I would like to follow up on Paul’s interesting comments on information sharing and the need in particular for timeliness. He raises a number of issues on when to share information and this is where I would like to come in. My background relies on information sharing across disciplines, be they units in the Bank or wider afield to other agencies such as Multi Lateral Development Banks (MDB) with their own integrity/investigations function or to law enforcement. And herein lies the difference between information managed by law enforcement when compared to that of the development community. In our search for timeliness – often a crucial issue for law enforcement it is not so for the development community, and in some ways this is essential as it allows us to first evaluate the reliability of the source of the information and then question the validity of the information. One may ask why we should do this, and the simple answer is – we must be able to satisfy ourselves that we have undertaken our own due diligence and are confident that the information we are providing will add value to the enforcement entity with whom we share the information. For instance we may find that after questioning the source of the data we ascertain that the information is not known directly to the source it is in fact a regurgitation of information relayed to him/her by someone else – and therefore while our source may be good the validity of our information could be questioned.
In early 2009, the U.S.-based multinational Halliburton paid $579 million to the U.S. government to settle charges it had bribed Nigerian officials to win a contract. In late 2008 the German telecommunications giant Siemens paid $1.6 billion in fines, penalties and disgorgement of profits to the German and American governments for bribing officials.
I believe that timeliness is key in the sharing of information. If criminal information about suspects is not shared with those who need to know in a timely manner, this can result in crimes being committed that could have been prevented or once-in-a-lifetime investigative opportunities being lost.
In the field of fraud and corruption and in our context, the failure to share information in a timely manner can result in funds continuing to leak that could have been put to use to the benefit of society and overburdened countries and taxpayers picking up the bill for products and services that they have not received, are incomplete or are hugely overpriced.
The question I want to raise is whether and how we can share information at a sufficiently early stage.