Monthly Archives: September 2013

Corruption Risk Assessment of the Ministry of Interior and National Security


Corruption – the abuse of entrusted power for private gain – is widely perceived to exist in Somalia where the UN has repeatedly reported on embezzlement of a grand scale.

To identify the root of the problem in Somalia’s federal government, marqaati has taken the initiative and carried out a corruption risk assessment of the federal government’s Ministry of Interior and National Security (MINS).

MINS was selected because it is in charge of the most important government bodies such as the police, internal security, and the directorate of immigration and naturalisation. It is therefore one of the largest ministries and identifying and combating corruption risk factors here is vital to the average citizen.

The aim of this study is twofold: first, to identify the processes and departments within MINS prone to corruption, and second, based upon that information, to design in the future projects to combat corruption within MINS and other ministries.


We adopted a risk assessment methodology developed by Project Against Corruption in Albania (PACA) in 2010 to suit the security limitations within which marqaati conducts its research.

Key ministry informants working in two different departments of the ministry and two other people who interact with the ministry regularly and whose role in the ministry can not be cited for security reasons because it could be used to identify them were selected for a panel discussion. During the discussion, a questionnaire consisting of 75 questions were asked by marqaati (see Appendix 1).  The panel discussed each question and from their discussion, a consensus was reached for each answer; all answers unknown to them are clearly indicated.

Of the 75 questions, 12 were unknown to them and 10 were not applicable, and are clearly marked as such. Therefore 53 questions were answered which gave a picture of the risks and incidences of corruption in MINS.

The relevant questions were answered which concerned the existence or lack thereof of anti-corruption policies, transparency, and accountability in MINS.

After risk factors were identified using the questionnaire, marqaati investigated specific cases of corruption. To this end, government financial records were analysed for impropriety (Appendix 2). Furthermore, additional key informants in another department were interviewed for verification purposes.


Verification of data was extremely difficult due to sources hesitating to confirm information out of fear of reprisals. Due to lack of confirmation, we have removed from this report many potential incidences of corruption. We shall however investigate them further in the future.

While some incidences may not be reported here, the list of risk factors identified is quite significant and warrants urgent action.

Corruption risk factors identified in MINS

  1. MINS does not have rules and regulations to deal with cases of potential corruption:
  1. No anti-corruption department
  2. No procedures to report internal cases of corruption
  3. No procedures for the public to report misconduct by ministry staff
  1. The existent internal inspection department, according to ministry staff, exists in name only and no inspections are actually taking place.
  2. Allegations by ministry staff of top ministry officials using ministry funds at personal discretion.
  3. The ministry shares very little information with the public, clouding its activities in secrecy. This makes risks of corruption high as few people know what is going on inside the ministry.
  4. Many of the staff are not aware of their job descriptions and have been appointed because they “know somebody” in top position.
  5. There is no complaints division to receive and deal with potentially significant numbers of public complaints given its exposure.
  6. The former Shabab rehabilitation programme and the Directorate of Immigration and Naturalisation (DIN) were identified as being the most vulnerable to corruption by ministry staff because of alleged funds misappropriation.
  7. Procurement procedures in the ministry do not involve open tenders.
  8. There are no known guidelines followed in hiring ministry staff.
  9. Officials are not required to declare their wealth before or after taking office.
  10. Financial records of MINS are kept a secret.
  11. No known existent code of conduct / ethics guide for ministerial staff.
  12. Inadequate training of staff; high frustration amongst staff due to alleged lack of appreciation by more senior officials.

Incidences of corruption in MINS

  1. There are no guidelines followed in hiring ministry staff . There appears to be a systematic abuse of this fact, which has led to the appointment of individuals with no experience or qualifications to important positions in the ministry. For instance, according to the key informants interviewed the minister’s cousin, Awil Wehliye has been appointed as a liaison officer to the UN and wields influence in the ministry due to his cousin being the minister. Likewise, directorship of key ministry departments have been given to friends of the minister such as Hussein Abdi Aden who is the director general of MINS and used to be a school teacher and old friend of the minister. Please contact us for a longer list of appointees with close relationship to the minister.
  2. Head of finances in MINS had withdrawn 23,500 US dollars from the central bank in one month of this year. This is not part of a 593,000 US dollars deposited in the MINS account by the central bank that month. The 23,500 USD withdrawn is confirmed by the key ministry informants to be for petty expenses which are released under the discretion the ministry’s head of finances.
  3. Upon preliminary investigation by marqaati of bank records, it was established that the Directorate of Immigration and Naturalisation within MINS was withdrawing money from the central bank and not depositing any, despite it making money from passport issuance. This indicates that the informants’ allegations of susceptibility to corruption are likely to be factual.


Risk of corruption at MINS is very high given the lack of transparency, financial discretion of top officials, and lack of an anti-corruption policy. Therefore, marqaati suggests the following:

  • Creation and empowerment of the independent anti-corruption commission stipulated in Article 111C of the provisional Somali constitution.
  • Creation of a working anti-corruption department in MINS and other ministries.
  • Giving ministry staff anti-corruption and ethics training to help deter corrupt practices.
  • Financial audits should be done across all ministries and their results made public. The Federal Parliament should pass a law mandating this.
  • Application of Article 32 of the provisional Somali constitution that stipulates that every person has a right to access information held by state. Furthermore, the Federal Parliament should amend and further clarify that article to strengthen transparency as stipulated in Schedule One (C) of the constitution.
  • Federal Parliament should pass a law mandating that officials taking office should disclose their financial status before and after leaving office.
  • All ministerial budgets, incomes, and expenditure data should be published online for present and future analysis.

We call on all concerned parties to work with us in making the above reforms to lower the risks of corruption in MINS and across the government.



Appendix 1

A. Organisational role


1. What are the core functions of the organisation (e.g. ministry, sub-unit within

ministry)? Ministry



2. Does the ministry have a ‘mission statement’ or similar description of its

function/role? Are staff aware of these? Do staff consider them accurate and

appropriate? Staff unaware of mission statement but say they have an idea of what their ministry is supposed to do.



3. Do the major sub-units of the ministry have ‘mission statements’ or a

clear definition of their function/role? Are staff aware of these? Do staff

consider them accurate and appropriate? Same as above.



4. Do all staff of the ministry have a clear job description/terms of reference

and are staff aware of this? No



B. Budget

5. What is the size of the ministry’s budget? Unknown


6. What is the rough breakdown of spending between salaries, investment,

purchases of goods and services and other types of spending? Unknown


7. What is the average size of a purchase/investment made by the ministry:

are there a significant number of very large purchases/investments in an

average year (or last year)? Unknown


8. What percentage of purchases/investment made by the ministry are put

out to open tender? None


9. How technically complex are the spending decisions made by the

ministry? Who takes the more complex decisions and on what basis? Financial decisions are made by the minister, the General Director, and the head of finance in the ministry. The minister sends people asking for money to the latter.



10. Are spending decisions on major items highly centralised (e.g. requiring the

signature of one senior official) or highly decentralised? Centralised



11. Are spending decisions on minor items highly centralised (e.g. requiring the

signature of one senior official) or highly decentralised? Decentralised



12. Does the organization receive income from the public, or designated clients

(taxation, customs levies, payments for services or rents etc.)  What is the

process for recording, banking and auditing these payments? In what form

are such payments received? The ministry receives payments from the public via the Directorate of Immigration and Naturalisation which issues passports. Payments are deposited into the Directorate’s bank account in Dahabshiil. This money is understand to be sizeable, and none of it has been found to be deposited into the central bank.

C. Human resources management

13. How many staff does the ministry employ? Unknown



14. How many of these are employed centrally (e.g. in a ministry), and how

many indirectly (e.g. public servants such as teachers)? Unknown


15. What percentage of the following categories (or equivalent categories) of your

staff have the status of civil servant, what proportion are currently within the

one-year probation period, and what percentage are employed on short-term


a. Secretary-General


b. Directors of departments or directors general


c. Directors of directorates or sector/office chiefs


d. Specialists




16. Is there any monitoring and statistics to show the rate of staff turnover within

the ministry. If so, what are the is turnover regarded by the ministry

as high, low, or about right? Yes; there is a high turnover of staff in the ministry.


17. Are there any internal recruitment guidelines in addition to the provisions of

the Law on Status of a Civil Servant? No


18. In what percentage of recruitments is the selection decision of the relevant

superior contrary to the recommendation of the ad hoc recruitment

committee, i.e. selects a candidate that was not one of those recommended? No such committee


19. Do recruitment procedures for staff in positions that might be regarded as

high-risk from a corruption point of view include criteria to attempt to ensure

the integrity of those appointed? No


20. Are applicants for staff positions questioned/screened to ensure they do not

engage in external activities or hold external interests that may conflict with

or impair the proper performance of their official duties? No


21. Do staff have a clear understanding of what situations constitute conflicts of

interest? No


22. Do new staff go through any induction process such as initial training? No


23. If so, does such training cover integrity issues? Is this repeated perhaps in

more specific ways on promotion or when staff move to new roles? N/A



24. Do staff regard their training as adequate to manage the situations that they

face? No


25. Who is designated as the person to whom staff should turn for advice. In

cases of uncertainty would they seek advice from other colleagues on an

informal basis before turning to their line manager, or seek advice elsewhere? Staff unaware of any such person.


26. Do staff feel that their salaries are adequate, just sufficient or insufficient to

ensure a reasonable standard of living? Just sufficient


27. To what extent do staff feel valued by (i) the organisation, ii) their direct

superior, in their role? They don’t feel valued by the ministry and their direct superiors.


D. Procedures and decision-making processes


28. Does the organisation do any of the following?

a. Issue or provide items such as licenses, permits, permissions,

certificates, passports or other documents to citizens or entities. Yes

b. Allocate any financial or other benefits to citizens (for example social

security benefits). No

c. Allocate any financial or other benefits to legal entities (for example

subsidies). No

d. Receive payments from members of the public (such as fees, taxes,

etc). Yes

29. Where it does so, are there clear procedures and clear criteria for the

provision of such items and/or receipt of payments? Unknown

30. Where can these procedures and criteria be found? Unknown

31. Where officials have to exercise discretion in the exercise of decisions on such

items, are there clear guidelines on how they should exercise that discretion

(e.g. that it should serve a particular objective)? No

32. If the organisation does not make a decision on items that are the subject of an

application period (e.g. for a license or permission) within the deadline

defined, is the issue automatically resolved to the benefit of the citizen/entity? No

33. Is the procedure for provision of such items organised in such as to minimise

the number of contacts citizens need to have with the organisation or other

organisations (one-stop shop). Yes

34. Are there multiple locations at which such items may be secured (e.g.

different branches of the same institution, post office, etc) or does one office

have a monopoly? One


E. Record-keeping


35. Does the ministry have clear rules for the management of records and

files? None known to staff.


36. Are individual decisions of the ministry recorded and filed according to

clear rules and for a clearly defined and binding minimum period? Some, yes.


37. Who has access to these files, who is authorised to amend them or review

them? No one in particular.


38. What degree of freedom of information exists with respect to the institution’s

files and documentation, both in terms of which decisions/files/documents

are made public automatically (and how), and which ones are available on

request? To what extent is such access guaranteed in practice? Under the pretence of national security, very little information is available publicly and given upon request.


F. Transparency

39. Does the ministry have a formal policy or rules on the automatic

dissemination of information? No Does this include automatic provision on the

website of the following?:

a. Organisational structure of Ministry and contact persons No

b. Ministry policies and policy documents No

c. Laws and sub-legal acts No

d. Draft laws and regulations No

e. Procedures of relevance to citizens and legal entities, such as for

applications for items mentioned in Section D. No

G. Access to information

40. Does the ministry have an official clearly designated to process and

respond to requests for information filed under the Law on Right to

Information on Official Documents? No

41. How many requests were filed last year? N/A

42. How many requests were refused or are currently in dispute? N/A

H. Ethics and integrity framework

43. Does the ministry have its own specific code of conduct or code of ethics? If it does, staff are unaware of it.

44. Are staff informed about the existence of the Code when assuming their

position? No

45. How often do staff receive training on ethics? Some do, some don’t: not more than once for those that do

46. Are staff familiar with the Code? What steps are taken to ensure this? No, none


47. Are there, either in such a code, or in guidelines or other regulations or staff

rules, provisions that instruct staff how to proceed in situations where they

find themselves subject to a conflict of interests? No

I. Accountability mechanisms

48. Do staff members have clearly-defined work procedures and routines for

reporting to superiors – either on a periodic basis (e.g. weekly staff meeting)

and on particular decisions or activities? No

49. Is there an internal inspection or control department? Yes, but it has been assessed to not function.

50. Approximately how many inspections/controls did the department carry out

last year? Unknown

51. Is there an internal audit department? Yes, though ministry informants say it doesn’t do its job.

52. What were the most important findings of the department last year? Unknown

53. How often is the ministry assessed by an external inspectorate or control

body? None in the past year

54. How often is the ministry audited by an external audit body? None in the last year

55. Were there any important findings on the ministry by such external

bodies last year (or at the last assessment)? N/A

J. Internal notification of ethics breaches

56. Is there a formal procedure by which staff members may notify a designated

official or unit of the ministry of suspected breaches of integrity or

contravention of the code of conduct within the ministry? No

57. Where the designated official is also the official that is the subject of the

complaint, is there an alternative channel by which staff may file complaints –

e.g. to an external organisation or to a higher superior? No

58. Are staff informed through training of these procedures and the official/unit

to whom they should file complaints? No

59. Are there any mechanisms in place to protect those who file such notifications

form retaliation? No

60. How many cases of such notifications by staff have there been in the last 12

months, and what was the outcome of these notifications for both sides

involved (the official notifying, and the subject of the notification)? None

K. Complaints mechanisms

61. Are there clear procedures by which citizens may file complaints against

actions of the ministry or its officials? No

62. Where can these procedures be found? N/A

63. Are decisions on complaints taken by the same person or unit in the

ministry at which the complaint was directed? N/A

64. How many complaints did the ministry receive last year? Unknown

65. How many complaints were upheld as well-founded? Unknown

L. Disciplinary procedures and sanctions

66. How many disciplinary proceedings were conducted against staff of the

ministry last year in connection with breaches of ethics rules? None

67. How many of these proceedings resulted in sanctions being applied? N/A

68. What was the breakdown in sanctions applied (number of cases for each type

of sanction)? N/A

M. Vulnerable areas

69. Can you identify which areas of your ministry or its activities are most

vulnerable to misconduct? Rehabilitation, Directorate of immigration, office of the director general of MINS

70. Has a risk analysis been conducted on your ministry to identify areas

vulnerable to misconduct? No

71. Does your ministry’s Anti-corruption Action Plan contain specific

measures to tackle these vulnerabilities? No such plan in the ministry

N. Anti-corruption policies

72. Who in your ministry has formal and specific responsibility for

development, implementation, monitoring and coordination of anticorruption

policy? No one

73. Is this responsibility stated in that staff member’s job description (see

Question 4)? N/A

74. Is there a working group within the ministry tasked with formulation,

coordination, monitoring and reporting on anti-corruption policy? No

75. How often does the working group meet? N/A

Appendix 2

Bank records. Contact us if interested in seeing them. All queries will be judged on a case-by-case basis.