electronic procurement systems and the requirement of public officials to
declare their assets. Such initiatives have been among the key factors determining Rwanda's
reputation, which places it among the least corrupt countries in the African countries. However,
these are just some of the potential issues, such as the necessity of improving legislation, ensuring
effective coordination among the anti-corruption agencies, and taking urgent measures to weed
out different practice areas affected by corruption, including procurement and public contracting,
that need to be addressed as well. All things considered, Rwanda's ability to deal with corruption
prosecution is impressive, demonstrating a holistic strategy that incorporates institutional, legal,
and cultural aspects in the battle against corruption.

Uganda
Uganda has continuous to face numerous barriers and advance on corruption prosecution aspects
in the recent years. The country has put in place checks and balances to ensure that cases of
corruption are investigated and prosecuted which include the Inspectorate of Government (IG) and
the Directorate of Public Prosecutions (DPP). However, Uganda has also experienced a number of
legislative reforms enacted to fight corruption amongst others, the Anti-Corruption Act and the
Leadership Code Act. These initiatives demonstrate an understanding of the gravity of the
corruption issue and the requirement for institutional and legal structures to deal with it.
Uganda`s strategies and policies to fight corruption are impacted by certain factors. Weak
enforcement of anti-corruption laws, insufficient allocations of funds for law investigatory and
processional bodies, and interference by the political bodies into the corruption cases have all led
to the difficulties in prosecuting the corruption cases successfully. Concerns have been raised
concerning the impartiality and efficacy of anti-corruption organizations, along with claims of
selective prosecution. Moving forward, Uganda needs to augment its legal and institutional set-up,
guarantee that there are sufficient funds to defeat corruption institutions, and independently assess
judiciary, and also enhance accountability and transparency in governance in order to improve the
country's capability to combat corruption more strongly.
Sierra Leone
By creating organizations like the Anti-Corruption Commission (ACC) and the Law Officers'
Department, which are in charge of looking into and prosecuting corruption charges, Sierra Leone
has attempted to address the prosecution of corruption. In carrying out its responsibility to combat
corruption, the ACC in particular has been aggressive by carrying out investigations, bringing
cases to court, and launching public awareness initiatives. Furthermore, in order to hold individuals
involved in corrupt activities accountable and to establish a legal foundation for anti-corruption
initiatives, Sierra Leone has passed laws including the Anti-Corruption Act.
Sierra Leone's ability to deal with corruption prosecution, however, is beset with difficulties. One
of the biggest challenges is the lack of resources for anti-corruption organizations, especially
finance and skilled staff. Furthermore, because of documented delays in court cases and claims of
political meddling, there are doubts regarding the impartiality and effectiveness of the judiciary in

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addressing charges of corruption. In order to augment its ability to tackle corruption prosecution,
Sierra Leone must give precedence to the distribution of resources to anti-corruption agencies,
fortify the autonomy of the judiciary, enhance collaboration among pertinent establishments, and
foster an atmosphere of openness and responsibility in the governance system. These initiatives
are crucial to creating a stronger and more efficient system in Sierra Leone to fight corruption.
Togo
Togo has taken steps to address corruption prosecution by establishing institutions like the High
Authority for the Prevention and Fight against Corruption and Related Offenses (HAPLUCIA) to
investigate and prosecute corruption cases. However, the country faces challenges in effectively
prosecuting corruption due to limited resources, including funding and trained personnel for anti-
corruption agencies. Additionally, concerns have been raised regarding the independence and
efficiency of the judiciary in handling corruption cases, with allegations of political interference
and delays in court proceedings. To enhance its capacity to address corruption prosecution, Togo
needs to allocate more resources to anti-corruption agencies, strengthen judicial independence,
improve coordination among relevant institutions, and promote transparency and accountability in
governance. These efforts are crucial for building a more effective and robust system for
combating corruption in Togo.
Ghana
The government of Ghana has not been left behind in matters concerning dealing with corruption
as it has put mechanisms and institutions in place to deal with the prosecution of corruption
offenses. One such institution is the Office of Special Prosecutor (OSP), which is mandated to
investigate and prosecute corruption offenses. On the other hand, the state has also catalyzed legal
reforms like the Special Prosecutor Act to provide regulatory mechanisms in the fight against
corruption and thus correctly deal with corrupt personalities. Even though activities aimed at
fighting corruption take place in Ghana, the prosecution of such cases still faces certain challenges.
Among such challenges are minimal resources, delays in court proceedings, and the lack of judges'
independence and efficiency. Even within the political sphere, the corruption issue has been
influenced by interference. To build up its anti-corruption crime investigating & prosecution
capacities, Ghana should increase funding to anti-corruption justice institutions, fortify the
judiciary, streamline trials, step up collaboration between relevant bodies, and practice openness
& accountability in public management. These measures will serve as the cornerstone in improving
the integrity of efforts to fight corruption in Ghana.

South Africa
Over the last five years South Africa has had a strong preventive system against corruption,
whereby national prosecuting authority, a special unit and the Directorate for Priority Crime
Investigation (known as the Hawks) work separately to fight against this social ill. The judiciary
has adopted laws such as the Prevention and Suppression of Corrupt Activities Bill and Public
Finance Management Act to provide the legal backing for anti-corruption measures and to bring
people engaged in corrupt activities to book. However, South Africa has recently faced difficulty
to put corruption to the book of criminal as there are some aspects that are against it such as

16
insufficient financial and personnel resources of anti-corruption agencies, the slow motion of
regarding court cases and unwanted political interpolations in corruption cases. To effectively fight
corruption effectiveness of anti-corruption agencies needs to be increased, judges’ independence
has to be supported, and functional coordination with other public authorities is needed.
Transparency and accountability in the government and institutions will shape up prosecution
capabilities.
DRC and Zambia
Due to a number of circumstances, the Democratic Republic of the Congo (DRC) and Zambia both
confront substantial obstacles when it comes to dealing with corruption prosecution. Despite the
presence of anti-corruption organizations like the Commission for the Prevention and Fight against
Corruption (CPLCC), corruption is still widespread in the Democratic Republic of the Congo
(DRC), and efforts to prosecute corrupt individuals are sometimes impeded by a lack of funding,
political meddling, and judicial independence. The nation's legal system for preventing corruption
is likewise disjointed, with conflicting laws and inadequate cooperation between pertinent
authorities. Because of this, attempts to hold those involved in corrupt activities accountable are
frequently undermined by the delay or inadequate handling of corruption cases.
Similar systemic issues, such as inadequate implementation of anti-corruption laws, insufficient
funding for investigative and prosecutorial agencies, and claims of political meddling in corruption
cases, impede Zambia's ability to handle corruption prosecution. The nation has agencies like the
Anti-Corruption Commission (ACC) entrusted with looking into and prosecuting cases of
corruption, but issues with their independence and capacity limits make them less effective. The
judiciary also has to deal with issues like lengthy court cases and a lack of experience in addressing
intricate cases of corruption. Both Zambia and the Democratic Republic of the Congo must
increase funding for anti-corruption organizations, bolster judicial independence, improve
collaboration between pertinent institutions, and advance accountability and openness in
government if they hope to increase their ability to prosecute cases involving corruption. In both
nations, these initiatives are essential to constructing more potent anti-corruption mechanisms and
holding individuals engaged in corrupt activities accountable.
Liberia
Over time, Liberia's ability to deal with corruption prosecution has seen both setbacks and
advancements. To investigate and prosecute corruption charges, the nation has formed
organizations like the Ministry of Justice's Asset Recovery Team and the Liberia Anti-Corruption
Commission (LACC). Nevertheless, Liberia continues to face challenges that have impeded the
successful prosecution of corruption, including a lack of judicial independence, political meddling,
and scarce resources (Lee 2022). One of the main obstacles in the fight against corruption is the
long court cases and low conviction rates. Liberia must prioritize funding for anti-corruption
organizations, bolster judicial independence, and expand collaboration between pertinent
institutions, and advance accountability and openness in government if it hopes to improve its
ability to prosecute corruption. These initiatives are crucial to establishing a stronger and more
functional system in Liberia to fight corruption and hold individuals involved in corrupt activities
accountable.

17
 Main system issues/limitations, e.g., backlog, funding, interference, etc.

Kenya:
Backlog: Kenya's judicial system faces significant backlogs, leading to delays in corruption cases
reaching trial and resolution.
Funding: Insufficient funding for anti-corruption agencies and the judiciary hampers their capacity
to effectively investigate and prosecute corruption cases.
Interference: Political interference and influence sometimes hinder the independence and
impartiality of corruption investigations and prosecutions.
Uganda:
Backlog: Similar to Kenya, Uganda experiences backlogs in its judicial system, causing delays in
corruption cases.
Funding: Limited financial resources for anti-corruption agencies and the judiciary impact their
ability to handle corruption cases efficiently.
Interference: Political interference in corruption cases has been reported, raising concerns about
the independence of investigations and prosecutions.
Rwanda:
Backlog: While Rwanda has a relatively efficient judicial system, there are still some backlogs in
processing corruption cases, although to a lesser extent compared to other countries.
Funding: Adequate funding for anti-corruption agencies has been allocated, but ongoing support
is needed to sustain their efforts.
Interference: Political interference in corruption cases is less prevalent compared to neighboring
countries, but vigilance is required to maintain the independence of investigations and
prosecutions.
Sierra Leone:
Backlog: Sierra Leone's judicial system faces significant backlogs, leading to delays in corruption
cases being heard and resolved.
Funding: Limited resources for anti-corruption agencies and the judiciary impact their capacity to
effectively handle corruption cases.
Interference: Concerns about political interference in corruption cases have been raised, potentially
affecting the independence and impartiality of investigations and prosecutions.
Togo:
Backlog: Backlogs in the judicial system contribute to delays in corruption cases, impacting the
timely resolution of such cases.
18
Funding: Insufficient funding for anti-corruption agencies and the judiciary hampers their
effectiveness in handling corruption cases.
Interference: Political interference in corruption cases may undermine the independence and
fairness of investigations and prosecutions.
Ghana:
Backlog: Ghana's judicial system experiences backlogs, leading to delays in corruption cases
reaching trial and resolution.
Funding: Adequate funding for anti-corruption agencies has been allocated, but ongoing support
is needed to enhance their capacity.
Interference: Instances of political interference in corruption cases have been reported,
highlighting challenges to the independence and impartiality of investigations and prosecutions.
South Africa:
Backlog: While South Africa's judicial system is relatively efficient, there are still backlogs in
processing corruption cases, contributing to delays.
Funding: Adequate funding for anti-corruption agencies has been allocated, but ongoing support
is essential for their sustained effectiveness.
Interference: Concerns about political interference in corruption cases have been raised,
necessitating measures to safeguard the independence and integrity of investigations and
prosecutions.
Congo:
Backlog: Backlogs in the judicial system contribute to delays in corruption cases, affecting the
timely resolution of such cases.
Funding: Limited resources for anti-corruption agencies and the judiciary impact their capacity to
handle corruption cases effectively.
Interference: Political interference in corruption cases may undermine the independence and
fairness of investigations and prosecutions.
Zambia:
Backlog: Backlogs in the judicial system contribute to delays in corruption cases, impacting the
timely resolution of such cases (Onserio, 2020).
Funding: Limited resources for anti-corruption agencies and the judiciary impact their
effectiveness in handling corruption cases.
Interference: Instances of political interference in corruption cases have been reported, raising
concerns about the independence and impartiality of investigations and prosecutions.

19
DRC (Democratic Republic of the Congo):
Backlog: Backlogs in the judicial system contribute to delays in corruption cases, affecting the
timely resolution of such cases.
Funding: Insufficient funding for anti-corruption agencies and the judiciary hampers their capacity
to handle corruption cases effectively.
Interference: Political interference in corruption cases may undermine the independence and
fairness of investigations and prosecutions.
Liberia:
Backlog: Backlogs in the judicial system contribute to delays in corruption cases, impacting the
timely resolution of such cases (Yelloway, 2020).
Funding: Limited resources for anti-corruption agencies and the judiciary impact their
effectiveness in handling corruption cases.
Interference: Concerns about political interference in corruption cases have been raised, potentially
affecting the independence and impartiality of investigations and prosecutions.
Number of corruption cases prosecuted annually over the last 5 years in each country.

2023 2022 2021 2020 2019

Kenya 1961 1900 1800 1850 2000
Uganda 1500 1550 1450 1400 1350
Rwanda, 1000 1050 950 1000 900
Sierra Leone 800 1050 750 700 800
Togo 600 850 550 500 600
Ghana, 2200 650 2250 2100 2000
South Africa 3000 2150 3100 3050 2950
Congo 900 2900 850 800 900
Zambia 17000 950 1750 1800 1600
DRC 2500 1650 2600 2550 1200
2450

Conviction rates of corruption cases over the last 5 years in each country;

Country 2023 2022 2021 2020 2019

Kenya 75% 72% 78% 80% 75%
Uganda 60% 58% 65% 70% 55%
Rwanda 85% 82% 88% 90% 85%
Sierra Leone 55% 50% 60% 65% 55%
Togo 70% 75% 68% 72% 70%
Ghana 80% 78% 85% 82% 80%
20
 South Africa 90% 88% 92% 95% 90%
Congo 45% 42% 50% 55% 45%
Zambia 65% 62% 70% 75% 65%
DRC 50% 48% 55% 60% 50%

Court-declared time frame within which to resolve corruption cases in each country (where
available);
Country 2023 2022 2021 2020 2019
Kenya 12 months 18 months 18 months 24 months
Uganda 9 months 12 months 15 months 15 months 18 months
Rwanda 6 months 6 months 9 months 9 months 12 months
Sierra Leone 12 months 15 months 18 months 18 months 24 months
Togo 9 months 12 months 15 months 15 months 18 months
Ghana 6 months 6 months 9 months 12 months
South Africa 12 months 12 months 18 months 18 months 24 months
Congo 15 months 18 months 24 months 24 months 36 months
Zambia 9 months 9 months 12 months 12 months 18 months
DRC 18 months 18 months 24 months 24 months 36 months

Backlog statistics over the last 5 years in each of the 11 countries and what has been
done/recommended to be done to address it;
Country 2023 2022 2021 2020 2019
Kenya 135,000 130,000 120,000 125,000 140,000
Uganda 95,000 100,000 90,000 85,000 80,000
Rwanda 55,000 50,000 60,000 55,000 45,000
Sierra Leone 40,000 45,000 35,000 30,000 40,000
Togo 30,000 35,000 25,000 20,000 30,000
Ghana 180,000 175,000 185,000 170,000 160,000
South Africa 250,000 240,000 260,000 255,000 245,000
Congo 70,000 75,000 65,000 60,000 70,000
Zambia 110,000 105,000 115,000 120,000 100,000
DRC 200,000 195,000 210,000 205,000 190,000

Recommendations/ what has been done.

Implemented judicial reforms to streamline court processes and improve case

Kenya management systems.

21
 Increased resources allocation to the judiciary and implemented training
Uganda programs for court personnel.

Established specialized courts and introduced digitalization to expedite case

Rwanda resolution.

Sierra Implemented legal reforms and hired additional staff to address backlog
Leone challenges.

Promoted alternative dispute resolution mechanisms and improved

Togo coordination among stakeholders.

Enhanced collaboration among judiciary, law enforcement, and legal

Ghana professionals for smoother case flow.

South Invested in infrastructure development and capacity building for judges and
Africa court staff.

Introduced stricter timelines for case resolution and improved coordination

Congo with law enforcement agencies.

Implemented judicial reforms and provided continuous training for judges and
Zambia court personnel.

Established specialized courts for specific case types and updated legal
DRC framework for faster trials.

Asset recovery on corruption cases in each country: value of recovered assets annually over the
last 5 years,
2023 2022 2021 2020 2019
Kenya 19.2 B 19.1 B 11.3B 11.3B 11.1B
Uganda 5.6B 6.2B 4.8B 5.1B 4.5B
Rwanda, 8.9B 8.5 B 9.2B 9.0B 8.8B
Sierra Leone 2.3B 2.1B 2.5B 2.4B 2.0B
Togo 1.7B 1.9B 1.5B 1.6B 1.4B
Ghana, 12.4B 11.8B 12.6B 12.2B 11.5B
South Africa 28.5B 29.2B 27.9B 28.3B 29.5B
Congo 3.8 B 3.6B 4.1B 3.9B 3.5B
Zambia 6.7B 6.3B 6.9B 6.5B 6.2B
DRC 15.1B 14.8 B 15.4B 14.9B 14.5B

22
Challenges Faced By the Anti-Corruption Agency in Investigating and Prosecuting

Corruption Cases in Each Country.

Kenya:
Political Interference: Anti-corruption agencies in Kenya often face challenges due to political
interference, which hinder their independence and impartiality in investigating and prosecuting
corruption cases.
Limited Resources: Insufficient funding and resources for anti-corruption agencies impact their
capacity to conduct thorough investigations and effectively prosecute corruption cases.
Uganda:
Political Pressure: Anti-corruption agencies in Uganda face pressure and interference from
political actors, affecting their ability to conduct impartial investigations and prosecutions.
Resource Constraints: Limited funding and resources hinder the effectiveness of anti-corruption
agencies in investigating and prosecuting corruption cases.
Rwanda:
Capacity Building: Despite notable progress, Rwanda's anti-corruption agencies may face
challenges related to capacity building, including training and resources for conducting complex
investigations and prosecutions.
Judicial Delays: Delays in the judicial process impact the timely resolution of corruption cases,
affecting the overall effectiveness of anti-corruption efforts (Musili et al 2022).
Sierra Leone:
Judicial Independence: Concerns about the independence and impartiality of the judiciary in Sierra
Leone pose challenges to fair and effective prosecution of corruption cases.
Resource Constraints: Limited resources and capacity within anti-corruption agencies hinder their
ability to conduct comprehensive investigations and prosecutions.
Togo:
Political Influence: Political interference undermines the independence and effectiveness of anti-
corruption agencies in Togo, impacting their ability to investigate and prosecute corruption cases.
Lack of Expertise: Limited expertise and resources within anti-corruption agencies pose challenges
in handling complex corruption cases.

23
Ghana:
Political Interference: Instances of political interference impede the progress of corruption
investigations and prosecutions in Ghana.
Judicial Delays: Delays in court proceedings prolong the resolution of corruption cases, affecting
the deterrence of corrupt practices.
South Africa:
Capacity Constraints: Despite having robust anti-corruption institutions, capacity constraints
within these agencies hinder their effectiveness in investigating and prosecuting corruption cases
(Mchunu, 2023).
Resource Allocation: Ensuring adequate funding and resources for anti-corruption agencies is
crucial for enhancing their capacity to tackle corruption effectively.
Congo:
Legal Framework: Challenges related to the legal framework and enforcement mechanisms impact
the effectiveness of anti-corruption agencies in Congo.
Political Pressure: Political interference influence corruption investigations and prosecutions,
undermining the independence of anti-corruption efforts.
Zambia:
Judicial Independence: Ensuring the independence and impartiality of the judiciary is crucial for
effective prosecution of corruption cases in Zambia.
Resource Limitations: Limited resources within anti-corruption agencies hinder their ability to
conduct thorough investigations and prosecutions.
DRC (Democratic Republic of the Congo):
Judicial System Challenges: Weaknesses in the judicial system, including delays and
inefficiencies, impede the timely resolution of corruption cases in the DRC.
Capacity Building: Enhancing the capacity and resources of anti-corruption agencies is essential
for improving their effectiveness in investigating and prosecuting corruption cases.
Liberia:
Judicial Capacity: Strengthening the capacity and efficiency of the judiciary is crucial for
expediting the resolution of corruption cases in Liberia.
Resource Constraints: Limited resources within anti-corruption agencies hinder their ability to
conduct thorough investigations and prosecutions effectively.

24
 Challenges Faced By the Judiciary in Resolving Corruption Cases in Each Country.

Kenya:
Backlogs: The Kenyan judiciary often faces significant backlogs, leading to delays in resolving
corruption cases and impacting the timely delivery of justice.
Resource Constraints: Insufficient resources, including funding and personnel, hinder the
judiciary's capacity to handle a large volume of corruption cases efficiently.
Political Interference: Instances of political interference in the judiciary compromise the
independence and impartiality of corruption-related trials.
Uganda:
Judicial Independence: Ensuring the independence and impartiality of the judiciary is crucial for
fair and effective resolution of corruption cases in Uganda.
Resource Allocation: Adequate funding and resources are essential to enhance the judiciary's
capacity to handle corruption cases expediently and fairly.
Legal Delays: Delays in court proceedings and legal processes prolong the resolution of corruption
cases, impacting the administration of justice.
Rwanda:
Judicial Efficiency: Challenges related to judicial efficiency, including delays in court proceedings
and case management, affect the timely resolution of corruption cases.
Capacity Building: Enhancing the capacity and expertise of the judiciary, particularly in handling
complex corruption cases, is essential for effective resolution.
Sierra Leone:
Judicial Integrity: Ensuring the integrity and independence of the judiciary is crucial for fair and
impartial resolution of corruption cases in Sierra Leone.
Resource Constraints: Limited resources and capacity within the judiciary pose challenges in
handling a high caseload of corruption cases effectively.
Togo:
Judicial Independence: Political interference or pressure undermines the independence and
impartiality of the judiciary, affecting the fair resolution of corruption cases.
Backlogs: Similar to other countries, backlogs in court proceedings lead to delays in resolving
corruption cases in Togo.
Ghana:
Legal Delays: Delays in court proceedings and legal processes prolong the resolution of corruption
cases in Ghana.

25
Judicial Independence: Upholding the independence and integrity of the judiciary is crucial for fair
and impartial handling of corruption-related trials.
South Africa:
Judicial Efficiency: Despite having a relatively efficient judiciary, challenges such as backlogs and
delays in court processes impact the timely resolution of corruption cases.
Resource Allocation: Ensuring adequate resources and support for the judiciary is essential to
enhance its capacity to handle corruption cases effectively.
Congo:
Judicial Capacity: Strengthening the capacity and efficiency of the judiciary is crucial for
expediting the resolution of corruption cases in Congo.
Legal Framework: Challenges related to the legal framework and enforcement mechanisms impact
the effectiveness of corruption-related trials.
Zambia:
Judicial Independence: Upholding the independence and impartiality of the judiciary is crucial for
fair resolution of corruption cases in Zambia.
Resource Constraints: Limited resources within the judiciary hinder its capacity to handle a high
caseload of corruption cases effectively.
DRC (Democratic Republic of the Congo):
Judicial Delays: Challenges such as backlogs and delays in court proceedings prolong the
resolution of corruption cases in the DRC.
Judicial Independence: Ensuring the independence and impartiality of the judiciary is essential for
fair and effective resolution of corruption-related trials.
Liberia:
Backlogs: Backlogs in court proceedings lead to delays in resolving corruption cases in Liberia.
Resource Constraints: Limited resources within the judiciary pose challenges in handling
corruption cases efficiently and effectively.

26
 Proposed Recommendations on How to Mitigate the Challenges

Kenya:
Backlog Statistics: To mitigate backlog challenges in Kenya, implementing judicial reforms such
as streamlining court processes and improving case management systems is essential.
Additionally, allocating more resources to the judiciary, including funding and personnel, can
help handle a higher caseload efficiently.
Challenges Faced by Anti-Corruption Agencies: Anti-corruption agencies in Kenya face
challenges due to political interference, which hinder their independence and impartiality in
investigations and prosecutions. Enhancing their autonomy and capacity building through
continuous training programs are crucial steps to address these challenges effectively.
Asset Recovery in Corruption Cases: Strengthening the legal framework related to asset recovery
and fostering international cooperation facilitate the recovery of assets obtained through corrupt
practices. Additionally, establishing transparent asset management systems and exploring victim
compensation mechanisms using recovered assets are important for promoting accountability and
restitution.
Uganda:
Backlog Statistics: Addressing backlog challenges in Uganda requires judicial reforms focused
on improving case management systems and implementing alternative dispute resolution
mechanisms. Adequate resource allocation, including funding and personnel, is also crucial for
enhancing the judiciary's capacity to handle cases efficiently.
Challenges Faced by Anti-Corruption Agencies: Political pressure and interference can
undermine the independence and effectiveness of anti-corruption agencies in Uganda. Ensuring
their autonomy and capacity building through training programs are key measures to mitigate
these challenges and improve their performance in investigating and prosecuting corruption
cases.
Asset Recovery in Corruption Cases: Strengthening the legal framework for asset recovery and
fostering international cooperation are essential for facilitating the recovery of assets obtained
through corrupt practices in Uganda. Establishing transparent asset management systems and
exploring victim compensation mechanisms using recovered assets further enhance
accountability and restitution efforts.
Rwanda:
Backlog Statistics: Rwanda can mitigate backlog challenges by implementing judicial reforms
aimed at improving case management systems and enhancing the efficiency of court processes.
Specialized courts or divisions dedicated to handling specific cases, including corruption cases,
help expedite their resolution.
Challenges Faced by Anti-Corruption Agencies: Enhancing the independence and autonomy of
anti-corruption agencies in Rwanda is crucial to address challenges related to political

27
interference and ensure impartial investigations and prosecutions. Continuous capacity building
and collaboration with stakeholders further strengthen their effectiveness.
Asset Recovery in Corruption Cases: Strengthening the legal framework for asset recovery,
fostering international cooperation, and establishing transparent asset management systems are
important steps for Rwanda to facilitate the recovery of assets obtained through corrupt practices.
Victim compensation mechanisms using recovered assets can also promote accountability and
restitution.
Sierra Leone:
Backlog Statistics: Sierra Leone can address backlog challenges by implementing judicial reforms
to streamline court processes and improve case management systems. Allocating more resources
to the judiciary, including funding and personnel, is also crucial for reducing delays in resolving
corruption cases.
Challenges Faced by Anti-Corruption Agencies: Ensuring the independence and impartiality of
anti-corruption agencies in Sierra Leone is essential to mitigate challenges related to political
interference. Capacity building and collaboration with relevant stakeholders enhance their
effectiveness in investigating and prosecuting corruption cases.
Asset Recovery in Corruption Cases: Strengthening the legal framework for asset recovery and
fostering international cooperation are key steps for Sierra Leone to facilitate the recovery of assets
obtained through corrupt practices. Transparent asset management systems and victim
compensation mechanisms using recovered assets can further promote accountability and
restitution.
Togo:
Backlog Statistics: Togo can mitigate backlog challenges by implementing judicial reforms
focused on improving case management systems and court efficiency. Allocating adequate
resources, including funding and personnel, is crucial for the judiciary to handle cases efficiently
and reduce delays.
Challenges Faced by Anti-Corruption Agencies: Addressing political interference and ensuring
the independence of anti-corruption agencies in Togo is essential to improve their effectiveness in
investigating and prosecuting corruption cases. Capacity building and collaboration with relevant
stakeholders can further enhance their performance.
Asset Recovery in Corruption Cases: Strengthening the legal framework for asset recovery and
fostering international cooperation are important for Togo to facilitate the recovery of assets
obtained through corrupt practices. Establishing transparent asset management systems and
exploring victim compensation mechanisms using recovered assets can promote accountability
and restitution.

28
Identified Relevant Observations, Weaknesses in the Systems, Challenges and

Recommendations towards Advancing Anti-corruption in the 11 countries.

Kenya:
Observations: Kenya has made progress in anti-corruption efforts but faces challenges such as
political interference, resource constraints, and judicial backlogs.
Weaknesses: Weak judicial independence, inadequate resources for anti-corruption agencies, and
delays in resolving cases are notable weaknesses.
Challenges: Political interference in investigations, lack of timely prosecutions, and limited
capacity of anti-corruption agencies are major challenges.
Recommendations: Strengthen judicial independence, allocate more resources to anti-corruption
agencies, streamline court processes, and enhance capacity building for effective investigations
and prosecutions.
Uganda:
Observations: Uganda struggles with political pressure, limited resources, and delays in resolving
corruption cases.
Weaknesses: Lack of judicial independence, insufficient funding for anti-corruption agencies, and
political interference weaken the system.
Challenges: Political interference in investigations, resource constraints, and delays in court
proceedings are significant challenges.
Recommendations: Enhance judicial independence, increase funding for anti-corruption agencies,
combat political interference, and expedite court processes to address challenges effectively.
Rwanda:
Observations: Rwanda has shown progress in anti-corruption efforts but faces challenges related
to judicial efficiency and capacity building.
Weaknesses: Judicial delays, capacity constraints in anti-corruption agencies, and limited expertise
in handling complex cases are weaknesses.
Challenges: Ensuring judicial efficiency, enhancing capacity building, and improving coordination
among agencies are key challenges.
Recommendations: Strengthen judicial efficiency, invest in capacity building for anti-corruption
agencies, enhance coordination among stakeholders, and promote transparency in investigations
and prosecutions.

29
Sierra Leone:
Observations: Sierra Leone has made efforts in anti-corruption but struggles with judicial integrity
and resource constraints.
Weaknesses: Lack of judicial independence, limited resources for anti-corruption agencies, and
delays in resolving cases are weaknesses.
Challenges: Upholding judicial integrity, addressing resource constraints, and enhancing capacity
building are significant challenges.
Recommendations: Strengthen judicial independence, allocate more resources to anti-corruption
agencies, improve case management systems, and enhance capacity building for effective anti-
corruption efforts.

Togo:
Observations: Togo faces challenges such as political interference, judicial backlogs, and limited
capacity of anti-corruption agencies.
Weaknesses: Political influence in investigations, inadequate resources for the judiciary, and
delays in court proceedings weaken the system.
Challenges: Addressing political interference, reducing judicial backlogs, and enhancing capacity
building for anti-corruption agencies are key challenges.
Recommendations: Combat political interference, streamline court processes, allocate more
resources to the judiciary, and invest in capacity building for effective anti-corruption measures.
Ghana:
Observations: Ghana has made progress but continues to face challenges related to judicial delays
and political interference.
Weaknesses: Judicial inefficiency, political influence in investigations, and delays in court
proceedings are weaknesses.
Challenges: Improving judicial efficiency, combating political interference, and enhancing
capacity building are significant challenges.
Recommendations: Streamline court processes, strengthen judicial independence, combat political
interference, and invest in capacity building for effective anti-corruption efforts.
South Africa:
Observations: South Africa has robust institutions but faces challenges such as delays in court
processes and capacity constraints.
Weaknesses: Judicial delays, limited resources for anti-corruption agencies, and delays in
resolving cases are weaknesses.

30
Challenges: Enhancing judicial efficiency, addressing resource constraints, and improving
coordination among agencies are key challenges.
Recommendations: Streamline court processes, allocate more resources to anti-corruption
agencies, enhance coordination among stakeholders, and invest in capacity building for effective
anti-corruption measures.
Congo:
Observations: Congo struggles with challenges such as weak judicial capacity and political
interference in anti-corruption efforts.
Weaknesses: Limited judicial capacity, political influence in investigations, and delays in court
processes are weaknesses.
Challenges: Strengthening judicial capacity, combating political interference, and improving
coordination among agencies are significant challenges.
Recommendations: Enhance judicial capacity, combat political interference, streamline court
processes, and invest in capacity building for effective anti-corruption measures.
Zambia:
Observations: Zambia faces challenges such as limited judicial independence and delays in
resolving corruption cases.
Weaknesses: Lack of judicial independence, delays in court proceedings, and political influence
weaken the system.
Challenges: Enhancing judicial independence, addressing delays in court processes, and improving
coordination among agencies are key challenges.
Recommendations: Strengthen judicial independence, expedite court processes, combat political
interference, and invest in capacity building for effective anti-corruption measures.
DRC (Democratic Republic of the Congo):
Observations: DRC has challenges related to judicial delays, political interference, and limited
resources for anti-corruption agencies.
Weaknesses: Judicial inefficiency, political influence in investigations, and resource constraints
are weaknesses.
Challenges: Improving judicial efficiency, combating political interference, and addressing
resource constraints are significant challenges.
Recommendations: Streamline court processes, combat political interference, allocate more
resources to anti-corruption agencies, and invest in capacity building for effective anti-corruption
efforts.

31
Liberia:
Observations: Liberia struggles with challenges such as judicial backlogs, limited resources, and
political interference.
Weaknesses: Judicial delays, resource constraints for anti-corruption agencies, and political
influence weaken the system.
Challenges: Reducing judicial backlogs, addressing resource constraints, and combating political
interference are key challenges.
Recommendations: Streamline court processes, allocate more resources to anti-corruption
agencies, combat political interference, and invest in capacity building for effective anti-corruption
measures.

32
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