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Strengthening Anti-Corruption Institutions (SN0003)



Action Plan: Senegal Action Plan 2021-2023

Action Plan Cycle: 2021



Lead Institution: OFNAC

Support Institution(s): Other actors involved in the implementation of the commitment • Institutions (National Assembly, Presidency of the Republic) • Ministries of Finance, Justice and Economy • Control bodies (General State Inspection, Court of Auditors, IGF, CENTIF) • Employers • Civil Forum • Local authorities • Development partners

Policy Areas

Anti Corruption and Integrity, Anti-Corruption Institutions, Asset Disclosure, Legislation, Whistleblower Protections

IRM Review

IRM Report: Senegal Action Plan Review 2021-2023

Early Results: Pending IRM Review

Design i

Verifiable: Yes

Relevant to OGP Values: Yes

Ambition (see definition): High

Implementation i

Completion: Pending IRM Review


What is the public issue that the commitment will address? After having adhered to several international anti-corruption instruments, Senegal set up OFNAC, by law n°2012-30 of December 28, 2012. This institution investigates cases and regularly submits reports to the public prosecutor implicating certain individuals. However, these reports are not always followed up. This can be explained, to some extent, by the absence of prerogatives of the OFNAC regarding the follow-up of investigation files transmitted to the competent judicial authorities. In addition, some of those authorities who are subjected to the declaration of assets do not fulfill this obligation, as provided for by Law No. 2014-17 of 2 April 2014, without being subject to sanctions. Consequently, strengthening the assignments of OFNAC would be a way of improving anti-corruption strategies and increasing the accountability and transparency of public action.

What are the objectives of the commitment? The main objective of this commitment is to strengthen the assignments of OFNAC. Specifically, it consists in one hand of ensuring that follow-up is given to investigation files transmitted to the competent judicial authorities, and in another hand, of making the declaration of assets be effective for all those who are subjected to the law

How would the commitment contribute to solving the public issue? The commitment will help: - strengthen the credibility of OFNAC - prevent corruption; and - improve the repression of corruption; - increase transparency in the management of public affairs and the follow-up of investigative files 21

Why is this commitment relevant to the OGP values? The commitment refers to the principle of anti-corruption, transparency and accountability, promoting the integrity of public officials.

Further information Senegal has a national anti-corruption strategy with three major axes: - Reform of the normative and institutional framework; - Improvement of governance and coordination of anticorruption interventions; - Improvement of communication and capacity building of anti-corruption actors (information, communication and education).

Important activity with a verifiable deliverable Agenda Start Closure 1. Advocate for the revision of Law n°2012-30 of 28 December 2012 on the creation and organization of OFNAC and its implementing decrees. January 2022 December 2023 2. Advocate for the adoption of an anti-corruption law, including the protection of whistleblowers, whistleblowers, victims and witnesses of corruption January 2022 December 2023 3. Advocate for the revision of the law n° 2014-17 of 2 April 2014 on the declaration of assets January 2022 December 2023 4. Disseminate the national anti-corruption strategy and draft laws January 2022 December 2023

IRM Midterm Status Summary

Action Plan Review

Commitment 3: Strengthening the powers of the National Office against Fraud and Corruption (OFNAC)

  • Verifiable: Yes
  • Does it have an open government lens? Yes
  • Potential for results: Substantial
  • For a complete description of commitment 3, see the action plan:

    Context and objectives

    This commitment aims to facilitate government and civil society collaboration to strengthen Senegal's legal and institutional anti-corruption framework. Specifically, milestones promise to advance reforms called for under Senegal's 2020-2024 national anti-corruption strategy (Stratégie Nationale de Lutte Contre la Corruption, SNLCC) [19] and to strengthen the enforcement powers of the National Office against Fraud and Corruption (OFNAC). As called for under Axis 1 of the national anti-corruption strategy, [20] this commitment seeks to strengthen the anti-corruption legal framework “with all concerned stakeholders, including civil society and the private sector, in a process of broad consultation based on studies and exchanges.” [21]

    This commitment undertakes to reinforce the powers of the National Office against Fraud and Corruption (OFNAC) by reviewing and upgrading its foundational legislation and decrees. OFNAC, established in 2012, investigates corruption cases and receives public officials' asset declarations as part of its mandate. However, OFNAC currently lacks the ability to follow-up on corruption cases after their referral to judicial authorities. Additionally, public official's compliance with asset declaration remains low, and non-compliant officials are unsanctioned. Milestones 1 and 3 of this commitment aim to address these obstacles to OFNAC's anti-corruption efforts.

    This commitment will be carried out by OFNAC and civil society association Forum Civil, and is supported by the National Assembly, the Presidency, the Ministries of Finance, Justice and Economy, control bodies, and local authorities.

    Potential for results: Substantial

    Corruption continues to impede Senegal's political and economic progress. In 2021, Senegal scored 43 out of 100 points in Transparency International's Corruption Perceptions Index, ranking the country 73rd out of 180 countries evaluated. [22] This commitment addresses the vital national issue of fighting corruption, as acknowledged by CSO African Governance Institute [23], and is supported by international agencies and development partners. [24]

    The 2020 national anti-corruption strategy aims to strengthen Senegal's legal and institutional anti-corruption tools. The strategy has three major axes: reform of the legal and institutional anti-corruption framework, improvement of anti-corruption actions and governance, improvement of communication and capacity building for actors involved in corruption prevention. The strategy is aligned with the government’s development framework of “Plan Sénégal Émergent” and receives support and funding from international partners. [25] Within these broader efforts, this commitment specifically aims to adapt or introduce legislation around OFNAC's operations and mandate (milestone 1), whistleblower, witness, and victim protection (milestone 2), and public officials' asset declarations (milestone 3).

    Ibrahima Fall, Permanent Secretary for OFNAC, stated that anti-corruption legislation would be reviewed and adopted under this commitment through a participatory approach. He clarified that a multidisciplinary committee, including civil society members, will draft the texts before their transmission to the ministerial and legislative circuit. However, Permanent Secretary Fall also noted that an internal government committee is already established to propose a draft bill to amend law 2012-30, establishing OFNAC. Moreover, a draft bill reforming the declaration of assets law (2014-17) was internally validated on October 27, 2021. Both texts will undergo a final internal reading before entering the administrative circuit. [26] Therefore, this commitment's potential to contribute to substantial open government results partly depends on whether the drafting process for such legislation is meaningfully opened to civil society and public input.

    The commitment proposes sanctions for non-compliance of asset declaration obligations, thus increasing accountability of public officials. The Permanent Secretary Fall anticipates that access to information on asset declarations also would improve as a result of the commitment. [27] Every year, OFNAC reports on the number of entry and exit declarations received, which remain low compared to the number of declarations that should be submitted. [28] If sanctions are established, “they will be a deterrent to anyone who attempts to commit the same offense while also contributing to the control of assets.” [29] Overall, “if follow-up is given to the investigation files sent to the competent judicial authorities and the declaration of assets is made effective for all subject persons, this will have an impact on good governance. Indeed, corruption will be repressed regularly through judicial decisions.” [30]

    In parallel to the above-mentioned legal reforms. OFNAC has also started to disseminate the national anti-corruption strategy in all regions of the country. This dissemination process will include the entire anti-corruption legal framework, when established. [31]

    While the milestones in the commitment text lack specificity, IRM research clarified that implementation of this commitment promises to strengthen civic participation in anti-corruption policymaking, through the creation of a multi-stakeholder committee to review and draft legislation. Moreover, the subsequent legislation can potentially strengthen government transparency and public accountability through greater protection for whistleblowers and asset declaration enforcement and disclosure. Provided that the resulting legislation is relevant and comprehensive, and if sanctions for non-compliance are adopted, the commitment could substantially enhance participation in anti-corruption policymaking and public accountability.

    Opportunities, challenges, and recommendations during implementation

    This commitment represents an opportunity for civil society to collaborate with the government to improve the anti-corruption legal framework. The African Governance Institute, an organization involved in the action plan, believes that the government is committed to the open government approach. [32] Including this pre-existing reform in the OGP action plan ensures support at the state’s highest level, and implementation can be informed by international best practices. [33]

    As for other commitments, stakeholders might face challenges in terms of securing political will, as the draft laws must be negotiated in parliament. Local elections in January 2022 offer the opportunity to seek anti-corruption allies among newly elected municipal leaders. Also, involvement of civil society organizations in the reform process must be clarified, as only Forum Civil is listed as stakeholder in the commitment text while a “framework of broad consultation” [34] is expected. Finally, it will be crucial to guarantee funding to implement and disseminate the updated anti-corruption framework.

    Senegal can look at several successful consultative approaches to strengthen institutional anti-corruption frameworks, such as the open and participatory drafting of the Croatian Anti-Corruption Strategy (2014). [35] Senegal can also look at Albania’s implementation of the law "On Protection of Whistleblowers" in its 2016 action plan. [36] For significant outcomes, the IRM recommends that the following criteria are met when implementing this commitment:

  • Establish opportunities for experts, civil society, and citizens to provide input on draft legislation and decrees that begin early and continue throughout the drafting process. Widely advertise opportunities to provide public input in advance and reach out with targeted invitations to facilitate broad consultation.
  • Provide procedural transparency by publishing draft legislation, multi-stakeholder meeting and consultation minutes, and information on how public input was incorporated into the final texts.
  • Build a coalition of anti-corruption champions in the administration, parliament, faith-based and community leaders, and among newly elected local representatives early on to facilitate passage and implementation of new and revised laws down the road.
  • Collaborate with civil society to ensure that sanctions are established in asset declaration legislation.
  • Undertake communication and awareness-raising activities through print, radio, and workshops across the country to build popular awareness and support for anti-corruption efforts.
  • [20] Axis 1 will be operationalized through “adoption of a special anti-corruption law taking into account all the mandatory provisions of the UNCAC, in particular strengthening of prevention mechanisms and repression (…)”. Updating the legal framework will include “generalizing codes of ethics, broadening the scope of asset declarations, taking into account conflicts of interest, integrating provisions to make prosecution compulsory in the event of referral to the judicial authorities of acts of corruption, extending OFNAC’s powers (…), protecting whistleblowers and witnesses” (SNLCC, p.53-54).
    [21] SNLCC, p.53.
    [22] Transparency International. Corruption Perceptions Index. 2021. Senegal.
    [23] Interview with Falilou Mbacke Cissé (Director General), Institut Africain de Gouvernance, 26 November 2021.
    [24] “In July 2021, the United Nations Office on Drugs and Crime (UNODC) supported the drafting of an asset declaration law in Senegal and held a follow-up workshop that raised awareness of the law among Parliamentarians”, Status of implementation of Conference resolutions 8/7, 8/8, 8/11, 8/12 and 8/14, on the prevention of corruption, Report of the Secretariat, Conference of the States Parties to the United Nations Convention against Corruption, 4 October 2021:
    [26] OFNAC written response to IRM researcher, 18 November 2021.
    [27] OFNAC written response to IRM researcher, 18 November 2021.
    [28]OFNAC’s activity report from 2018 (last one published on its website) mentions the following data: 865 people were considered active taxable persons in 2018. Among these, 41 entry declarations were registered and 30 exit declarations. As of December 31, 2018, 45 taxable persons had still not made their entry declaration and 96 exit declarations were expected. See
    [29] OFNAC written response to IRM researcher, 18 November 2021.
    [30] OFNAC written response to IRM researcher, 18 November 2021.
    [31] OFNAC written response to IRM researcher, 18 November 2021.
    [32] Interview with Falilou Mbacke Cissé (Director General), Institut Africain de Gouvernance, 26 November 2021.
    [33] Interview with Falilou Mbacke Cissé (Director General), Institut Africain de Gouvernance, 26 November 2021.
    [34] SNLCC, p.54.
    [36]Albania OGP National Action Plan 2016-18, Implementation of the Law "On Protection of Whistleblowers" Commitment:


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