Report to Congress: MCC’s Approach to Confronting Corruption
Corruption fundamentally undermines economic growth, which is why the Millennium Challenge Corporation (MCC) directly addresses corruption when choosing partner countries and when developing and implementing programs. Corruption is challenging and multifaceted, and there is no single, simple action to deal appropriately and practically with all aspects of corruption. This report to Congress updates MCC’s overall three-part approach to confronting corruption:
- Country eligibility decisions – MCC uses its Control of Corruption indicator as a key measurement for eligibility; MCC also assesses any fraud and corruption allegations from a previous compact when considering a country for a subsequent compact;
- Program implementation – MCC establishes a range of controls to prevent, detect, and mitigate against fraud and corruption during the course of program implementation. In instances where corruption is identified as a major constraint to economic growth, Compact programming has also been designed to address efficiency and corruption issues within our partner countries; and
- Continued monitoring – MCC regularly monitors corruption issues as a matter affecting country eligibility during the course of program implementation.
Since 2012, MCC’s approach to monitoring and responding to corruption issues has evolved further, as outlined in this revised report. MCC’s updated thinking on the Control of Corruption indicator, governance indicators more broadly, the role of the threshold program in fighting corruption, and the role a government’s anti-fraud and corruption actions play in subsequent compact decisions are all featured in Section I. Section II is updated to reflect advances made in anti-fraud and corruption controls in program implementation since 2012. Finally, section III reflects MCC’s progress in responding to concerns about corruption in our partner countries, updating the Suspension and Termination Policy, and further consulting with experts in the field of measuring and monitoring corruption.
Considering Corruption when Making Country Eligibility Decisions
MCC’s mandate is to work with relatively well-governed, poor countries. In order to assess countries that are relatively well-governed, MCC creates annual scorecards that use objective and quantifiable policy indicators in three broad policy categories: Ruling Justly, Investing in People, and Encouraging Economic Freedom. These policy indicators are developed by independent third-party institutions, which rely almost exclusively on objective and publicly available data, and have an analytically rigorous methodology. The Control of Corruption indicator is a “hard hurdle” to MCC eligibility. Countries must be in the top half of their income group on the corruption indicator to pass the scorecard, which places an assessment of anti-corruption efforts at the center of MCC’s eligibility decision-making process.
The inclusion of the Control of Corruption indicator as a hard hurdle is tied directly to MCC’s mission to pursue economic growth and poverty reduction. Economics literature shows the importance of controlling corruption for economic growth and poverty reduction. Corruption hinders economic growth by increasing costs, lowering productivity, discouraging investment, and reducing confidence in public institutions. It can limit the development of small- and medium-sized enterprises, weaken systems of public financial management, and undermine investments in health and education. 1 Corruption also can increase poverty by slowing economic growth, skewing government expenditure in favor of the rich and well-connected, and concentrating public investment in unproductive projects. Corruption can result in public officials promoting a more regressive tax system, siphoning funds away from essential public services, adding a higher level of risk to the investment decisions of low-income individuals, and reinforcing patterns of unequal asset ownership, thereby limiting the ability of the poor to borrow and increase their income. 2
To assess country performance on controlling corruption, MCC uses the Worldwide Governance Indicators’ 3 Control of Corruption indicator on its scorecard. This indicator, produced annually by Brookings and the World Bank, measures the extent to which public power is exercised for private gain (including both petty and grand forms of corruption), as well as capture of the state by elites and private interests. It also measures the strength and effectiveness of a country’s policy and institutional framework to prevent and combat corruption. 4
MCC also uses supplementary information to assess levels, trends, and instances of corruption, including quantitative and qualitative data and reports from third-party experts; surveys on corruption; interagency information and reporting; and other flows of reliable information from nongovernmental organizations and technical experts at other donor agencies. An illustrative list of the types of supplementary data and reports MCC uses when assessing countries for eligibility and monitoring their performance over time can be found in Section III of this report.
MCC’s use of the Control of Corruption indicator can incentivize reform.
Along with helping MCC identify countries with lower levels of corruption, the Control of Corruption indicator also appears to incentivize some governments to pursue reform efforts. In order to improve performance on MCC’s scorecard - and the Control of Corruption indicator, specifically - several governments have engaged with MCC staff, reached out to indicator institutions that measure and monitor corruption, drafted plans for policy reforms, and taken tangible steps to try to address corruption in their countries.
In fact, in a 2013 paper entitled “Measuring the Policy Influence of the Millennium Challenge Corporation: A Survey-Based Approach,” academics at William and Mary College asked 640 development experts whether domestic authorities in their country had ever undertaken “specific policy adjustments or reform to improve performance on [the Control of Corruption] indicator?” Respondents from 57 countries stated they were aware of such actions by their governments. 5
While specific examples are not given for all 57 countries, several MCC candidate countries have been recognized by the media or NGOs for their specific actions to combat corruption, in part to improve on the Control of Corruption indicator. For example, in July 2013, the Economist highlighted actions by the government of Cote D’Ivoire’s Committee for MCC Eligibility to promote a public awareness campaign against corruption, while simultaneously drafting a new anti-corruption law. 6 In 2012, the government of Honduras was recognized by both the Open Budget Index and the Public Expenditure and Financial Accountability assessment for increasing its budget transparency. In 2008, the government of Sierra Leone strengthened its anti-corruption commission, which has subsequently indicted a number of government officials on corruption charges, as highlighted by the New York Times in April 2013. 7 While not all countries are incentivized by the Control of Corruption indicator, a growing body of research suggests that some countries are taking action to improve their scores.
Good governance is more than just Control of Corruption
While the WGI Control of Corruption indicator is quite comprehensive - covering everything from public perceptions, to firms’ experiences, to the strength of anti-corruption laws and institutions - there are important governance issues that fall outside of its’ boundaries. For example, the strength and impartiality of the legal system, security of private property rights, the enforceability of private and government contracts, and government compliance with the judicial system all fall within WGI’s Rule of Law indicator, which MCC also uses on its scorecard. Similarly, policy consistency – the extent to which government commitments are honored by new governments – falls within WGI’s Government Effectiveness indicator.
Although only Control of Corruption is used as a hard hurdle, all three of these indicators measure important elements of good governance, and all three contribute to the Board’s decision on whether to select a country for MCC assistance.
MCC uses its Threshold Program as a tool to improve policies and practices.
The objective of MCC’s Threshold Program is to assist a country in becoming compact eligible by supporting targeted policy and institutional reforms based on deeper diagnostic, feasibility, and cost-effectiveness analyses. These reforms are often related to control of corruption. A good example is Honduras, which was selected as eligible for MCC threshold program assistance in fiscal year 2012. The Honduras threshold program’s goal is to improve the efficiency and transparency of the Government of Honduras, which will be achieved by improving Honduras’ public financial management and the efficiency and transparency of public private partnerships. Program results will help to demonstrate if the Government of Honduras has the political will and capacity to carry out important reforms that are critical for combatting corruption and spurring faster economic growth.
MCC assesses Fraud and Corruption allegations from a previous Compact or Threshold Program when considering a country for a subsequent Compact
When the Board considers countries for subsequent compacts, one of the topics the Board considers is the country’s adherence to MCC standards in their previous compact, including the country’s capacity to manage compact implementation without unaddressed violations of MCC’s policies on fraud and corruption (see Section II for details on MCC’s Fraud and Corruption policies.) Similarly, when considering a country for an initial compact, the Board will consider MCC’s experience implementing a threshold program in that country, if applicable. In several cases the Board has decided not to select previous threshold partners for compact eligibility, in part due to insufficient political will in implementing corruption-related reforms or respond to fraud corruption allegations within the threshold program.
MCC Fraud and Corruption Controls
MCC safeguards against corruption in compact programs through multiple channels, including fiscal controls, procurement requirements, training for local Millennium Challenge Account (MCA) entities (the country unit implementing the MCC program), and referral of fraud and corruption allegations to the USAID Office of the Inspector General (OIG). MCC ensures that procurements are open, fair, and competitive through its Program Procurement Guidelines, expert review of procurement documents, and oversight of the procurement process, including review of selection methods, assessment of bidding documents, and bid evaluations. MCC’s approach to procurement, as well as its overall program management approach that creates efficiencies and minimizes fraud, has also been incorporated into broader government systems (e.g. Morocco) or retained in the continuation of the MCA as an operating unit (e.g. Honduras and Ghana). MCC has also engaged in efforts with the World Bank to improve procurements more broadly in a number of African countries by sharing best practices (e.g. provision of Ghana procurement project to Liberia with the World Bank).
On a quarterly basis, MCC approves fiscal accountability plans and reviews disbursement reports and requests, thereby supporting effective financial management and providing additional protection against fraud and corruption. Where MCC assesses local country systems to be insufficiently qualified, open, and transparent, MCAs use external procurement agents and fiscal agents who are hired through an international procurement process. Most MCA invoices are paid from the United States, removing the need to have sizeable bank accounts in recipient countries. The in-country “Permitted Accounts” that are used to pay the remaining expenses are kept separate from host-country finances and have strict controls on payment approvals, allowing transparency and accountability by avoiding co-mingling of funds and authorities. All MCAs are required to hire outside auditors, whose reports are reviewed by both MCC staff and USAID OIG. The permanent presence of MCC staff (expatriate and local) in resident country missions provides on-the-ground support to and oversight of compact activities procured and implemented by the MCAs. In addition, MCC technical staff, MCC-hired independent engineers, USAID OIG, and the U.S. Government Accountability Office, all provide oversight.
In 2009, MCC approved its Policy on Preventing, Detecting, and Remediating Corruption and Fraud in MCC Operations(Anti-Fraud and Corruption Policy). This policy includes actions that MCC has taken to enhance its capacity to prevent, detect, and remediate instances of fraud and corruption, including compact-specific fraud and corruption risk assessments. These assessments are developed to identify specific risks of fraud and corruption for each compact based on the unique projects, institutional, and country contexts. MCAs design action plans for controlling corruption, based on the risk assessments, which are approved and monitored by MCC. The Anti-Fraud and Corruption Policy also provides guidance to MCC and MCA staff on methods and strategies to prevent fraud and corruption. As part of the policy, MCC has clear and responsive mechanisms to respond to allegations of fraud or corruption in compacts. Administrative interventions or sanctions may occur if cases of fraud or corruption are detected.
As of September 2013, training on awareness and prevention of fraud and corruption has been provided in fourteen countries. Training is provided by a contractor or by MCC staff and consultants, and overseen by a senior anti-fraud and corruption advisor with years of relevant experience. As a result of this training, eight anti-fraud and corruption action plans have been completed by local MCAs, approved by MCC and the relevant MCA Boards of Directors, with the majority posted on MCA websites. Additional action plans are being developed and reviewed.
MCC has instituted an internal training program for all MCC staff involved in compact development or implementation. Training is delivered by a senior anti-fraud corruption advisor and an assistant general counsel, and covers the Anti-Fraud and Corruption Policy; the process of developing compact-specific fraud and corruption risk assessments; and the roles and responsibilities of MCC staff members in reporting potential cases of fraud and corruption. Training also includes several case studies that test understanding of the issues and generate discussion.
In 2009, MCC established an anti-fraud and corruption team (AFC Team) to intake and address allegations of fraud and corruption submitted to MCC. Allegations can be submitted confidentially through MCC’s website; by e-mail to members of the AFC Team; or directly to the USAID Office of Inspector General. The AFC Team is chaired by MCC’s senior investment and risk officer, who reports directly to MCC’s chief executive officer, and includes an assistant general counsel and a representative from MCC’s department of administration and finance. MCC’s senior anti-fraud and corruption advisor also participates in meetings on a regular basis.
Allegations of fraud and corruption are reviewed and confidentially monitored by AFC Team members, who may confer with relevant MCC staff members in order to determine the specific nature of an allegation. The OIG is notified of all allegations, including those that are most likely to be flawed procurements. The AFC Team coordinates closely with USAID OIG on appropriate follow-up and meets regularly with OIG to discuss open allegations and to agree on when and under what circumstance allegations should be “closed.” In serious cases, OIG may determine that it wants to undertake an investigation of the allegation and may request that MCC take no action (to include not informing the relevant MCA about the allegation) pending an OIG investigation. With notice to the IG, MCC will take administrative action, such as canceling a procurement when time is of the essence and when MCC must exercise its fiduciary responsibility (e.g., minimize exposure of MCC funds to potential diversion or to prevent awarding a contract under questionable circumstances).
As of early September 2013, MCC had received over 120 allegations of fraud and corruption; approximately 40% of those pertained to procurement issues and a majority did not involve fraud and corruption. However, when warranted, MCA staff members have been terminated and at least one person has been arrested in connection with information collected by OIG and/or MCC.
Monitoring Corruption with Partner Countries
MCC assesses corruption when determining country eligibility, and then continues to regularly monitor corruption within partner countries, as well as respond to stakeholders’ specific corruption concerns. MCC monitors policy performance for all partner countries on an ongoing basis, and on an annual basis provides an update on policy performance for all partner countries to MCC’s Board of Directors (Board). Specific events (high profile cases of corruption, a sudden change in policies or practices related to corruption, or sudden shifts in indicator scores) may trigger more intensive investigations and result in additional updates to interagency representatives and the Board.
When assessing levels, trends, and instances of corruption, MCC uses quantitative and qualitative data and reports from third party experts; surveys on corruption (population and firm surveys); interagency information and reporting; and other flows of reliable information (including nongovernmental organizations and technical experts at other donor agencies).
MCC uses data from government assessments, commercial business information providers, and nongovernmental organizations to assess corruption issues, including: (i) the existence and utilization of anti-corruption laws and institutions; (ii) levels of bureaucratic regulations that create opportunities for corruption; (iii) the presence of active auditing and investigative bodies; (iv) prosecution of corrupt officials; (v) legal protection of whistleblowers; (vi) active anti-corruption civil society groups; and (vii) the business costs of corruption. Data and reports utilized by MCC come from (when available):
- African Development Bank Country Policy and Institutional Assessments
- Asian Development Bank Country Policy and Institutional Assessments
- Bertelsmann Transformation Index
- Freedom House Countries at the Crossroads
- Global Insight Global Risk Service
- European Bank for Reconstruction and Development Transition Report
- Economist Intelligence Unit Risk-wire & Democracy Index
- Freedom House
- World Economic Forum Global Competitiveness Report
- Global Integrity Index
- Heritage Foundation Index of Economic Freedom
- Cingranelli Richards Human Rights Database and Political Terror Scale
- IFAD Rural Sector Performance Assessments
- iJET Country Security Risk Ratings
- Institutional Profiles Database
- African Electoral Index
- International Research and Exchanges Board Media Sustainability Index
- International Budget Project Open Budget Index
- World Bank Country Policy and Institutional Assessments
- Political Risk Services International Country Risk Guide
- Reporters Without Borders Press Freedom Index
- U.S. State Department Trafficking in Persons report
- Global Insight Business Conditions and Risk Indicators
- U.S. Government Excluded Parties List System (EPLS)
MCC also uses population surveys and surveys of firms that aim to measure topics, including public trust in the financial honesty of politicians; public perceptions of corruption; frequency of bribery by firms; and frequency of corruption among specific public institutions (political parties, legislature, media, the military, education system, legal system, utilities, tax revenue, police, medical services, customs, public officials, etc.). Surveys utilized by MCC include (when available):
- Business Enterprise Environment Survey
- Gallup World Poll
- Institute for Management and Development World Competitiveness Yearbook
- Political Economic Risk Consultancy Corruption in Asia Survey
- Transparency International Global Corruption Barometer Survey
- Vanderbilt University Americas Barometer
- World Economic Forum Global Competitiveness Report
In addition, MCC uses interagency supplemental information and reporting, including from the State Department, USAID, Treasury, and other USG agencies. MCC also may consult with other donors, experts at nongovernmental organizations, academia, and MCA counterparts.
Improving capacity to identify and track patterns of corruption.
Corruption is, by its nature, difficult to measure. MCC’s Control of Corruption indicator aggregates across data to allow cross-national comparisons that identify the extremely good and extremely poor performers. While this is the function MCC needs the Control of Corruption indicator to perform, an indicator of this type is limited in its ability to track specific year-on-year changes, or to be objectively verified by third parties.
By looking at the individual components of the Control of Corruption index, MCC is able to draft “Indicator Analyses,” which give more detailed snapshots of the status of corruption in countries. These indicator analyses can highlight what individual institutions perceive as year-on-year changes, but they are still limited in their ability to demonstrate clear trends in corruption.
Certain second-generation governance indicators – such as the reports produced by Global Integrity or the Open Budget Index – provide more details on specific, objectively verifiable practices or policies in a country. These types of indicators do not measure corruption per se, but rather provide a snapshot of the function of “accountability institutions” in a country that are intended to help fight corruption. The reports and scores for countries on each of these surveys not only track changes over time, but the transparent methodologies enable third parties to understand what specific policy or implementation changes have led to a different scoring.
MCC makes use of these data whenever they are available. Because most actionable governance indicators cover only a limited number of countries, MCC has been encouraging experts in governance to expand the coverage of these indicators. Consistent, iterated and specific measures of performers the function of institutions of accountability would strengthen MCC’s ability to identify or track patterns of corruption.
MCC has already begun making selective use of these types of indicators in assessing specific anti-corruption projects. For example, prompted by concerns about corruption levels and trends in Honduras, MCC used data from the Open Budget Index and the World Bank’s Public Expenditure and Financial Accountability framework to assess the Government of Honduras’s efforts to make its budget process more transparent and accountable. We are hopeful that these types of data will also prompt new thinking and research by experts in the field. MCC has committed to continuing its public consultations with governance experts on this issue.
If improving the capacity of the indicator sources used by MCC is a priority, the U.S. Government could support this type of measure by increasing funding, raising awareness, and encouraging private sources to support this research.
MCC process to determine if level of corruption warrants termination or suspension.
Most countries selected as eligible for MCC funding demonstrate sustained levels of commitment throughout the duration of partnership with MCC. However, when concerns about corruption arise, MCC determines what constitutes a corruption-related “pattern of action” that warrants MCC response, suspension, or termination. MCC’s approach to determine a pattern of action is based on consultations with academic and civil society experts (including Transparency International, Global Integrity, and Freedom House) to identify issues and to determine if the corruption environment has deteriorated substantially. There was not a pre-existing consensus among development practitioners or in the academic literature on this topic. We asked experts to help us identify the appropriate issues to watch, when trying to determine if the corruption environment has deteriorated substantially. Based on this expert feedback, MCC follows an approach to monitoring corruption that is in keeping with the agency’s eligibility criteria and Suspension and Termination policy. When reviewing whether allegations of corruption suggest a pattern of actions contrary to MCC’s eligibility criteria, MCC makes a distinction between two types of corruption:
- Incidents of opportunistic corruption driven by individual actors or groups. This is more likely to represent the actions of individuals, rather than a coordinated government effort. MCC is concerned by these instances, but does not believe that they necessarily represent a fundamental change in levels of corruption in a country.
Government led efforts to undermine institutions of accountability such as courts, anti-corruption commissions, auditors, or the media. This represents an effort to alter a country’s institutional structure in a way that makes individual instances of corruption more likely, enables corruption to flourish, and cultivates a culture of impunity, and is the type of scenario that could contribute to a pattern of actions warranting MCC response, suspension, or termination.
An example of MCC’s response to the latter type of corruption could be found in Senegal in 2012. Although Senegal has traditionally performed well on the Control of Corruption indicator and has relatively strong anti-corruption policies and institutions, MCC became concerned when then President Wade issued a decree to alter Senegal’s procurement code, in order to exclude certain government-issued procurements from independent regulation and audit. This proposed change to the very policies and institutions designed to control corruption in Senegal raised a red flag for MCC. Working with colleagues throughout the US Government and the greater donor community, MCC took part in a dialogue with the government of Senegal to express concern about the proposal and implications on corruption. The decree was subsequently repealed.
As the above example illustrates, if a partner country’s commitment to controlling corruption appears to deteriorate, MCC has several leverage tools. These include public or private warnings to the government; a policy improvement process where MCC staff work with representatives of the government to design, implement, and evaluate actionable steps to improve policy performance; and operational adjustments to implementation in cases of fraud or corruption within MCC programs. In extreme cases, MCC can implement its Suspension and Termination Policy.
Because of the nature of MCC’s investments and the limited timelines on which programs operate, suspending or delaying funds is a serious and often irreversible step. Suspension is governed by MCC’s policy on Suspension and Termination. This policy and MCC’s authorizing statute, provide the right to act, not in the face of individual events, but based on evidence of a “pattern of actions” that represents a decline in the policy areas captured by MCC’s scorecard. A decision to suspend or terminate is ultimately taken by MCC’s Board. 8
In 2013, MCC updated its policy on Suspension and Termination. The 2013 revision was an opportunity to update the language and affirm some of the sound practices that have contributed to MCC’s credibility. Revising the policy allowed MCC and its Board of Directors to engage on the process MCC uses to inform a CEO recommendation to suspend or terminate, as well as ensuring MCC provides the full range of information the Board needs to make a fully briefed decision. The Board voted to approve the updated policy in March 2013.
At the time of writing, MCC’s Board has taken action under this policy in ten instances, 9 all of which related to democratic backsliding, human rights violations, or coups. While much of what MCC’s Board has found to merit a suspension or termination has been directly related to electoral processes or lack thereof, MCC recognizes that accountable governance goes well beyond the transparent and peaceful transfer of elected office.
In the coming year, MCC will further engage experts in the still-nascent fields of measuring and monitoring corruption. Because concerns about corruption are often intertwined with questions about rule of law, MCC sees two specific paths for further progress.
- Understanding the real-time warning signs of a meaningful change in the state’s tolerance of corruption.
- Articulating an MCC approach to considering citizen security for countries, or regions, where crime, corruption, and human rights intersect.
From engaging with the Center on Global Development on the strengths and weaknesses of specific corruption indicators, to brainstorming with Global Integrity on how to fill gaps in the field of measuring governance, to working with Freedom House to ensure our monitoring of corruption remains as robust as possible, MCC remains committed to incorporating the best possible thinking and tools into its eligibility models.
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- 2. ii Gupta, Sanjeev, Hamid R. Davoodi, and Rosa Alonso–Terme. 2002. Does Corruption Affect Income Inequality and Poverty? Economics of Governance 3: 23–45. Ravallion, M., and S. Chen. 1997. What Can New Survey Data Tell Us About Recent Changes in Distribution and Poverty? World Bank Economic Review 11(2): 357–382Gupta, Sanjeev, Hamid R. Davoodi, and Erwin R. Tiongson. 2001. “Corruption and the Provision of Health Care and Education Services,” in The Political Economy of Corruption, edited by Arvind K. Jain. London: Routledge. Mauro, P. 1998. Corruption and the Composition of Government Expenditure. Journal of Public Economics 69: 263–279. Rajkumar, A.S. and V. Swaroop. 2002: Public Spending and Outcomes: Does. Governance Matter? World Bank Policy Research Working Paper 2840. Anderson, James, Daniel Kaufmann, Francesca Recanatini. 2003. Service Delivery, Poverty and Corruption—Common Threads from Diagnostic Surveys. Background paper for 2004 World Development Report. Washington DC: World Bank. Olken, Benjamin. 2006. Corruption and the Costs of Redistribution: Micro Evidence from Indonesia. Journal of Public Economics 90 (4–5): 853–870.
- 3. The Worldwide Governance Indicators is an aggregate index combining up to 21 different assessments and surveys, depending on availability. The Control of Corruption indicator draws on data, as applicable and available, from the Country Policy and Institutional Assessments of the World Bank, the Asian Development Bank and the African Development Bank, the Afrobarometer Survey, the World Bank’s Business Environment and Enterprise Performance Survey, the Bertelsmann Foundation’s Bertelsmann Transformation Index, Freedom House’s Nations in Transit and Countries at the Crossroads reports, Global Insight’s Business Conditions and Risk Indicators, the Economist Intelligence Unit’s Country Risk Service, Transparency International’s Global Corruption Barometer survey, the World Economic Forum’s Global Competitiveness Report, Global Integrity’s Global Integrity Index, the Gallup World Poll, the International Fund for Agricultural Development’s Rural Sector Performance Assessments, the French Government’s Institutional Profiles Database, the Latinobarometro Survey, Political Economic Risk Consultancy’s Corruption in Asia, Political Risk Service’s International Country Risk Guide, Vanderbilt University Americas Barometer Survey, the Institute for Management and Development’s World Competitiveness Yearbook.
- 4. For a detailed discussion of the methodology employed for this indicator, please see http://www.brookings.edu/opinions/2010/0924_wgi_kaufmann.aspx.
- 5. Parks, B. and Rice, Z. 2013. Measuring the Policy Influence of the Millennium Challenge Corporation: A Survey-Based Approach. The Institute of Theory and Practice of International Relations: The College of William and Mary.
- 6. The Economist. (2013, July.) Billboards Against Corruption.http://www.economist.com/blogs/baobab/2013/07/c-te-d-ivoire
- 7. Nossiter, Adam. (2013, April.) Sierra Leone’s Health Care System Becomes a Cautionary Tale for Donors. New York Times. http://www.nytimes.com/2013/04/14/world/africa/sierra-leone-graft-charges-imperil-care-and-aid.html?pagewanted=all&_r=0
- 8. MCC’s Board is chaired by the Secretary of State and includes the Treasury Secretary, U.S. Trade Representative, USAID Administrator, MCC’s CEO, and four non-government members.
- 9. In chronological order: Yemen 2005, Gambia 2006, Mauritania 2008, Madagascar 2009, Nicaragua 2009, Armenia 2009, Niger 2009, Honduras 2010, Mali 2012, and Malawi 2012. Under this same policy, Malawi and Niger were subsequently reinstated by the MCC Board after each country took tangible corrective actions to address the pattern of actions for which they were suspended.