Table 20.3 Levels of mitigating actions needed to address vulnerabilities, by organizational (action) category and functional (governance) dimension Functional (governance) dimension Organizational (action) category
Procedures
Human resources and administrative capacity
Policy
Institutions
Enforcement
Political decision
Legislation
Border agencies
Interagency
Rules of business
Government guidelines
Interagency
Administration
Internal
Statute
Political decision
Government guidelines
Legislation
Interagency
Revenue
Government guidelines
Finance
Budget
Finance
Source: Authors’ compilation.
The example in table 20.5 shows the impact on corruption risk of one customs process substep (border infrastructure) within the arrival, landing, and reporting step. This impact is assessed in terms of the issues and risks, the agencies concerned, the probability of corruption, and the mitigating action identified in the particular context. The mitigating actions are assigned to four major customs functions (preventive, investigative, postclearance, and online checks) and to other checks and audits. The impact of the mitigating actions is assessed in terms of functions affected and overall contribution to reducing the risk. As each action may have an impact on other areas later in the process, dealing with one aspect of the reform may have a greater than proportional result in terms of downstream operations. For example, border station design must take into account interagency and cross border cooperation—identified under a previous step in the matrix—which will also contribute to solve some later compliance issues. Each time such an action is completed under the project, the table is automatically updated to change the value in the corresponding cell to 0, thus reducing the total impact of mitigating actions for this substep on corruption risk (shown in the right column of table 20.5, with a starting value of 25 in the example). The impact on corruption risk levels of a given aspect of reform is accordingly reflected in a specific governance surface diagram for (figure 20.3, using the border infrastructure example). Each time an action is completed under the substep (or an earlier substep), one of the peaks on the diagram is flattened. Ideally, when all mitigating measures have been introduced, the entire surface bottoms out and becomes flat. B O R D E R M A N A G E M E N T M O D E R N I Z AT I O N
20 Integrity risk modeling in the border management context
For each combination of an organizational (action) category and a functional (governance) dimension, the level of the mitigating action needed is shown in a matrix (table 20.3). The matrix also brands project input categories in a way that allows crossreferencing among various donors. In designing this matrix it was recognized that most vulnerabilities to corruption are attributable, or related, to deficiencies in all four functional dimensions. To allow the setting of priorities, only the most important dimensions were identified for each substep. Human resources and administrative capacity affect all processes and were recognized as an important crosscutting issue, but they were included in the matrix only when they had an unusually large impact on the ability to implement reforms. It was also recognized that any mitigation action plan would require strong capacity and institution building measures. For the example introduced earlier (see tables 20.1 and 20.2) a comprehensive table was constructed (table 20.4), correlating corruption risks and vulnerabilities to possible mitigating actions and the agencies involved (broken down by the various levels of mitigating action) and setting priorities for each mitigating action. The comprehensive table was then transformed into an overall governance surface diagram showing the vulnerability of customs processes to corrupt practices (figure 20.2). Given the high interaction between processes, mitigating actions in one area usually have downstream effects on later processes. Such effects can be updated automatically by the model. Links were therefore established in the matrix between measures taken under one process step and any later steps that would be affected by the same measures.
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