Interview With Dashdavaa Zandraa, Mongolia’s Anti-Corruption Chief

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Interview With Dashdavaa Zandraa, Mongolia’s Anti-Corruption Chief

“Fighting corruption is more about eliminating the conditions that create corruption than about corrupt officials,” says the director-general of Mongolia’s Independent Authority Against Corruption.

Interview With Dashdavaa Zandraa, Mongolia’s Anti-Corruption Chief
Credit: IAAC handout

Since Mongolia’s rapid democratization in the 1990s, the country has faced major hurdles in combating corruption. The country spent many years attempting to adopt a new, transparent legal system that prevents government officials taking bribes, but there was a blind side. Although the legislative framework aimed at ending corruption, implementation was not quite successful. When the Pandora Papers revealed undisclosed assets, including cash and property worth millions of dollars, held by Mongolian high-level officials, it sparked public outrage.

As Mongolia’s international reputation grew, both government and non-government organizations have been working on fighting corruption. For example, in 2020, Mongolia implemented e-governance in the midst of the COVID-19 pandemic; significantly, these electronic services help to eliminate lower-level corruption by cutting out interactions with bureaucrats to access government services. Despite these efforts, however, Mongolia continues to rank toward the bottom of international corruption barometers.

In order for us to get a fuller picture, The Diplomat interviewed the director-general of Mongolia’s Independent Authority Against Corruption (IAAC), Dashdavaa Zandraa, about past and future efforts to fight corruption.

In 2021, Mongolia scored 35/100 and ranked 110th out of 180 in Transparency International’s Corruption Perceptions Index. It has not scored above 39/100 since the index began using the current scoring system in 2012. What is the leading contributing factor in Mongolia’s corruption, and why has improvement been so hard to come by?

The Government of Mongolia attaches great importance to the fight against corruption. For instance, on July 16, 2021, at the initiative of the Prime Minister Oyun-Erdene Luvsannamsrai, a working group was established to improve the assessment of the Corruption Perceptions Index published by Transparency International.

The main goal of this working group is to correct the shortcomings of the previous anti-corruption measures and to eliminate the obstacles to the successful reduction of corruption.

Generally speaking, to improve [Mongolia’s ranking on] the Corruption Perceptions Index, it is necessary to change the underlying factors that contribute to corruption. First, it is important to reduce the bureaucracy of the civil service, and second, to improve the legal environment.

Mongolia is actively working to reduce the bureaucracy of the civil service through digitalizing civil services and has successfully integrated 512 civil services as of now. In addition, the Prime Minister has set a goal to reduce the number of government licenses, signatures, and contracts issued to businesses by 50 percent in 2024, which will drastically reduce the human factor in civil services. Mongolia’s long-term development policy also states that “e-governance technology will reach international standards and social relations will be developed without corruption and bureaucracy.”

Furthermore, to effectively combat corruption, it is necessary to eliminate the underlying conditions that create the risk of corruption rather than corrupt officials and minimize human involvement by limiting the ability of officials to make subjective decisions. For instance, in the framework of e-governance development, the process of allocating land to citizens has been fully digitalized and posted publicly on the “” website, making it possible for citizens to receive land allocation only in a transparent manner through auctions, without any government officials’ interference. In other words, it eliminated the risk of officials abusing their power and illegally allocating land to themselves and others. Fighting corruption is more about eliminating the conditions that create corruption than about corrupt officials.

In the future, we aim to further develop e-governance and integrate all possible government information networks using blockchain technology. The use of advanced technology in anti-corruption activities is essential.

To improve the legal environment, the government has submitted a draft Law on Whistleblower Protection to the Parliament. We are confident that the results will be visible in 2022, as we are holding regular meetings with international donors and foreign research organizations and implementing good practices and recommendations to combat corruption.

According to the recently released TRACE International’s Bribery Risk Matrix, the risk of bribery in Mongolia’s business sector has decreased by 2 points and has improved by 7 placements. Since 2019, our country’s assessment has been consistently improving.

Over the years, the Mongolian public has expressed distrust or disappointment in IAAC efforts at tackling high-level corruption. For example, the notorious “60 billion tugriks” case right before the 2017 Mongolian presidential election captured public attention, but the involved parties still hold government positions. What new approaches is the agency utilizing to pursue high-level corruption cases?

We pay special attention to all cases of corruption, both high and petty corruption. In 2021, 160 corruption cases were prosecuted.

Recovery for corruption is a key strategy not only for the international anti-corruption community but also for national policy and is a vital goal for our country’s public policy. Recovery is an important factor in establishing social justice, even if it does not fully heal the damage done to the integrity of the state, democratic values, and the opportunities that citizens would have. The Independent Authority Against Corruption pays utmost attention to the recovery of damages caused by corruption crime and has recovered $4 million in 2019, $12.5 million in 2020, and $33.8 million in 2021 to the state treasury. In addition to government organizations, the fight against corruption requires the participation of non-governmental organizations, the media, citizens, and international organizations’ cooperation, and efforts.

According to the Anti-Corruption Law of Mongolia, the IAAC receives annual declarations of assets and income of public officials and, in the event of significant changes, we inspect and monitor the legitimacy of the official’s income. In particular, the declaration of assets and income of high-risk sectors, organizations, and high-ranking government officials is of great importance. This is crucial for proving and identifying corruption, conflict of interest, and illicit enrichment. In 2020, the IAAC registered a total of 41,686 declarations of interests, assets, and income, which inspected 542 declarations and held 79 officials responsible for violations of law. In addition, 704 complaints, and information of conflict of interest were inspected, and 25 officials were held accountable.

Can you walk us through the process for investigating a case that may involve high-level corruption (for example, involving conflicts of interests or bribery)?

Investigations into corruption are regulated by the Mongolian Criminal Procedure Code. According to the law, an investigator of the IAAC shall investigate a corruption case based on a complaint, decide on whether to open an inquiry case, and immediately notify the prosecutor.

During the investigation, an investigator shall take samples, fingerprints, and footprints for analysis, [hear] testimony from victims and witnesses, confiscate assets, and property relevant to the case, and appoint experts for further investigation.

Upon completion of the inquiry, the investigator shall submit to the prosecutor one of the proposals to close the inquiry case or initiate a criminal case and prosecute as an offender. In the case of an indictment, an investigation is conducted until the case is transferred to court.

After investigation, the prosecutor shall decide whether to transfer the criminal case to court and, if transferred, issue an indictment. Thus begins the process of resolving the case in court.

The IAAC has come under political pressure in the past, which organizations like Transparency International warned could interfere with the body’s functioning. Do you believe the IAAC is sufficiently empowered to perform its core functions as an independent body?

Yes, I do believe that the IAAC is sufficiently empowered to perform as an independent body. During my time as a director-general, I have not faced any kind of political pressure. The Parliament of Mongolia passed the Anti-Corruption Law on July 6, 2006, which established the IAAC as an independent, sovereign, and specialized government agency. The law provides political, economic, social, and legal guarantees to ensure the independence of the organization. For instance, the IAAC’s budget must be approved independently, and it is prohibited to transfer an employee to another position without its consent.

Furthermore, the director-general and deputy director-general of the IAAC are appointed and dismissed by the Parliament. In this case, the directors shall be dismissed upon their request, for medical reasons, the expiration of their term of office, and the entry into force of a court sentence. In addition, the law prohibits the removal, suspension, or dismissal of the directors on grounds other than those specified in the law. This guarantees the independence of the IAAC.

In 2019, the Mongolian branch of Transparency International evaluated the IAAC’s performance. The assessment rated the IAAC’s legal independence as “good,” its operational independence as “moderate,” and its organizational independence as 78 out of 100, with four recommendations. We believe that the assessment of independence has increased as a result of the implementation of the recommendations.

Mongolia implemented e-governance in 2020, amid COVID-19. This is a new approach for Mongolia to tackle low-level bribery and corruption in public service. Do you believe there has been an improvement in lower-level corruption in the past year?

Yes, I also believe that petty corruption has decreased over the year. The ability to communicate directly between a citizen and a civil servant poses a certain risk of corruption. Many countries around the world are using a variety of techniques to reduce this risk, and the development of e-governance has proven successful. Therefore, Mongolia pays utmost importance to the development of e-governance. As mentioned above, 512 public services have been digitalized so far, and the goal is to digitalize all available public services in the future. It also has the advantage of eliminating bureaucracy and increasing information transparency.

Bribery Risk Matrix and the Rule of Law Index improvement indicate that the level of corruption has declined to some extent in Mongolia. The IAAC also conducts regular internal surveys to identify corruption, one of which is the Public Integrity Assessment. The assessment indicated a decrease in the level of corruption in 2021.

How does the IAAC deal with offshore-related cases, particularly involving parties who may hold high-level government positions? How is the IAAC working with other governments to combat corruption in Mongolia?

Corruption has spread beyond the national level, with the involvement of foreign banks, financial institutions, and the public and private sectors. Mongolia has signed 36 agreements with about 20 countries on mutual legal assistance in civil and criminal matters, transfer of offenders, and transfer of sentenced persons. We are working to further expand and deepen this type of agreement. Although no mutual legal assistance agreement has been signed, we have worked effectively with several countries under the UN Convention Against Corruption, in particular in the areas of recovery of damages and information exchange.

One of the main principles of the  U.N. Convention Against Corruption is to recover corruption crime damages. In this framework, the IAAC successfully recovered $7 million worth of illicit assets, such as apartments, houses, and cash, from the United States, the United Kingdom, and Switzerland. We look forward to further expanding our international cooperation with the member states of the Convention to the fullest extent possible.

Furthermore, the IAAC is cooperating extensively with the Asset Recovery Interagency Network- Asia Pacific, the Organization for Economic Cooperation and Development, the World Bank, the United Nations Office on Drugs and Crime (UNODC), the Stolen Asset Recovery Initiative, and the FATF.