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relative to FY 2012, at over 70 central banks.
11. Monitoring work was carried out in close collaboration with area departments, as well as departments providing technical assistance.
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Safeguards staff informs area departments of
significant developments identified during the monitoring phase, as well as instances of delays in receiving requested information.
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Monitoring work in FY 2013 also included staff accompanying an area department mission to one country to clarify treatment of certain foreign deposits for
monetary data reporting purposes under the existing program, and to assess the effectiveness of the audit committee.
A. Safeguards Findings and Recommendations
12. While safeguards assessments continue to see a general trend of improvements in the central banks’ safeguards framework, areas of risk to IMF resources remain in certain areas.
Some key findings are summarized below. Board Oversight
13. All central banks assessed had a functioning Board of Directors with a majority of non- executive members, but oversight was not always effective.
In a number of cases, audit committee oversight was not effective due to inadequate scope or committee members’ lack of
requisite technical competencies. Recommendations to address these vulnerabilities included: i expanding the scope of oversight; ii publication of the audit committee annual activity report;
and iii hiring an advisor with expertise in the areas of financial reporting and auditing to assist the audit committee. One assessment found a Board with limited responsibilities that did not include
oversight of executive management. Consequently, financial reporting and auditing frameworks were exclusively under the control of the Governor thereby creating conflict of interest issues. The
assessment recommended revising the central bank law to provide the Board with a broader mandate and, as an interim measure, establishment of an audit committee.
Autonomy
14. Weak autonomy was found in two central banks.
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In both cases, this was due to inadequate provisions in the central bank law that allowed: i the government to give instructions to
the central banks; and ii the central banks to effectively provide unlimited lending to government or other entities. Other weak provisions in the law concerned appointment rules for central bank’s
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Central banks on occasion request Fund technical assistance to implement safeguards recommendations. In such cases, safeguards staff liaises with the technical assistance team to facilitate monitoring of the implementation status
of recommendations.
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The 2010 policy review endorsed the requirement that instances of non-receipt of monitoring information be explicitly flagged in staff reports. Two reports were flagged in FY 2012, and there was no occurrence in FY 2013.
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In two more cases, the legal framework did not provide the central bank with adequate autonomy, but this risk was mitigated by de facto practices.
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Board members. Recommendations were made to revise the central bank law and in one case, this was incorporated in the program design.
Financial Reporting and Auditing
15. Deficiencies in financial reporting and auditing frameworks that pose a risk of misreporting were identified in six cases.
Most of the central banks assessed had their financial statements prepared and audited in accordance with international standards. Internal audit
departments were functioning and also benchmarked against international standards. However, in some cases the assessments identified vulnerabilities that could pose risks for accurate data
reporting and the adequacy of controls over financial resources:
Weak financial reporting. In one instance, a central bank did not adopt a comprehensive
financial reporting framework, and in another, such a framework was not fully followed with respect to creating impairment provisions on loans to government and the financial sector.
Poor external audit quality. In two assessments, staff identified deficiencies in the
independence or quality of external audit practices. In both cases, audit firms were part of global networks, which illustrates that network membership alone does not guarantee good
audit quality.
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Inadequate internal audit. Four assessments saw low internal audit coverage of areas of
importance to safeguards, for example, foreign exchange and reserves operations, lending operations, IT systems and controls, due to low capacity in the central bank either in terms
of competencies or number of staff.
16. Assessments tackled the above-mentioned deficiencies through targeted recommendations and improvements to audit committee oversight.
Recommendations included: i adoption of an internationally recognized accounting framework; ii involvement of an
external audit partner from another office with demonstrated experience in central bank audits; or iii an external quality review of the internal audit function and, where necessary, co-sourcing
arrangements with another central bank or professional firm. However, such recommendations address only specific vulnerabilities identified by the assessment and not the underlying conditions
that allowed the vulnerabilities to emerge, specifically the lack of effective oversight. Accordingly, strengthening audit committee oversight was a key governance element that featured in a number
of assessments.
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These experiences were communicated to the auditing profession and their networks through staff’s outreach collaboration with stakeholders. Such instances include staff’s briefing to the IFAC’s Forum of Firms on audit quality
concerns see bullet point on staff’s engagement with auditing firms on page 11.
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20 40
60 80
100 120
Recommendations incorporated in program measures
Other recommendations end-April 2012
end-April 2013
Implementation Rates for Safeguards Recommendations
Controls and Risk Management
17. Deficiencies in operational controls were identified in two assessments. In one case, controls over payments on behalf of the government were weak, resulting in larger than acceptable
cash transfers and payments not substantiated by appropriate documents. The assessment recommended the appointment of an international audit firm to conduct an audit of controls, and
the status of implementation of earlier recommendations in this area. In another case, currency notes designated for destruction were not immediately perforated, which led to instances of theft.
The assessment recommended establishing formal control procedures for the destruction and perforation of unfit notes.
18. Assessments found varying degrees of development in central bank risk management functions.
Only two central banks had developed their risk management functions to an advanced stage. In four others, development of the risk management framework was a work in progress, and
for the remaining five central banks assessed no substantial progress was evident. Safeguards assessments provided recommendations tailored to advance development of the risk management
function, taking into account central banks’ capacity and overall development of their respective governance frameworks.
Recommendations
19. Staff continues to emphasize tailored recommendations.
