CHAPTER 3 ii. Findings of the CRM 106. The CRM's discussion on corruption and money laundering focused on measures that could be put in place to combat both. There has been much more enthusiasm among stakeholders for discussing corruption rather than money laundering. 107. As regards money laundering, the Ghanaian authorities are taking action in certain areas, especially money laundering related to drug trafficking and smuggling. A difficult area in the Ghanaian, and indeed African, setting is related to legitimate cross-border operations (involving proper transit at customs stations) and money transfers related to remittances and trade. Many persons both traders and non-traders simply do not operate in the formal banking systems, even though they handle large amounts of cash. Similarly, remittances often involve cash transfers through foreign exchange bureaus and other private agents. It becomes a challenge to the authorities to decipher which constitute genuine fund transfers and which involve money laundering. 108. The private and civil society stakeholders expressed the earnest desire that the government should deal resolutely with corruption in public administration, as it undermines public finances as well as the government's credibility. They welcome government efforts to tackle corruption (e.g. via legal and other institutional and organisational reforms), but note that low salaries make certain types of corruption difficult to eradicate. Institutional arrangements must be accompanied by a strong commitment to enforce the rules in actual practice. Organisations tasked with implementing the arrangements must have adequate capacity and incentives to do so. There is, for instance, a widely held public perception that corruption at the level of the judiciary, coupled with the problem of producing concrete evidence, has made the fight against corruption extremely difficult. 109. Government representatives at the discussions noted the institutional and organisational efforts recently put in place or reinforced to tackle corruption, such as the Serious Fraud Office (SFO) and the Office of Accountability. Laws relating to auditing and procurement also play a part in the fight against corruption in public administration. Various additional procedures include: ? Enforcement of codes of conduct; ? Simplification of procedures in the provision of public services; ? Prompt investigations of allegations of corruption; and ? Establishment of clear and publicised rules and procedures for procurement. 78

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