Anti-Corruption Day: Safeguarding Integrity Through Change

Tracy Staines Inspector General #UnitedAgainstCorruption #IACD2025

Remaining Steadfast in Our Commitment to Integrity, Transparency and Accountability

“The 2025 Anti-Corruption Day theme, ‘Uniting with Youth Against Corruption: Shaping Tomorrow’s Integrity,’ reminds us that the fight against corruption goes beyond systems and controls; it is fundamentally based on people and shared values. The real leaders in ensuring that Global Fund money is used with integrity and honesty are in the community: health workers, peer educators, and disease experts at the country level.” — Tracy Staines, Inspector General, Global Fund Office of the Inspector General (OIG).

On the 2025 International Anti-Corruption Day, the Global Fund remains steadfast in its commitment to integrity, transparency, and accountability.

As the Global Fund advances its eighth replenishment despite shifting global dynamics and mounting economic pressures on implementer governments, risks at the country level are intensifying and creating opportunities and incentives for fraud and abuse. Ensuring that every dollar is used for its intended purpose has never been more critical in the fight against HIV/AIDS, TB and malaria.

In this article, the Inspector General, Tracy Staines, explores the direct line between fraud and lost lives. While the Global Fund has strong governance systems in place to safeguard donor funds, the OIG is working on increasing its collaborative partnerships, enhancing information-sharing, and using technology and innovation in the fight against wrongdoing.

How do you see the Global Fund’s commitment to integrity and transparency as being key to its core function of saving lives?

Kofi Annan said, “The Global Fund will go down in history as one of humanity’s biggest achievements. It’s one of the kindest things people have ever done for each other.”

Inherent in the Global Fund’s foundation are core principles: partnership, country ownership, performance-based financing, and transparency.

These are not abstract concepts; they provide the backbone of the Global Fund’s ability to deliver impact. From an OIG perspective, funds stolen are funds taken away from the financing of medicines, diagnostics, and frontline health workers. OIG teams have seen first-hand the direct and devastating effects of fraud and abuse in our programs. The Global Fund’s mission can only be maximized when we ensure that every dollar is transformed into lifesaving impact, free from fraud and abuse.

Furthermore, without strong safeguards and oversight that contribute to donor confidence, we could not secure the financing that our programs rely on.

So what tools, policies or frameworks do the Global Fund have in place to safeguard the activities financed by our organization against fraud and abuse?

To ensure that funds reach those who need them most, the Global Fund relies on robust systems to deter, prevent, and respond to risk. Our fraud risk management approach is built on three lines of defense:

• First line: Country Teams, implementers, and in-country assurance providers;
• Second line: Risk Department, Grant Finance, the Ethics Office, and other risk owners such as Supply Operations; and,
• Third line: Independent oversight by the OIG.

The Grant Management Framework governs how funds flow through Principal Recipients and countries under strict agreements and performance-based funding. This is reinforced by assurance providers, Local Fund Agents (LFAs), and internal and external audits at the country level to verify financial controls and compliance, along with regular monitoring to detect irregularities early.

Beyond financial controls, integrity is embedded in our Code of Conduct and governance instruments such as the Policy to Combat Fraud and Corruption, the Ethics and Integrity Framework, and the Integrity Due Diligence Framework.

A recent OIG investigation illustrates how the OIG, Country Team and local assurance mechanisms can work together effectively to maximize efficiency and impact. The operational implications stemming from an anonymous complaint to the OIG hotline were discreetly discussed between OIG and the Country Team. Because there was insufficient detail to warrant immediately opening an investigation, an LFA review was commissioned. This review further uncovered indicators of fraudulent overcharging and the use of falsified documentation to secure contract awards.

How is OIG adapting its approach to address new and emerging risks in a shifting global landscape, ensuring OIG resources are focused where they matter most?

Driving Impact Through Partnership

Collaboration and information-sharing with Secretariat colleagues, with external partners, and with government counterparts are more crucial than ever.

For example, OIG’s Audit Unit works closely with the Secretariat and implementers to ensure assurance work targets the right risks early. Our investigators partner with local authorities and technical agencies to accelerate evidence-gathering.

Expanding our cooperation with organizations like GAVI, which is supported by many of our Board constituencies, creates opportunities to share intelligence and harmonize risk mitigation strategies. Earlier this year, we alerted GAVI to an issue affecting the funding of both organizations. We investigated the matter together, ensuring the interests of both parties were protected.

OIG also collaborates with Supreme Audit Institutions and national oversight bodies to strengthen governance on the ground. Through MOUs and knowledge-sharing initiatives, these efforts have helped to strengthen local capacity and promote best practices across the sector.

Adapting Oversight

OIG is adopting agile, innovative approaches to maximize impact and strengthen the protection of Global Fund resources.

For example, we recently introduced Rapid Assurance Reviews to help stakeholders anticipate and manage risks, and to adapt strategies to safeguard program outcomes. These are real-time, risk-based assessments that deliver timely assurance during process design. These reviews are invaluable when major decisions must be made quickly, often without complete information. Similarly, Rapid Advisory Reviews offer immediate guidance to the Secretariat throughout process development, ensuring robust controls from the outset.

In investigations, we have enhanced our proactive methodology to employ intelligence-driven methods to identify integrity risks that are not reported to OIG. After a proactive integrity review of a Global Fund-financed activity, OIG recently worked closely with the Country Team to refine project design and reduce fraud risk. We are also leveraging investigations conducted by implementers, extending our reach and enabling quicker intelligence gathering on emerging risks, so the Global Fund can respond before frauds can take hold.

What insights can you share on how new technologies are enhancing the prevention and detection of fraud and corruption?

Automation frees our team to focus on advanced risk analysis, while ongoing investment in staff proficiency with cutting-edge tools ensures their safe and effective application. In one investigation, OIG applied advanced analytics and machine learning to mobile money transactions, uncovering anomalies such as duplicate payments, unusual timing, and suspicious recipient details. This data-driven approach revealed hidden patterns like spikes in duplicate payments and phone numbers linked to multiple identities enabling targeted investigation.

What role can all of us - both internal and external stakeholders - play in adapting to the evolving landscape in terms of safeguarding the funds entrusted to us?

Ensuring integrity in all aspects of Global Fund activities requires vigilance at all levels. It requires people to speak up and speak out. The Global Fund is committed to fostering a culture of accountability and vigilance, ensuring everyone can speak up safely when something does not look right. Speaking out is not limited to reporting concrete allegations of fraud and abuse, it also entails staff consulting or seeking advice from integrity experts, whether OIG or the Ethics Office, when there is a concern.

Through the Whistleblower Policy and the I Speak Out Now initiative, individuals have access to secure, confidential channels for reporting suspected fraud, abuse, or misconduct. These mechanisms are designed to encourage early reporting and intervention, while protecting individuals from retaliation.

Get Involved!

To mark International Anti-Corruption Day, the OIG has launched a series of e-lessons designed to strengthen awareness and build capacity for speaking out against fraud and abuse. These interactive modules will help you understand the risks, recognize warning signs, and learn how to report concerns safely.

Ultimately, integrity is everyone’s business, and we encourage you to join us whether by completing the e-lessons, reaching out if you see something suspicious, learning how to spot red flags of fraud and abuse or contacting us to discuss fraud prevention strategies.