In Eastern Africa, as in almost every other region of the world, there is a constant demand for increased efforts and actions to improve interventions on illicit financial flows generated by corruption, human trafficking, environmental and wildlife crime, counter-terrorism, money laundering, and asset recovery to name a few.
The EU’s AML-CFT ESCAY Project has been working with partner countries, not only in eastern Africa, but with 33 countries spread across east, central and southern Africa, targeting and disrupting illicit financial flows generated by organised crime.
As part of the EU’s AML-CFT ESCAY Project’s activities and needs assessments in this region, it was established that there was a lack of ‘Financial Investigation’ courses being delivered at any of the Police training institutions in most of the project’s partner jurisdictions. This clearly identified a need to support the development of a locally designed and accredited financial investigation curriculum in order to establish the foundations of nationally trained and accredited financial investigators. The EU’s AML-CFT ESCAY project team, led by Alma Wanyama, a Senior Technical Advisor with the project, focused on the needs of individual jurisdictions with a view to invest in supporting Police training institutions to develop such a curriculum, ultimately reducing reliance on ad hoc external support and creating a focus for future national skills development.
Thus the EU’s AML-CFT ESCAY Project embarked on a challenging but essential assignment to identify core capacity requirements needed to support the needs of these partner jurisdictions. And as Project team leader Frédéric Bayard, asserted in many instances, there was a need to build knowledge, skills and competencies to enable increased effectiveness across the AML/CFT landscape by providing tailored assistance.
Capacity building is a very complex activity requiring significant care and consideration in both the planning and delivery. Amongst other qualities, it needs to be realistic, achievable, and tailored to specific needs. It needs to provide sustainable development opportunities for students to develop their skills, knowledge, and understanding.
The Project therefore launched the support of selected countries to develop a National Curriculum on Financial Investigations. The decision to facilitate the design of a financial investigation curriculum for four different countries simultaneously – Malawi, Tanzania, Uganda, and Zambia – was a key element of the ultimate success of the process which took place over four months, including three face-to-face meetings. The multiple jurisdictions enabled peer review, sharing of experiences, and mutual support whilst designing four individually unique curricula.
A well developed and crafted curriculum is at the heart of any learning process. Curriculum development is the planned, purposeful and systematic process to create a platform for a positive educational experience. Sadly, it is an area often overlooked by providers as it can take a significant length of time to develop and requires a multi-agency approach. However, it is the essential foundation of the process for the delivery of any new skill or capability.
The curriculum framework, including the expected learning outcomes, communicates what teachers and learners should know and do. The curriculum is a description of what, why, how, and how well students should learn in a systematic and intentional way. Expected learning outcomes define the totality of information, knowledge, understanding, attitudes, values, skills, competencies, or behaviours a learner should master upon the successful completion of the curriculum.
Following AML-CFT ESCAY Project’s engagement with senior leaders in each country, a representative from the Police, the Financial Intelligence Unit and Prosecution was nominated to take the lead on behalf of their jurisdiction. The mix of experts from different countries created an environment where there was a definite sense of common purpose. The national representatives were supplemented by regional experts facilitating insights into academia, financial investigation, asset recovery, the role of a prosecutor, the perspective of the judiciary and accreditation agencies.
After the first meeting, each country undertook a detailed training needs analysis, stakeholder engagement (at both senior and practitioner level) and commenced the initial curriculum design.
A second face to face meeting explored some of the challenges encountered during the initial drafting of the curricula. The importance of peer review and support was evident during this week of activity. National experts from different jurisdictions, supported by other experts, were able to compare and contrast problems and reach appropriate solutions for the individual national requirements.
The interim period between the second and final meeting was an opportunity to focus on the fine details. Group and individual tutoring sessions were regularly conducted through online meetings in order to ensure that all opportunities and avenues for improvement were identified.
The final meeting was conducted in the presence of senior leaders and representatives from each country. This brought a sharp focus to the deliberations for the preparations in advance of the meeting requiring constant review and enhancement of the Senior representatives, who included Director of Public Prosecutions, Head of Financial Intelligence Unit, senior Law Enforcement officers and senior Prosecutors and experts in curriculum implementation. The latter was particularly important, led by the University of Nairobi with contributions from National Council for Technical and Vocational Education and Training (NACTVET) in Tanzania and National Curriculum Development Centre, Uganda.
The development and accreditation of the financial investigation curricula for Malawi, Tanzania, Uganda and Zambia has been a significant success and provides a great opportunity for the delivery of nationally owned and designed training to improve skills and capacity. However, the effective implementation requires support from across the international donor and provider community to support elements such as tutor training, development of manuals and guidance. Quite simply, delivery of the curriculum to a cohort of students will be the only way to evaluate whether the training has achieved its objectives and provide opportunities to identify areas for improvement.
Success in this area of activity is always dependent on people and undertaking the design of any curriculum, not least a financial investigation curriculum, requires people with a multidisciplinary background. The initial enabling mechanism was provided by the EU’s AML-CFT ESCAY project team through its recognition of national requirements and partnership approach. And success was achieved by bringing together national experts in a positive environment and providing them with the tools and the time to undertake a complex task.
Ultimately, any basic analysis of relevant processes and systems necessary for successful financial investigations, will identify that a key enabler in any of those investigative interventions is that a ‘financial investigation’ should be undertaken by a trained financial investigator who has completed an accredited curriculum delivered by a relevant institution. And this is the role that the completed curricula are anticipated to play and contribute to fighting illicit financial flows in the eastern Africa region and beyond.
