When the IMF provides a loan to a country, a due diligence
exercise is carried out to obtain assurances that the country’s
central bank receiving IMF resources is able to adequately manage
the funds, and provide reliable information. Experience with these
“safeguards assessments”, since they were introduced in 2000, has
shown a positive impact for many central banks through strengthened
governance, control, and reporting mechanisms.
Protecting IMF resources ensures future availability to other members
Under its
Articles of Agreement, the IMF must establish “adequate safeguards”
for the use of its
resources. This is to ensure that
loans to member countries are repaid as they fall due so those
resources become available to other members in need. Types of safeguards
include
limits on how much can be borrowed,
conditions on the loans, measures to deal with misreporting or
arrears, or “safeguards assessments” of central banks.
The “safeguards assessment”
A safeguards assessment is a diagnostic review of a central bank’s
governance and control framework. Five key areas—denoted by the acronym
ELRIC—are assessed to help safeguard IMF disbursements and minimize the
risk of inaccurate reporting of key data to the IMF (“misreporting”) for
as long as a country has IMF credit outstanding. Emphasis is placed on
the effectiveness of the central bank’s governance across all ELRIC
areas.
External audit mechanism: The publication of central
bank annual financial statements that are independently audited in
accordance with internationally accepted audit standards is a key
requirement under the safeguards policy. Assessments look at the process
for the selection and rotation of external auditors, their compliance
with international standards, and whether the audited financial
statements are published annually.
Legal structure and autonomy: Government
interference can undermine a central bank’s autonomy and increase the
risks in its operations. Assessments therefore focus on laws and
regulations affecting autonomy, transparency and governance at the
central bank as well as actual practices in these areas. They also
ascertain whether the legal framework supports the other four ELRIC
pillars.
Financial reporting: Safeguards assessments evaluate
whether the central bank adheres to international good practices for
transparent financial accounting and reporting so that accounting
systems provide reliable and timely information. Assessments also focus
on the consistency between published financial information and central
bank monetary data that are sourced from the accounting system.
Internal audit mechanism: The internal audit
function helps the central bank to evaluate and improve the
effectiveness of risk management, control, and governance processes. The
IMF assesses whether the internal audit function is effective, and
whether the central bank has sufficient staff resources and
organizational independence to fulfill its mandate. Assessments also
review compliance of the internal audit function with international
standards.
System of internal controls: Sound policies and
procedures, including effective risk management, are necessary to
safeguard assets, and ensure the accuracy and completeness of accounting
records and information. Assessments review the quality of oversight of
external and internal audits, as well as controls over banking,
accounting, and foreign exchange operations. Particular attention is
paid to reserves management functions and controls over data reported to
the IMF.
Assessments involve several steps
Central banks provide information—including
financial statements, internal and external audit reports, and summaries
of central bank controls—to the IMF on the above five areas. IMF staff
review this documentation, and hold discussions with the bank’s staff
and external auditors; many assessments also include a visit to the
central bank. A safeguards report is produced that includes
recommendations to address indentified vulnerabilities, and key
recommendations may become part of
program benchmarks.
Where IMF lending is provided as direct budgetary support,
assessments look for a clear framework between the central bank and the
government for repaying IMF lending so that their respective roles and
obligations are transparent and well understood.
Country authorities have the opportunity to comment
on the report before it is finalized.
Safeguards assessment reports are confidential documents and the IMF
Executive Board is informed of the findings and recommendations in
summary form in country reports. Safeguards reports may be shared with
the World Bank and, where relevant, the European Central Bank on a
confidential basis, but only with the written consent of the central
bank in question and subject to strict distribution controls. Formal
confidential briefings can be provided to donors, if requested, with the
consent of the central bank. The Board is also provided annual activity
reports that include findings, issues, and corrective actions taken.
IMF staff monitor the implementation of safeguards
recommendations and developments in central banks’ safeguards
frameworks, for as long as IMF credit is outstanding. Safeguards
assessments are conducted for each new loan request.
Flexible Credit Line (FCL) arrangements, however, are exempt because
of the rigorous requirements that must be met to qualify for an FCL, and
safeguard procedures are therefore limited to a review of the most
recently completed audit of the central bank. Members may also request a
voluntary assessment where there is a non-financial arrangement with the
IMF.
Assessments complement other IMF work
The
safeguards assessments policy was introduced in March 2000, in the
wake of instances of misreporting and allegations of misuse of IMF
resources. It is now an integral part of the IMF’s lending activities,
with 244 assessments having been
completed to date. The policy was last
reviewed in July 2010.
Safeguards assessments are conducted independently from other IMF
activities such as
surveillance, program discussions, and
technical assistance. They are distinct from other IMF initiatives,
which aim to enhance transparency and data integrity, such as
Financial Sector Assessment Programs (FSAPs), ROSCs, and data
dissemination standards. In addition, these initiatives are voluntary
while safeguards assessments are linked to borrowings from the IMF.