Mike J. Masoud
March 31, 2026

This is Part 3 of a five-part series on where countries should start when corruption is widespread across institutions and economic sectors. If Part 1 argued that a country must define corruption clearly, and Part 2 argued that it must build the right institutional foundations, this part addresses the practical question that follows: where should a country actually begin? The answer is blunt. It should not begin everywhere at once. It should begin where corruption risk is concentrated, where state capacity can act, and where early action can produce visible results for citizens (FATF, 2025; IMF, n.d.).

A country that says corruption is everywhere but starts nowhere has already chosen failure. Serious reform begins with diagnosis, prioritization, and sequencing. The FATF’s risk-based approach is useful here, even beyond anti-money laundering. FATF states that countries should identify, assess, and understand their national money laundering and terrorist financing risks, and then allocate resources to mitigate those risks effectively. Its updated guidance goes further: risk assessment should be ongoing, should inform changes to law and regulation, and should help authorities allocate and prioritize resources (FATF, 2024). That logic should also govern anti-corruption strategy more broadly. A country must first identify where corruption is hurting most, how it operates, who benefits, and which sectors produce the greatest public damage.

This is why national anti-corruption reform should begin with a structured corruption exposure assessment. Not a speech. Not a committee photo. Not an imported strategy document. A real diagnosis should identify high-risk sectors, vulnerable decision points, common forms of abuse, institutional bottlenecks, and the incentives that sustain corruption. The IMF’s governance and anti-corruption work is relevant because it focuses on state functions most critical to economic activity: fiscal governance, financial sector oversight, central bank governance, market regulation, rule of law, and AML/CFT. It also uses diagnostics to identify governance weaknesses, corruption vulnerabilities, and sequenced reform priorities (IMF, n.d.; IMF, 2026). That is the right approach. A country should not reform blindly. It should reform where the risks are economically and institutionally most damaging.

Public procurement is often one of the first sectors that deserves attention. The OECD notes that procurement is exposed to integrity risks across the entire cycle, from needs assessment to tendering and post-award phases, and that these risks include bribery, conflicts of interest, undue influence, unnecessary contracts, and cartel behavior (OECD, n.d.). That matters because procurement corruption is not only expensive; it is also harmful. It is visible. It affects roads, hospitals, schools, medicines, infrastructure, and public trust. If a government wants citizens to feel that anti-corruption is real, procurement is often one of the clearest places to begin.

Georgia’s reforms after 2003 offer a useful lesson on sequencing and visible early wins. World Bank accounts of Georgia’s public service reforms describe the use of one-stop shops, simplification of procedures, automation, and payment systems that reduced direct contact between citizens and officials. These reforms did not solve every governance problem. But they showed that reducing discretion, simplifying procedures, and making transactions more transparent can quickly lower opportunities for petty corruption in daily life (World Bank, 2012; World Bank, 2010). That is the kind of early progress citizens notice.

Hong Kong’s ICAC offers a different but equally important lesson. Its official structure reflects a three-pronged strategy: law enforcement, corruption prevention, and community education. The point is not that every country should mechanically copy Hong Kong. The point is that early action should not be limited to arrests. It should also redesign systems, close corruption opportunities, and shape public expectations. If reform begins only with punishment, while ignoring prevention and public understanding, it will not last (ICAC, 2025).

A serious first-year strategy should therefore do five things. First, conduct a national corruption exposure assessment. Second, identify two or three high-risk sectors where action is urgent and visible. Third, reduce discretion at known corruption points through process redesign, digitization, and control strengthening. Fourth, protect reporting channels, including whistleblowing and public complaints. Fifth, publish baseline indicators and year-end results so that citizens can judge whether progress is real. FATF’s recent toolkit is especially useful here because it urges countries to identify data gaps, prioritize further work, and develop targeted action plans rather than pretending they already understand the whole problem (FATF, 2025).

The starting point, then, is not “fight corruption everywhere.” That sounds strong, but it means nothing. A country should start where corruption is most prevalent, institutional leverage exists, and citizens can see the difference. Reform that cannot be prioritized cannot be implemented. Reform that cannot be measured cannot be trusted.

Next Tuesday, Part 4 — Why Anti-Corruption Efforts Fail Even When The Language Sounds Perfect — will examine how state capture, selective enforcement, donor complacency, weak incentives, and performative integrity destroy anti-corruption efforts from within.

References

Financial Action Task Force (FATF) (2024) Money Laundering National Risk Assessment Guidance. Available at: https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Money-Laundering-National-Risk-Assessment-Guidance-2024.pdf.coredownload.inline.pdf(Accessed: 30 March 2026).

Financial Action Task Force (FATF) (2025) FATF Launches National Risk Assessment Toolkit To Help Countries Identify Greatest Money Laundering Risks. Available at: https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-launches-National-Risk-Assessment-toolkit-to-help-countries-identify-greatest-money-laundering-risks.html(Accessed: 30 March 2026).

ICAC (2025) Organisation Structure. Available at: https://www.icac.org.hk/en/about/struct/index.html (Accessed: 30 March 2026).

International Monetary Fund (IMF) (n.d.) Governance And Anti-Corruption. Available at: https://www.imf.org/en/topics/governance-and-anti-corruption (Accessed: 30 March 2026).

International Monetary Fund (IMF) (2026) Frequently Asked Questions On Governance Diagnostic. Available at: https://www.imf.org/en/about/faq/governance-diagnostic (Accessed: 30 March 2026).

OECD (n.d.) Integrity In Public Procurement. Available at: https://www.oecd.org/en/topics/sub-issues/integrity-in-public-procurement.html (Accessed: 30 March 2026).

World Bank (2010) Fighting Corruption In Public Services: Chronicling Georgia’s Reforms. Available at: https://documents1.worldbank.org/curated/en/518301468256183463/pdf/664490PUB0EPI0065774B09780821394755.pdf(Accessed: 30 March 2026).

World Bank (2012) Georgia’s Fight Against Corruption In Public Services Wins Praise. Available at: https://www.worldbank.org/en/news/press-release/2012/01/31/georgias-fight-against-corruption-in-public-services-wins-praise(Accessed: 30 March 2026).