By Toby McIntosh
The International Monetary Fund’s signature strategy to fight corruption is entering a critical final negotiating stage with Pakistan, but with Ghana, after a long gestation period, an agreement was reached on Oct. 10 .
Both countries have beeb engaged for many months with the IMF in a process that produces Governance Diagnostic Assessments. The assessments are a key IMF tool for assessing the severity of national corruption and identifying governance weaknesses and corruption vulnerabilities.
Sometimes controversial reform recommendations are made in the reports, which are prepared by IMF staffers at the request of governments. The assessment and action plans are discussed with governments. Media reports from Pakistan suggest strong government resistance to the recommendations.
Publication of the diagnostic report is voluntary although most governments agree to do so. The Ghana report will be issued “in the coming weeks,” according to an IMF statement. However, media accounts suggest that Pakistan officials oppose publication of the report.
Doing more governance diagnostics was endorsed by a top IMF official over a year ago, and it appears that the pace of assessments is just slightly higher. By EYE’s count, there are seven assessments in various stages. (See May 2024 EYE article, IMF to Expand ‘Governance Diagnostics,’ Engage in More Follow-Ups, Official Says.)
An assessment was began this year on Kenya. A report on Togo could be released later this year. Authorities in Malawi are still considering whether to release a 2024 report on their country. A report on Haiti was issued in April. Since EYE published this article, an IMF official wrote to say that Lebanon and Sierra Leone are also having diagnostics done.
Transparency International several months ago criticized the process. TI called for the governance assessments process to be more transparent and participation mandatory, with more attention to implementation.
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Conclusion of Process Can Get Sticky
The assessments in Ghana and Pakistan show that the going can get complicated after government officials see the preliminary assessments and the proposed action plans.
In Pakistan, a conclusion seemed close in August, but progress seemed to slacken after some of the potential reforms were leaked. Continuing disagreements about governance may have contributed to inconclusive financial assistance talks that adjourned Oct. 8, though many other issues were involved.
Regarding Ghana’s assessment, IMF officials had predicting virtually all year that agreement was near. The announcement came in conjunction with a deal on IMF financial support.
In Kenya, the diagnostic process just got underway this year. An IMF team visited in late June. A draft report will be ready by the end of the year, according to the IMF. Also, Togo in July requested that an assessment be conducted, also with an end of the year completion target.
One diagnostic report was released in 2025, for Haiti, where prospects for implementation appear dim.
Overall, the IMF has concluded 22 diagnostic assessments since 2021, 15 of which have been made public, according to the IMF page on the program. Officially, assessments are begun at the invitation of country governments and publication of the report in voluntary. In recent years all the reports have been released.
Transparency International Criticizes Process
The Governance Diagnostic Assessments system was criticized in July by Transparency International.
TI wrote that “gaps remain in the process that risk GDAs falling short, as assessments remain voluntary…, limit the participation of civil society and have minimal accountability measures in place.”
“Transparency International is calling for stronger measures on anti-corruption and governance reform to be incorporated, including adjustments to how GDAs – and debt-sustainability assessments more broadly – are carried out and recommendations implemented,” said the blog post, which highlighted parallel assessments on governance issues done by TI and other civil society groups in Sri Lanka and Pakistan.
TI said the IMF “must embed governance and anticorruption criteria at the core of debt sustainability assessments.” TI said To ensure long term economic recovery, tools such as the governance diagnostics and Fiscal Transparency Evaluations “must become a mandatory and transparent practice for all countries in debt distress and negotiations.”
Defending the program, Julie Kozack, Director of the IMF Communications Department on July 3 told reporters, “Government diagnostic assessments allow our experts to go and do a deep assessment of governance in a country, look at where governance weaknesses exist, and to recommend a path forward to improve governance and reduce corruption over time.”
From a distance, EYE has followed the process in Ghana and Pakistan.
IMF, Ghana Agree on Governance Report
On Oct. 10, the IMF announced a staff-level agreement under which Ghana will gain access to $385 million.
As part of the announcement, the IMF said:
The authorities are committed to strengthening governance and public sector efficiency. The Governance Diagnostic Assessment report was completed and will be published in the coming weeks. Efforts to improve transparency and oversight need to continue, particularly in the management of SOEs in the gold, cocoa, and energy sectors.
SOEs are state-owned enterprises.
Ghana Process Drawn Out
Negotiations over the governance diagnostic for Ghana were delayed at the government’s request before the 2024 elections and puttered along after the election of a new government even though new President John Mahama stressed that fighting corruption is a top priority. (See article on his efforts in TRT Afrika.)
IMF officials have hinted all year that an agreement on anticorruption steps in Ghana was almost ready.
Back in February of 2025, a Bank spokesperson said a draft diagnostic was “in the process of being finalized.” He said, “The report aims to support the authorities’ efforts to address gaps in the country’s governance systems, promote the efficiency of public spending, enhance competitiveness, and lay the foundations for higher and more inclusive growth.”
By late August, the report seemed on the verge of publication. An IMF spokesperson on Aug. 27 told EYE, “The draft Governance Diagnostic report for Ghana has now incorporated formal comments from the new authorities. The finalized report will be transmitted to the authorities shortly, and we understand they intend to publish it immediately thereafter.”
Before the December 2024 election, the government of then-President Nana Addo Dankwa Akufo-Addo asked for work on the diagnostic to be suspended until after the election, sources told EYE.
Before that pause, finalization of Ghana’s diagnostic had been expected in the first quarter of 2024, the IMF said in a Nov. 23, 2023, press release at the conclusion of a 10-day IMF Technical Assistance mission in Accra.
In late 2024, the IMF has said one specific area where “the authorities have committed to strengthen the existing framework is the asset declaration system for public officials,” according to an IMF web page on Ghana dated Dec. 2, 2024. “Furthermore, the Ghana Revenue Authority, with support from IMF technical assistance, is developing a plan with the aim to improve the professional standards of tax administration in Ghana,” the IMF said.
Leaks of Pakistan Plan; No Conclusion Yet
Media reports in recent months have suggested that the Pakistani government is resisting some the IMF’s proposed anticorruption reforms.
However, on Oct. 8, the IMF said “significant progress” had been made toward reaching a staff level agreement on future IMF financial support. The statement on progress referred to a long list of items, including “strengthen governance and transparency.”
Media reports on the eve of the final of talks cited disagreements on governance issues. Dunya News said “differences persist.”
Details were sketchy. Some reporting suggested progress on asset disclosure by officials, improvements concerning of investigatory capacity and agreement on an awareness campaign to curb corruption and promote access to information. AAJ News and others said Pakistan had proposed setting up a task force to review its anti-corruption framework.
Significantly, whether the diagnostic report will be published may remain as a point of contention, several outlets said. Saama reported, “The IMF is reportedly insisting on the report’s publication and implementation, while the government has expressed reservations over timing and procedural transparency.”
Previous Reports on Disagreements
Headlines in Pakistan during August highlighted provisions in the IMF diagnostic objectionable to government officials,
Some of the leaked proposals were:
- An end to special treatment for parliamentarians’ development schemes Daily Times
- More timely and transparent budgeting processes Express Tribune
- A new authority for bureaucrats to declare their assets News
- Removal of the finance secretary from the central bank’s board The Press Trust of India
- Revoking the federal government’s authority to order inspections of commercial banks The Press Trust of India
The IMF report said that the identification of politically exposed persons remains uneven and there are insufficient corruption-specific red-flags to detect misuse of public office, according to a Tribune report.
A similar report in The News said the IMF “has recommended strengthening the operational effectiveness of National Accountability Bureau (NAB) and introducing further reforms to bolster Anti-Money Laundering (AML) legislation in Pakistan.” It continued, “However, the government plans to raise formal objections to the IMF’s draft report …, contending that several identified shortcomings in the technical report do not accurately reflect on-ground realities.”
IMF spokesperson said crisply, “The IMF doesn’t comment on leaked information. The Corruption and Governance Diagnostic Report for Pakistan has not been finalized. It will be published upon finalization.”
Work on the diagnostic was started early in 2025 with the expectation of a conclusion in August. IMF officials visited Pakistan several times this year to discuss the diagnostic’s terms. Also, during talks on financing, “The Fund’s team questioned the progress on addressing anti-money laundering coordination, particularly prioritization of risks emerging from trade-based money laundering,” according to an Oct. 1 Reuters report.
In early September, Pakistan government officials gathered to prepare a reply to the IMF’s prescriptions, the media reported. TechJuice wrote, “Participants reported dissatisfaction with draft findings on public finance management tax administration and anti-money laundering enforcement.”
In late September, Reuters reported that the IMF “has asked Pakistan to provide a detailed progress report on anti-money laundering measures as negotiations continue in the Finance Ministry for the release of the next tranche under the $7 billion loan program.” The IMF also sought updates on the establishment of provincial-level enforcement agencies to curb money laundering and corruption, Reuters said.
IMF Sent Signals Earlier This Year
Many of the IMF’s ideas on Pakistan should not have been a surprise.
On May 17 the IMF issued a lengthy document following a three-week IMF mission to Pakistan in late February and early March that said, “Accelerating structural reforms will unlock Pakistan’s competitiveness….” It goes on to mention “decisively strengthening governance and anticorruption institutions.”
What specifically needed to be strengthened was not detailed, but the report noted the pending governance diagnostic assessment. The target date of the end of July for publication of GDA was delayed, the IMF said, because of “operational delays related to the identification of a focal point.” This referred to who has been designated by the government to be the responsible official.
The May report also referenced some elements of governance reform, saying, “The authorities are working to enact legislation to publish asset declarations of high-level public officials, but additional time is needed owing to delays in the legislative process.” Reforms related to the mechanisms and safeguards for the Sovereign Wealth Fund (SWF) and state-owned enterprises are also mentioned,
The publication of GDA is at the discretion of the government and the IMF statement specified that “the authorities are also committed to publish their action plan to implement the GDA’s recommendations.”
A Civil Society Governance Diagnostic Assessment on Pakistan issued in July was based on the same rationale as the IMF governance diagnostics. “Pakistan’s economic problems are underpinned by governance issues,” begins the 76-page report. The effort was let by Transparency International chapter in Pakistan and involved a nationwide consultative process
There is “a broad consensus on the need for structural reforms to enhance transparency in fiscal governance, oversight, and public sector accountability,” according to the report, which detail many reform ideas.
It stresses that “the effectiveness of such diagnostics depends heavily on domestic political commitment.”
Togo Diagnostic Underway, Too
Togo has requested as Governance Diagnostic Assessment and there are signs of a potential disagreement over one reform standardly pushed by the IMF, disclosure of assets by public officials.
Togo’s request was noted in a July IMF report (Paragraph 35 in July Staff Report). The target date for publication of the report is the end of 2025.
“In the meantime,” the IMF report says, “the authorities have committed to amending the legal framework for public procurement to require the collection and publication of the names and nationalities of beneficial owners of companies awarded public contracts.”
Looking ahead, and hinting at some future tensions, the staff report says, “Staff also recommends that the authorities align the income and asset declaration regime for senior officials with best practice, including by requiring the publication of declarations.”
However, the report continues: “The authorities argue that this would expose declaring individuals to undue social pressure to share their wealth. In contrast, staff believe that strengthening asset and income declarations can be an important step towards enhancing the public’s trust and may at some point be needed to ensure support for revenue mobilization and fiscal consolidation.”
Malawi Diagnostic Done, But Unpublished
The IMF has completed a diagnostic in Malawi, but it has not been published.
An Aug. 6 IMF report mentions this very briefly, saying only that Malawi authorities “will consider publishing the 2024 Governance Diagnostic later in 2025.”
This suggests that the report was finished in 2024 and implies that Malawi is reluctant to issue the report.
Diagnostic on Haiti Notes ‘Fragility’
The diagnostic report for Haiti, dated January 2025 though released in April, includes 30 “Priority Recommendations” (Table 3 in Annex 5). Thirteen are labeled for action in the short term.
The assessment was requested by the authorities in May 2023 and supported by the current administration, the report says, so the process took two years. “The plan below is proposed bearing in mind Haiti’s fragility, limited resources and capacity constraints,” notes the report.
The report is substantially critical. A sampling:
A recurring concern with respect to anti-corruption and anti-money laundering efforts is their uneven enforcement. At the most basic level, key laws, regulations and standards are not enforced owing to a lack of independence from elite interferences, insufficient capacity and resources. The legal and institutional frameworks are inadequate to address the existing risks and vulnerabilities. Impunity has been the norm for some time and has gotten worse in the last few years.
