Tools Audit Export Fauna and Flora



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Corrupción Transnacional
Methodological Tools for
the Public Auditing of the
Legal Export of Wild Flora
and Fauna Species, with a
Focus on the Prevention of Transnational Corruption
PHOTO: Vitaliy Zamedyanskiy – Unsplash September 2021

Corrupción Transnacional
Specialized Working Group in the Fight against Transnational Corruption (GTCT)
Ing. Carlos Alberto Riofrío González
Acting Comptroller General of the State of the Republic of Ecuador
President of GTCT
Full Members:
Lic. Jesús Rodríguez , President of the General Auditing Offi ce of the Nation (Argentina)
Dr. Henry Lucas Ara Pérez, Comptroller General of the Plurinational State of Bolivia
Minister Ana Lúcia Arraes de Alencar, President of the Federal Court of Accounts (Brazil)
Dr. Jorge Bermúdez Soto, Comptroller General of the Republic of Chile
Dr. Carlos Felipe Córdoba Larrarte, Comptroller General of the Republic of Colombia
Lic. Gladys María Bejerano Portela, Comptroller General of the Republic of Cuba
Ing. Carlos Alberto Riofrío González, Comptroller General of the State of the Republic of Ecuador, Presidency
Lic. Roberto Antonio Anzora, President of the Court of Accounts of the Republic of El Salvador
Dr. Edwin Humberto Salazar Jerez, Comptroller General of Accounts of the Republic of Guatemala
Magistrado Ricardo Rodríguez, President of the Superior Court of Accounts of the Republic of Honduras
Lic. David Rogelio Colmenares Páramo, Superior Auditor of the Federation (Mexico)
Lic. Gerardo F. Solís Díaz, Comptroller General of the Republic of Panama
Dr. Camilo Daniel Benítez Aldana, Comptroller General of the Republic of Paraguay
Econ. Nelson Shack Yalta, Comptroller General of the Republic of Peru
Associate Members:
Counsellor Adircélio de Moraes Ferreira Júnior, President of the Court of Accounts of the State of Santa Catarina
Counsellor Antonio Cristovão Correia de Messias, President of the Court of Accounts of the State of Acre
Dr. Eduardo Benjamín Grinberg, President of the Honorable Court of Accounts of the Province of Buenos Aires

Corrupción Transnacional
Methodological Tools for
the Public Auditing of the
Legal Export of Wild Flora
and Fauna Species, with a
Focus on the Prevention of Transnational Corruption
September 2021

Roberto José Domínguez Moro
Technical Team at the Contraloría General del Estado del Ecuador, Presidency of the OLACE-
FS Working Group Specialized in the Fight against Transnational Corruption
• María Isabel Vásquez Paredes, María Gabriela Mesías, Daniela Rodriguez and Lisette Ma-
ría Villacrés García
Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
• Christiane Holvorcem, Erwin Alberto Ramírez Gutiérrez, Melissa Janeth Narro Saucedo
* The results of the in-house consultancy carried out by María de los Ángeles Barrionuevo were
essential for the development of this publication. For more information about this work, we
invite you to consult the OLACEFS webinar on the occasion of World Wildlife Day, entitled
“Prevention of Corruption: The Role of SAIs In Wildlife Trade”, organized and presented on
March 3, 2021 by the Presidency of the GTCT, along with GIZ, which is available on OLACEFS’
YouTube channel at (video in Spanish).
© Copyright 2021, OLACEFS
Printed in Brazil
The concepts and opinions expressed in this work are solely the responsibility of its authors.
It is allowed to copy this publication, in part or in whole, without changing its content, as long as the source is
mentioned and there is no commercial goal whatsoever.
This publication and the study that preceded it had the support from the German Cooperation through the Deuts-
che Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH, in the context of regional project Strengthening
External Control in the Environmental Field, implemented in an alliance with the Federal Court of Accounts (TCU)
of Brazil and the Latin American and Caribbean Organization of Superior Audit Institutions (OLACEFS).

GTCT Corrupción Transnacional
Message of the Presidency of the GTCT
1. Available at ora02mar2021SPN_web.pdf
The entities that make up the OLACEFS Spe-
cialized Working Group on the Fight Against
Transnational Corruption (GTCT) have enthu-
siastically taken on the task of defi ning tools
to verify the correct execution of controls in
legal processes for the commercialization of
wild fl ora and fauna. This responsibility de-
rives from the mission of the external con-
trol bodies regarding the care of public re-
sources. Thus, the conservation and proper
management of species in Latin America and
the Caribbean constitute a fundamental axis
for these organizations, even more so when
strong links have been identifi ed between
transnational corruption and the commis-
sion of environmental crimes that may in-
volve offi cials of public entities (Domínguez,
For this reason, the Working Group has obtai-
ned the support of the German Development
Cooperation (GIZ), through the OLACEFS
Project for Strengthening External Control,
to carry out studies that will allow the de-sign of instruments to combat illegal trade
in species. A fi rst result of this alliance has
been the publication “Species traffi cking as
a paradigmatic case of transnational corrup-
tion: potential contributions of governmental
external control.” Now, we are pleased to in-
troduce this document, whose contents help
to strengthen methodological aspects, thus
enhancing the planning of environmental
audits in the region.
We invite members of the international su-
preme audit community and external stake-
holders to review and use the tools provided
in this publication with the aim to protect
the biodiversity of Latin America and the Ca-
ribbean and achieving the goals set out in
the 2030 Agenda for Sustainable Develop-
ment, SDG 14 and SDG 15.
Ing. Carlos Alberto Riofrío González
President of the GTCT

GTCT Corrupción Transnacional
Message from GIZ
Supreme Audit Institutions (SAIs), through
their audits and mandates, can contribute
to strengthening the transparency of public
administration, making risks visible and cre-
ating strong and effective internal controls
to help prevent corruption. Other key ele-
ments of the SAI’s anti-corruption work in-
clude focusing audit actions and activities in
areas of high corruption risk, redirecting or
referring questions about alleged illegal/cor-
rupt practices to relevant law enforcement
agencies, cooperation with anti-corruption
institutions, as well as involving civil society
in government auditing and accountability
The importance of SAIs was recognized by the
United Nations General Assembly in Resolu-
tion A/69/228 (December 2014) to “promote
effi ciency, accountability, effectiveness and
transparency in public administration, whi-
ch is conducive to achieving the goals and
national development priorities as well as in-
ternationally agreed goals.” In addition, the
United Nations (UNGASS: 2021) has recog-
nized the contribution of SAIs in the area of
preventing and fi ghting corruption.
In this sense, and since its creation in 1963,
the Latin American and Caribbean Organiza-
tion of Supreme Audit Institutions (OLACEFS)
promotes the exchange of knowledge among
SAIs in the region, encourages technical
cooperation among its members and with
external actors, contributes to the develop-
ment of innovative audit tools and methodo-
logies, and encourages the execution of re-gional initiatives to strengthen transparency
and integrity both within SAIs and in the pu-
blic sector.
Created in 2019, the OLACEFS Working Group
Specialized in the Fight against Transnatio-
nal Corruption (GTCT), under the leadership
of the Offi ce of the Comptroller General of
the Republic of Ecuador, seeks to articulate,
promote and consolidate existing and future
initiatives for the prevention, detection and
mitigation of impacts of corruption, as well
as support its investigation and penalization.
The GTCT has received support from the
German Cooperation, through the Deutsche
Gesellschaft für Internationale Zusamme-
narbeit (GIZ) GmbH, for the implementa-
tion -with OLACEFS- of the regional projects
Strengthening External Control in the En-
vironmental Area (2016-2021) and Streng-
thening External Control to Prevent and Fi-
ght Corruption (2021-2024). One of the fi rst
initiatives of this technical collaboration fo-
cuses on the issue of corruption associated
with illicit traffi cking in wild species, which
is highly relevant in the region, given its har-
mful social, environmental and economic ef-
fects, with a focus on the role of SAIs in its
In a recent publication
2, resulting from a
consultancy supported by the previously
mentioned regional project with an environ-
mental focus, the GTCT addressed the issue
of corruption associated with the illicit tra-
ffi cking of species, discussing international
2. “Species traffi cking as a paradigmatic case of transnational corruption: possible contributions of governmental external control”; available at ora02mar2021SPN_web.pdf

GTCT Corrupción Transnacional
PHOTO: Gerald Schombs – Unsplash
practices to combat this type of crime, the
most relevant actors involved, the existing
potential for contributions in the area by
SAIs, as well as the importance of coopera-
tion among institutions, at national and re-
gional levels, to achieve signifi cant results in
the mitigation of these crimes.
This publication represents a step forward in
the work of the GTCT, aimed at strengthening
the capacities of SAIs in Latin America and
the Caribbean in fi ghting corruption asso-
ciated with the illicit traffi cking of species.
As a result of another consultancy supported
by the project, a methodology was developed
for planning audits on the subject, including
the selection of species whose illegal trade
aims to be investigated, the survey of regula-
tions and legal and administrative processes
involved in the commercialization of species,
their vulnerability to corruption, and the
mapping of relevant actors and their inter-
connections. This methodology is described in detail in the following pages, concluding
with a case study on the application of the
methodology to the analysis of the process of
legal export of sharks in Ecuador.
We hope that this publication will help SAIs
in carrying out external control actions, toge-
ther with other SAIs and national or multila-
teral institutions, that contribute to discou-
raging corruption in these species trading
processes, thus preserving biodiversity, the
functioning of ecosystems, and the natural
heritage of the countries in the region.
Erwin Alberto Ramírez Gutiérrez
Director of Regional Projects Strengthening of External Control in the Environmental
Area and Strengthening of External Control for Prevention and Effective Fight against Corruption
Biosphere Program
Deutsche Gesellschaft für Internationale
Zusammenarbeit (GIZ) GmbH, Brazil’s Offi ce

GTCT Corrupción Transnacional
International trade, like any legal activity
regulated by the relevant government ins-
titutions and governed by a set of technical
and legal provisions, is part of the univer-
se auditable by Supreme Audit Institutions
(SAIs), given the intervention of a considera-
ble number of specialized government agen-
cies, as well as entities for the registration
and control of operations carried out for the-
se purposes.
Furthermore, with the growing importance
that international trade has acquired as a
tool for generating employment and econo-
mic development, the correct performance
of the related authorities –and that can be
evaluated through the action of governmen-
tal external control through the practice of
different types of audits– represents a factor
of utmost importance, given the possibilities
that the exchange mechanisms are used for
irregular purposes.
That is why the Specialized Working Group
on the Fight against Transnational Corrup-
tion (GTCT) of the Latin American and Carib-
bean Organization of Supreme Audit Institu-
tions (OLACEFS), aware of the importance of
offering technical alternatives to SAIs to deal
with this type of problem, provides to the
auditing community and other stakeholders the document Methodological Tools for Pu-
blic Auditing of the Legal Export of Wild Flora
and Fauna Species, with a Focus on the Pre-
vention of Transnational Corruption.
This document systematizes the specialized
consulting work presented on March 3, 2020
in a webinar organized by the GTCT, within
the framework of the implementation of the
regional Project for Strengthening External
Control in the Environmental Area, with the
support of the German Cooperation (through
the Deutsche Gesellschaft für Internationale
Zusammenarbeit (GIZ) GmbH).
The document offers methodological ele-
ments to support SAIs in defi ning possible
environmental audits with a focus on cor-
ruption prevention and inter-institutional
coordination in the area of wildlife trade,
constituting a relevant topic to add to the
universe of possible objects of public audi-
ting conceived as a complement to the gui-
delines set forth in the Environmental Guides
and other technical documents
3 developed
by the Working Group on Environmental
Auditing (WGEA) of the International Orga-
nization of Supreme Audit Institutions (IN-
TOSAI), as well as by the Special Technical
Commission for the Environment (COMTEMA)
3. There is an important body of documents on environmental matters developed by the WGEA, which will be detailed in section V of this work; These texts, and the Spanish version of some of them, can be consulted at
guidelines/. Likewise, it is recommended to consult GUID 5200, “Activities with an Environmental Perspective,” available at https://www. and GUID 5203 “Cooperation on Audits
of International Environmental Accords,” available at
4. Documents are available at

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Message of the Presidency of the GTCT ………………………………………………………………..5
Message from GIZ …………………………………………………………………………………………… 6
Preface …………………………………………………………………………………………………………. 8
I. Introduction …………………………………………………………………………………………….. 11
II. Justifi cation ……………………………………………………………………………………………. 15
III. Basis for the preparation of the document …………………………………………………… 19
IV. Defi nition of the Audit Object …………………………………………………………………….. 21
V. Defi nition of processes and sub-processes ……………………………………………………. 25
VI. Mapping of relevant actors ………………………………………………………………………. 30
VII. Practical example: the commercialization of the Ecuadorian shark ………………….. 36
VIII. Opinions of specialized organizations ……………………………………………………….. 40
IX. Conclusions ……………………………………………………………………………………………. 44
List of Acronyms ……………………………………………………………………………………………. 46
Glossary ………………………………………………………………………………………………………. 47
References …………………………………………………………………………………………………… 49


GTCT Corrupción Transnacional
The processes of globalization have opened
new markets with high purchasing power
in different Asian and Middle Eastern coun-
tries, which have joined the traditional spa-
ces for the consumption of fl ora and fauna
in Europe and North America. This scenario
puts the conservation of species at risk and
facilitates the occurrence of acts of corrup-
tion to ensure that the “good” is obtained.
Species and derived products are used in di-
fferent areas: food (shark fi ns, swallow nests,
bear vesicles, turtle eggs, etc.), pharmaceu-
tical industry (primates and other mammals for experimentation), fashion industry (fi ne
skins, reptile hides, bird feathers), decorati-
ve items (elephant tusks, rhinoceros horns,
hawksbill products, hunting trophies) or pets
(exotic birds, big cats, reptiles, apes) (Camis
et. al., 2010), or through the exploitation of
fi ne woods, cacti or orchids (Sinovas et al.,
2017), in the case of fl ora species marketed
with higher profi t margins.
WWF/Dalberg (2012, p. 11) summarize the
value chain involved in the illicit traffi cking
of wildlife species and their parts:
5. Fernández, Lauxmann & Trevignani (2014, p. 614) characterize this dynamic in this way: “The value added by each of these activities and the
forms of appropriation/retention of the same allow to identify: a) central activities -those that absorb the most of the profi ts produced within
the chain; and b) peripheral activities -those that only appropriate a marginal portion of the benefi t- and, as a result, to notice the unequal
appropriation of benefi ts from the international exchange existing between them.”
Consumer country Country/countries of transit
Flow of products – the process can take place along the chain Country of origin
Medicines Local
Consumer goods
Individual local poacher Local
Regional intermediary and
international trader
Criminal groups Professional
hunters (national or international)
This has resulted in an important incentive
for all those countries located in the so-cal-
led “Global South”
5 –including those of La-
tin America and the Caribbean– and which
have attractive natural resources for such
markets, to substantially increase the cap-
ture, production and commercialization of
live specimens or their parts –fi ns, organs,
feathers, skins, meat, etc.– or the extraction and collection of forest and silvicultural pro-
ducts to satisfy demand.
This commercialization does not necessarily
entail the existence or development of an
institutional infrastructure for the manage-
ment of these resources, the realization of
scientifi c sustainability studies –which allow
for orderly exploitation– or the application

GTCT Corrupción Transnacional
6. More information available at
of a precise legal framework by authorities
with an optimal level of capacities. Rather, in
a considerable number of cases, these types
of operations turn into illicit traffi cking on a
transnational scale, and are integrated into
the operation patterns of organized crime
(UNODC, 2012). These activities result in a
growing need to make use of bribery, kickba-
cks, extortion, smuggling and other forms of
corruption, to avoid the control and oversi-
ght of the authorities, as well as to evade the
sanctions to which offenders may be subject.
However, there is also the possibility that the
exploitation and commercialization of a na-
tural resource does not necessarily mean a
serious impact on the stability or balance of
ecosystems or even contribute to the extinc-
tion of a species. In the legislation of each
country, there are provisions to allow the
legal import and export of species and their
derivatives, in a context of sustainable deve-
lopment, and with due attention to caring for
the environment (Valencia, 2018).
In principle, thanks to the work of interna-
tional organizations, Non-Governmental Or-
ganizations (NGOs), academic and scientifi c
groups, together with the participation and
commitment of governments, regulatory fra-
meworks have been established –which are
continually being updated– that would allow
to set the basis for the rational use of natural
These instruments are aimed at promoting
that the use of biological resources translates
into a real increase in the well-being of the
different sectors and social groups that parti-
cipate in the process, while protecting those
species that are at risk of extinction, as well as through information exchange and inter-
-state cooperation. It is relevant to highlight
the important contribution that the Conven-
tion on Biological Diversity has for these pur-
6 regarding the adoption of a series of
strategic objectives to conserve the species.
The most relevant example of this approach
is the Convention on International Trade in
Endangered Species of Wild Fauna and Flora
(CITES), an instrument that originated in 1973
and currently includes more than 180 mem-
ber countries (Nadal, et. al., 2013).
Thus, under the protection of the existence of
a formally legal trade, transactions are genera-
ted for the sale of species and their parts that,
in principle, would be under the protection of
the regulations applicable to the defense of
the environment. Specifi c technical problems,
such as the incorrect tariff classifi cation, or
inaccuracy in the taxonomic identifi cation of
a specimen/by-product to be exported, can
open up opportunities to circumvent regula-
tions and obtain profi ts by placing species at
risk on the international market.
However, it should be mentioned that the
application of such a wide-ranging regula-
tory framework, the high volume of trade,
the unusual levels of profi t generated by
some products and by-products, and the
willingness of certain actors in the process to
evade control measures, have resulted in the
commission of irregular activities, through a
growing exploitation of the weaknesses and
shortcomings still present in governmental
In this sense, potential offenders have oppor-
tunities to take advantage of the so-called
“legal loopholes,” in which the scope of the

GTCT Corrupción Transnacional
regulations is not exhaustive or explicit; the
gray areas, in which a wide level of discretion
in the interpretation and application of the
regulations is left to the government agent in
charge, or the technical, economic, scienti-
fi c, equipment and training limitations of the
competent authorities in charge of enforcing
the law.
Even more serious is the fact that other parts
of the capture, production, import and ex-
port processes, such as the determination of
quotas, the granting of licenses or the issu-
ance of certifi cates of origin of a commodi-
ty, to name a few, remain vulnerable to the
practice of corruption.
In such cases, government agents can re-
ceive anything from monetary offers to inti-
midation and threats from criminal organi-
zations, so that they can guarantee that the
goods are being traded legally. The result is
the uncontrolled exit of species and deriva-
tive products into the market that generate
additional pressures on the viability and con-
servation of certain biota that, due to their
fragility, are placed at high risk.
It should not be forgotten that the impact on
a species cannot be separated from the im-
pact it has on the ecosystem to which it be-
longs. For example, the imbalance in trophic
chains or pollinating agents can have expo-
nential effects in terms of the disappearance
of other associated species of wildlife (Coo-
ney et al., 2015), that is why the conservatio-
nist approach should not focus on particular
cases, but rather assume an overall view. In the same way, the protection of species
and ecosystems is not necessarily a matter
that is exhausted when reaching the border
of national states. Due to the transnational
nature of crimes against the environment,
as well as the international commerciali-
zation – legal or not – of these goods, it is
essential to recognize that the problem
must be addressed in all its manifestations
through cooperation, the exchange of infor-
mation and shared vigilance of the nations
that participate in the commercial process,
as countries of origin, transit or destination
(Reuter and Mosig, 2010). For this reason,
this may constitute a topic of study of inte-
rest to OLACEFS.
Finally, it is also necessary to determine
the way in which, from a bureaucratic
perspective, the actors involved in the di-
fferent processes and sub-processes in-
terrelate: the collector, hunter, breeder or
farmer, the producers of articles from the
species or its parts, carriers, warehouses,
the authorities in charge of issuing licen-
ses, permits and corresponding commer-
cial documentation, customs agencies,
tax officials, scientific advisers, importing
companies, distribution companies and
the final consumer. In effect, the legal
trade in species, unlike illegal trade, ge-
nerates a chain of documentary evidence
that links the actions to responsible offi-
cials and, consequently, can be subject to
scrutiny by the institutions in charge of
pulic auditing to determine the degree of
compliance with their mandates.


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Justifi cation
There is a wide variety of reasons for the
commercial use of wild fl ora and fauna spe-
cies of the different countries of the world.
For example, as environmental assets, they
constitute an important part of the econo-
mic heritage of nations, so that the actions
generated by their exploitation represent
sources of employment and, consequently,
of income, for the different actors that are
part of the commercial chains, as well as
sources of fi scal income for the States in the
form of fees for issuing permits, and taxes on
imports and economic activity. In this sen-
se, it is worth highlighting the importance
of ecotourism
7 as a desirable alternative or
model for the use of natural resources in a
sustainable way and that, additionally, re-
presents a considerable source of income for
the coun tries that offer it. These assets and
incomes are part of the public fi nances, and
therefore they are subject to governmental
control, internal and external.
On the other hand, the recurring situations
of economic crisis, unemployment and mar-
ginalization, with their resulting impacts on
the general welfare, represent an important
incentive to resort to this type of activity –
both in a clandestine and irregular manner,
as well as complying with the guidelines and requirements contemplated in the corres-
ponding legal frameworks– in order to obtain
income. High levels of profi t, concentrated
in the fi nal stages of the commercialization
chain, can lead to an overexploitation of the-
se resources, with highly damaging and so-
metimes irreversible effects on the mainte-
nance and conservation of ecosystems. Due
to the fact that the income received by the
direct producer of these goods tends to be
low, the implementation of policies for the
conservation and rational use of natural re-
sources, as well as the granting of govern-
ment incentives for the provision of environ-
mental services, could operate as effective
deterrents to involvement in traffi cking ne-
tworks if the profi t margin they offer exceeds
that of irregular operations.
Several nations have a considerable num-
ber of species of wild fl ora and fauna, which
places them as megadiverse countries; to
qualify as megadiverse, the country in ques-
tion must have at least 5,000 endemic plant
species and marine ecosystems (UN WCMC,
2020). In this case, there are seventeen sta-
tes: in the Latin American and Caribbean re-
gion are Brazil, Colombia, Ecuador, Mexico,
Peru and Venezuela while, in the rest of the
world, there is Australia, China, the United
7. An in-depth study of the subject is constituted by the WGEA document “Impact of Tourism on Wildlife Conservation” available in English at

GTCT Corrupción Transnacional
States of America, the Philippines, India, In-
donesia, Madagascar, Malaysia, Papua New
Guinea, Democratic Republic of the Congo
and South Africa.
As can be seen, a considerable number of
countries in Latin America –among which
stand out those that share the environment
of the Amazon, the largest region of tropical
forest on the planet– have important resour-
ces of wildlife that can be placed on the in-
ternational markets, which does not prevent
non-megadiverse countries from having
commercially important species, or from
operating as countries of origin or transit for
the export of species and their derivatives.
For this reason, the issue of governmental
external control regarding the legal export of
these goods falls within the area of interest
of all the SAIs of the nations that make up
the region.
On the other hand, it is necessary to empha-
size that the care of wildlife resources repre-
sents a transboundary and transgenerational
public good. Its administration constitutes a
commitment to not only sustainably address
current needs, but also protect the interests
and rights of future generations through the
implementation of public policies, legal-re-
gulatory frameworks and judicial systems
appropriate for this purpose, in tune with the
vision of sustainable development outlined
in the Brundtland Report, 1987
8 and the Rio
Declaration on Environment and Develop-
ment, 1992.
In addition, environmental protection re-
presents an international commitment,
framed in compliance with the 2030 Agen-
da for Sustainable Development. It is worth
highlighting Target 14.4 of Goal 14 “Unde-
rwater Life:”
… effectively regulate harvesting and end
overfi shing, illegal, unreported and unregu-
lated fi shing and destructive fi shing practi-
ces and implement science-based manage-
ment plans, in order to restore fi sh stocks in
the shortest time feasible, at least to levels
that can produce maximum sustainable yield
as determined by their biological characte-
As well as Target 15.5 of Goal 15 “Life of Ter-
restrial Ecosystems:”
Take urgent and signifi cant action to re-
duce the degradation of natural habitats,
halt the loss of biodiversity and, by 2020,
protect and prevent the extinction of thre-
atened species
The export of endangered species continues
to be a high-priority problem, and audits of
government control mechanisms can make
an important contribution to the detection of
risk areas, processes of interaction between
individuals and government bodies, and the
defi nition of the relevant actors involved in
the process. Public auditing thus constitutes
a key element in the fi ght against corruption
that may be generated in this activity, given
its privileged position to investigate the ma-
8. Available at
9. Available at

GTCT Corrupción Transnacional
nagement of state institutions in the rational
use of environmental assets, a relevant part
of the national heritage.
Given the magnitude of the universe sus-
ceptible to being subject to governmental
external control, as well as the limitation in
terms of available resources and the capa-cities of the audit staff in terms of technical
knowledge in the matter to carry out these
tasks, the defi nition of an adequate planning
methodology to guide the efforts of the SAIs
may mean a highly relevant contribution to
systematize the efforts carried out and thus
achieve a positive impact on the attention to
environmental issues.
PHOTO: Alex Steyn – Unsplash


GTCT Corrupción Transnacional
Basis for the preparation of the document
This instrument includes a series of methods
that SAIs can use to address the legal export
of wild fl ora and fauna species and their deri-
vatives that present a level of risk in terms of
the conservation of the region’s ecosystems,
and that could conceal acts of corruption at
the internal or transnational level, in order to
plan an audit on this issue.
For the preparation of this document, three
consultancies developed in 2021 by María
de los Ángeles Barrionuevo on the analysis
of the mechanisms underlying the legal ex-
port of wild fl ora and fauna species will be
used, focused on the selection of case stu-
dies, fl ow diagrams of operations and ma-
pping of relevant actors or stakeholders,
which together allow the determination of
specifi c aspects in which SAIs have the ca-
pacity to intervene.
The proposed approach would be to of-
fer methodological and analytical tools
that allow SAIs to define, in the strategic
planning stage of audits, the parts of the
process subject to governmental external
control that are most susceptible to acts
of corruption.
The audit of these critical nodes –such as li-
censing, permit granting, review and verifi –
cation activities or customs control and cle-arance measures, to name a few– as well as
the actions that the audited entities put into
practice to resolve the observations resul-
ting from governmental external control, can
help to combat the deterioration of wild fl ora
and fauna species at risk caused by formally
legal exports.
This text synthesizes the concepts expressed
by the author in three technical reports:
• “Consultancy to diagnose the suscepti-
bility to corruption of processes for legal
export of wildlife species: Selection of
case study, species and country;”
• “Consultancy to diagnose the suscepti- bility to corruption of processes for legal
export of wildlife species: Mapping of ac-
tors,” and
• “Consultancy to diagnose the suscepti- bility to corruption of processes for legal
export of wildlife species: Case Study.”
The methodology proposed by Barrionuevo
would then allow a rigorous selection of the
objects to be audited, i.e., which species
to start with, considering the risk factors in
the legal commercialization processes. All
this, with the aim of improving SAI reviews
of existing controls in government manage-
ment that facilitate this traffi c.

GTCT Corrupción Transnacional
This document addresses the defi nition of
the audit object, the defi nition of proces-
ses, the mapping of actors, a summary of the
practical case focused on the export of shark
derivatives from the Republic of Ecuador and the opinion of different governmental and
non-governmental organizations on the sub-
ject, as well as some fi nal considerations by
way of conclusion.

GTCT Corrupción Transnacional
Defi nition of the Audit Object
In integrating their annual audit programs,
SAIs use different methodologies to deter-
mine the reviews to be carried out. Given
that the potentially auditable universe brin-
gs together a very high number of actions
and operations in which the different gover-
nment agencies are involved, it is necessary
to carry out a strategic planning process, ba-
sed on appropriate methodologies and gui-
delines, so that the audits that the SAIs carry
out include relevant issues in terms of fi nan-
ce, social impact, interest of legislators, and
transcendence in public opinion and trans-
national relevance.
Each SAI independently determines the cri-
teria to be observed in its planning process,
taking into account elements such as ins-
titutional operational capacity –availability
of qualifi ed technical, fi nancial and human
resources; sources of information –which
represent an important input to determine
the viability of an audit; the results of in-
ternal control –which may show vulnerable
areas; the background information and re-
sults of past audits –which show recurren-
ces or unattended matters; the execution
of diagnostics –through the analysis of the
available data; the existence of risk factors
–that prioritize attention and resources to the most relevant or serious cases; or the
media impact –which may affect public
opinion and the interests of legislators, to
name a few.
In the event that wild fl ora and fauna spe-
cies become possible objects of audit, it is
also possible to defi ne guidelines that make
it possible to outline the existence of risk
issues, the availability of public informa-
tion or government or private entities that
can provide relevant data, or the existence
of legal instruments or specifi c public po-
licies oriented towards environmental pro-
In this sense, it is evident that, of the set of
species and their derivatives that are sub-
ject to commercialization processes, not all
have the same hierarchy in terms of the eco-
nomic importance of their exploitation, the
degree of vulnerability that each particular
species presents or the availability of infor-
mation about possible acts of corruption at
the national and transnational level in their
commercialization –especially in the case
of megadiverse countries. It is therefore ne-
cessary to establish some criteria that allow
the SAI to determine if there are possible ob-
jects of governmental external control whose
analysis is justifi ed on a cost-benefi t basis,
12. On this subject, it is suggested to consult the WGEA document “Environmental data: sources and options for Supreme Audit Institutions,
available in English at

GTCT Corrupción Transnacional
in terms of the volume of trade or the costs
that an audit would imply for the institution
to carry out.
Barrionuevo (2021a) proposes a series of gui-
delines that may be applicable at this stage
of the audit’s strategic planning process,
in order to delimit the universe of potential
subjects of audit and their hierarchy, as well
as support decision-making regarding con-
ducting an investigation. These criteria can
be divided into two themes: (1) the situation
of the wildlife species in particular and (2)
the existence of an effective regulatory and
institutional framework aimed at the protec-
tion of said species and their derivatives.
Regarding the fi rst group, the CITES classi-
fi cation is proposed for use in terms of the
degree of risk of the species, by resorting to
the three annexes of the Convention, which
show the status of the species. Article II of
CITES determines that:
1. Appendix I shall include all species threa-
tened with extinction which are or may be af-
fected by trade. Trade in specimens of these
species must be subject to particularly strict
regulation in order to not endanger their sur-
vival further and must only be authorized in
exceptional circumstances.
2. Appendix II shall include: a) all species
which, although currently not necessarily
endangered, could become endangered un-
less trade in specimens of those species is
subject to strict regulation in order to avoid
use incompatible with their survival, and b) those other species not affected by trade,
which must also be subject to regulation in
order to allow effective control of trade in the
species referred to in subparagraph a) of this
3. Appendix III shall include all species whi-
ch any Party states are subject to regulation
within its jurisdiction for the purpose of pre-
venting or restricting exploitation, and whi-
ch require the cooperation of other Parties in
the control of trade.
In this way, the SAI can determine, with the
technical assistance of local CITES offi ces,
national environmental authorities, NGOs or
academic groups, which species are inclu-
ded in CITES appendices I, II and III. This,
in order to effectively recognize the species
that are traded within the legal framework.
Similarly, verifi cation of CITES compliance
through a coordinated audit could serve as a
baseline for SAIs for subsequent planning of
control actions on the subject.
Additionally, the SAI can use the support of
academic institutions, NGOs, information
from the media or citizen complaints to de-
termine the existence of possible areas of
interest or open cases of commercializa-
tion –which, although formally legal, con-
ceal illegal acts– that merit the practice of
an audit by the authorities responsible in the
process of buying and selling a species or its
Regarding the regulatory and institutio-
nal framework criteria, Barrionuevo (2021a)
13. les/esp/disc/CITES-Convention-SP.pdf

GTCT Corrupción Transnacional
takes up the tools for the analysis of crimes
against wildlife and forests of the United Na-
tions Offi ce on Drugs and Crime (UNODC),
which were developed by the organizations
that make up the International Consortium
on Combating Wildlife Crimes (ICCWC), and
which allow determining the degree to which
each country has the necessary instruments
for the protection of wildlife species, in order
to select a case study among the countries of
Latin America and the Caribbean.
The proposed criteria are (1) if the country
is megadiverse; (2) if it is an active mem-
ber of CITES; (3) whether an administrative,
scientifi c or other authority has been de-
signated to facilitate the implementation of
CITES at the national level; (4) if there are
national strategies or specifi c public poli-
cies to reduce the traffi cking of illicit spe-
cies; (5) if there is information on the spe-
cies selected to be used by offi cials linked to the control of the crime; (6) if the coun-
try has signed bilateral or multilateral agre-
ements –such as the Lima Declaration on
Illegal Trade in Wildlife– to combat trans-
national crimes of this nature; (7) if there
is a link with illegal marketing networks for
these products; (8) if there are reports of
organized crime active in the traffi cking of
species –for example, in the media–, and
(9) if there are technical assistance and
aid programs to combat this crime, such as
regional or fi eld offi ces of the International
Criminal Police Organization (INTERPOL),
UNODC or the International Union for Con-
servation of Nature (IUCN).
These criteria can be used by an SAI to iden-
tify the complexity of the regulatory and ins-
titutional framework applicable to the audit
to be performed, as well as to know the pos-
sibilities of having the necessary support or
advice to carry out the investigation.
Jakob Owens – unsplash

PHOTO: Kevin Bessat – Unsplash

GTCT Corrupción Transnacional
Defi nition of processes and sub-processes
Once a wildlife species of interest has been
selected, it is necessary to analyze the pro-
cesses that its commercialization follows to
determine those critical points or nodes in
which the intervention of State agents or
institutions is vulnerable to the incidence of
corrupt practices and, therefore, susceptib-
le to governmental external control through
different types of audits: compliance, perfor-
mance, coordinated, or even forensic, in the
event of the presumption of any illicit act, in
accordance with the applicable regulations
for each control entity.
Both private and governmental actors inte-
ract in a production and commercialization
process; those who wish to carry out econo-
mic activity must adhere to the existing re-
gulations, undergo reviews and verifi cation
visits, process permits and licenses, obtain
the offi cial documentation necessary for the
collection, transport, transformation and sale
of articles of trade in the national market, or
the necessary permits to place the products
on the international market.
These are complex processes and sub-pro-
cesses in which the authorities must apply
the regulatory and legal frameworks that
exist at the national level and adhere to the
provisions of treaties, conventions and agre-
ements in the international sphere to which
their countries are party. The intervention of the different authorities, in principle, would
guarantee that the processes operate in a
normal way, with the generation of a com-
plete administrative fi le that allows follow-
-up on each case, as well as the necessary
inspections to verify compliance with the
applicable provisions.
However, it is precisely in the actions of go-
vernment agencies where it is possible to
identify weaknesses in terms of the possibi-
lity that, by omission, lack of technical know-
ledge and specialized training, or even ma-
lice, errors or omissions may be committed
that undermine the effectiveness of the ac-
tion of the instruments aimed at the protec-
tion of wildlife species at risk, and which may
be seriously affected as a result of their ove-
rexploitation. Barrionuevo (2021a) identifi es
the following among these types of actions:
… Government institutions and public offi –
cials or persons who hold public offi ce may be
involved in the illicit traffi cking of wild fl ora
and fauna species and in this way, directly or
indirectly, collaborate with traffi ckers. The
most frequent cases of association are rela-
ted to the breach of their duties or the abu-
se of power in the exercise of a position, the
inadequate custody of documents, the issu-
ance of fraudulent certifi cations and permits,
the failure to carry out controls or seizures,
the prevarication by action or omission that
generates a notorious lack of justice or sanc-

GTCT Corrupción Transnacional
tions for those who are involved in the crime
or bribery by omitting or not carrying out con-
trols or reviews that were under their respon-
sibility. These problems are aggravated by a
lack of information and training for offi cials,
a lack of experience that does not allow them
to adequately follow up the process, as well as
the overload of work they may have and which
limits the accuracy in the fulfi llment of their
functions. (p. 2).
These elements constitute critical nodes in
which SAIs can concentrate their investiga-
tive efforts since they are included in their
framework of attributions and contribute, if
corrected, to create a regulatory structure
and administrative praxis that are more resi-
lient to the onslaught of corruption.
It is now time to defi ne how to identify these
nodes in the legal commercialization of wil-
dlife species. The steps required to export,
for example, raw timber products, such as
ornamental products or fi nished furniture,
will not be the same as those required to
place live animals abroad for scientifi c pur-
poses; the marketing channels, the proce-
dures and permits required, the conditions
of collection and transport and complian-
ce with the legal framework of the country
where the importer/distributor or the fi nal
buyer resides, among other factors, may be
very different. It is therefore necessary to
divide a process into its respective sub-pro-
cesses, in order to identify how the actors
involved are interrelated and thus defi ne a
critical path covering all the relevant sta-
ges, which will provide greater clarity with respect to the intervention of governmental
external control.
Following Barrionuevo’s exposition (2021c),
in the case of wild fl ora and fauna species
and their derived products, it is feasible to
propose, in general terms, four sub-pro-
cesses in which it will be possible to detect
a series of critical nodes: (1) extraction au-
thorization, (2) extraction, (3) export autho-
rization and (4) export. Obviously, these sub-
-processes can be broken down, depending
on the type of operations in question and
the characteristics of the exported goods in
question; the proposal tries to represent the
minimum stages that need to be analyzed.
The table below includes the description of
the sub-processes and critical nodes that
could be subject to a review by SAIs.
Since the administrative processes and the
legal and regulatory requirements may vary
from country to country, the characteristics
of the process for the commercialization of
these goods must be determined; identify the
relevant authorities and learn their substan-
tive processes to determine the critical nodes
to concentrate on in the audit work and, with
this, optimize the use of resources and incre-
ase the impact that their fi ndings will have in
corrective and preventative terms.
The elaboration of fl ow charts allows a clear
visualization of the processes and of those
responsible for each stage, as can be seen
in the following diagram, generated by Bar-
rionuevo (2021c), for the investigation on the
export of shark fi ns from Ecuador:

GTCT Corrupción Transnacional
Process for Legal Export of Wildlife Species
Sub-process Description Critical nodes
1. Extraction
authorization Processing of the authorization, legal ac-
creditation or the necessary permits for a
natural person or legal entity, in order for
them to carry out certain extractive/pro-
ductive actions.
• Procedures for obtaining permits and
• ID of the legal representative
• Processes to review documentation or
address observations
2. Extraction Obtaining biological resources by autho-
rized individuals or legal entities, through
the capture, hunting or fi shing of speci-
mens and the obtaining of their by-pro-
ducts, the felling of timber resources or
the collection of certain species of wild
fl ora
• Control and monitoring of extractive
• Provisions to prevent evasion of controls
• Existence of institutional coordination
protocols between the different
authorities involved in the accreditation
and monitoring processes
• Detection of apocryphal documentation
or that falsifi es the volumes of the
obtained resource
• Taxonomic classifi cation of products
3: Export
authorization Processing of documentation for the
export of species, which implies obtai-
ning certifi cates of origin, application
of phytosanitary and zoosanitary stan-
dards, the allocation of export quotas,
the issuance of import and export au-
thorization of the species included in
any of the appendices of the CITES.
• Processes to obtain the necessary
documentation of the items to be traded
• Specialized advice regarding the
identifi cation of the species for the
issuance of CITES permits
• Tariff classifi cation of species or their
derived products
• Feasibility and cost of carrying out legal
procedures as an incentive for corrupt
practices to evade controls
4: Export Exit of the fi nal products through a cus-
toms agency, which involves elements
such as invoices, declaration of origin,
nature, composition, volume and desti-
nation of the cargo, corresponding tariff
treatment, storage and reviews, both in
the fi scal area and in the control area,
where merchandise destined for export is
• Presentation and validation of the
documentation necessary for export by
the customs authorities
• Carrying out inspections
• Accreditation of rules of origin for
• Tariff classifi cation
• International coordination with customs
authorities of transit and import countries
• Comparison of declared export and
import volumes

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Sub-process 1: Authorization to develop the fi shing activity
Natural personor legal entity
Step 1:
fi shingactivity authorization
Step 2:Review
authorization request
Step 3: Issue
authorization agreement Request with
observations Prepare
sí Is it
approved? Request
Flow Diagram
Graphic symbol Meaning
Party Responsible
for the Process
Flow Line


GTCT Corrupción Transnacional
Mapping of relevant actors
The fi ght against transnational corruption is
not the task of a single organization, since
the multiple facets that the problem pre-
sents require an international and multidis-
ciplinary approach, in order to juxtapose, in a
coordinated and institutional way, the efforts
of different actors – both state and private –
to help control this phenomenon.
In this sense, public auditing can play a very
important role in these processes, but it is
necessary to recognize that its action is li-
mited to a very precise area and has a spe-
cifi c scope: the practice of audits. Hence, an
articulated fi ght against corruption requires
the establishment of synergies with other
stakeholders, in order to enhance the im-
pact of the review work conducted by SAIs.
However, it is necessary to determine who may
have an identifi able interest or legal powers to
contribute concrete elements in this process;
therefore, it is necessary to identify the stake-
holders and the type of interaction that SAIs
can engage in with them.
For these purposes, Barrionuevo (2021b)
proposes a methodology to classify the ac-
tors involved, determine their level of cen-
trality and protagonism in the different
identifi ed sub-processes and establish the
relationships that link them to each other.
This methodology involves fi ve steps: (1) De-
fi nition of the Overall Objective; (2) Recog-nition and Classifi cation of Actors; (3) Iden-
tifi cation of Critical Nodes and Defi nition of
Objectives; (4) Generation of a Control-Con-
tribution Map; and (5) Representation of the
Relationships between Actors.
Step 1: Defi nition of the Overall Objective
consists of defi ning a plausible object to be
audited registered in the process for legal
export of wildlife species. It is recommended
to follow the indications proposed in Section
IV of this Guide, making use of CITES infor-
mation regarding the status of endemic spe-
cies in each nation and that provided by the
media, academia, citizen complaints, inter-
national organizations and NGOs.
Step 2: Recognition and Classifi cation of
Actors, the SAI will defi ne, through the analy-
sis of the existing information, the applicable
legal framework and the attributions of diffe-
rent public agencies related to the process to
be audited, and corresponding to the geogra-
phical, political and administrative context of
each country. The following actors will be iden-
tifi ed who, according to Barrionuevo (2021c),
… have information, resources or experien-
ce to contribute in the prevention, control
and monitoring of the activity… have, in the
exercise of their duties, the responsibility and
capacity to implement actions, as well as re-
gulate and generate norms to intervene in the
administrative and legal processes linked to
the control of corruption (p. 6).

GTCT Corrupción Transnacional
Once the relevant actors have been determi-
ned, they will be classifi ed into three groups:
i) Public Institutions –SAIs, ministries, de-
centralized or deconcentrated bodies, na-
tional institutes, and customs, military, and
police authorities; ii) International and In-
tergovernmental Organizations and NGOs –
of all types, sizes and scope; and iii) Private
Sector –academic and research groups, ar-
tisan or industrial producers, marketers, and
Step 3: Identifi cation of Critical Nodes and
Defi nition of Goals is based on breaking the
main process down into the sub-processes
that compose it and the defi nition of the criti-
cal nodes that are likely to be affected by cor-
ruption, as stated in Section V of this Guide.
To do so, a specifi c objective will be assig-
ned for each identifi ed sub-process in order
to identify the actions that are included in
the legal mandate of each SAI – conducting audits, evaluating public policies, reviewing
the applicable internal control mechanisms,
proposals for the improvement of performan-
ce, inter-institutional coordination actions,
etc.– and that can effectively contribute to
strengthening prevention and control ac-
tions by the different actors involved.
In Step 4: Generation of a Control-Contri-
bution Map, once the actors and institutions
have been classifi ed and the critical nodes
have been identifi ed by sub-process, it will
be possible to visualize what control and su-
pport capacity they can offer to the activities
of prevention and control of acts of corrup-
tion in legal exports of wildlife species. Bar-
rionuevo (2021b) proposes that the different
actors are placed in the four quadrants for-
med by a Cartesian plane in which the abs-
cissa axis (x) represents the level of control
–high or low– and the ordinate axis (y) the
level of support –equally high or low.
Quadrant II (-,+) Quadrant I
Quadrant III (-,-) Quadrant IV

GTCT Corrupción Transnacional
Directly responsible
• Quadrant I Actors
Participation and Collaboration
• Quadrant II Actors
Not Involved in the Process
• Quadrant III Actors
The use of this resource will make it possib-
le to locate those directly responsible –and
their degree of incidence– in each sub-pro-
cess, as well as the actors and institutions
that can provide direct or indirect support.
In Quadrant I, will be placed the actors with
competencies and legal powers for the pre-
vention and control of corruption; it is on the-
se actors that SAIs (which are always located
in said Quadrant) should focus their review
efforts on verifi cation and evaluation of com-
pliance with their administrative functions.
In Quadrant II, will be placed the actors with
the potential to support prevention and con-
trol actions carried out by SAIs, usually in-
ternational organizations and NGOs, through
the exchange of information, training of offi –
cials, contribution of economic resources for
investigations or strengthening of monito- ring systems. In Quadrant III, public or priva-
te actors will be assigned that, although they
have a more relative or tangential interest in
the different sub-processes, may eventually
provide some kind of support; and, fi nally,
Quadrant IV could contain government ac-
tors with no major link to the process, which
is not frequent.
Step 5: Representation of the Re-
lationships between the Actors implies the
graphic representation of the relationships
between the actors involved in each sub-
-process, as well as their degree of centrality
in terms of responsibility for controlling acts
of corruption, following the classifi cation
based on the four Quadrants of the previous
step and using, this time, a concentric circle

GTCT Corrupción Transnacional
Higher Education Institutions
Other SAIs
Means of
Authority Ministry
of Finance
Ministry of
Symbol Type Description
Continuous lineClose ties (exchange of information, frequency of contact, coin-
cidence of interests, coordination, mutual trust) and cooperative
Dotted Line
Weak or informal ties
Red lineTensions in ties, confl icting interests, confl ictive relationships
ArrowDirection of ties
Once the actors of each sub-process
have been included in their respective
places on the graph, the relationships between them are represented using the
following symbols, adapted by Barrio-
nuevo (2021c):
It should be mentioned that since the ac-
tors that are in the outer circle do not par-
ticipate in the sub-process, it is not neces-
sary to graph their relationship to the other
actors. A simplifi ed example of the graphical re-
presentation of the relationships between
actors that have the objective of controlling
acts of corruption related to the sub-process
of wildlife species export could be as follows:
One can distinguish, for example, the links
derived from the process of governmental
external control from the SAI to offi cial en-
tities, an occasional input from the media to
the SAI; the possibility of carrying out a co-
ordinated audit with SAIs of other countries,
a hostile relationship of an NGO towards the
governmental bodies in charge of avoiding
corruption in the sub-process, or the su-
pport of CITES for the fulfi llment of the provi-
sions for the care of the species.

GTCT Corrupción Transnacional
Barrionuevo (2021b) concludes with the re-
minder that this type of exercise makes it
possible to illustrate the state of a constella-
tion of relationships at a given time and in a
given space; the assessments regarding the
role played by the different actors and their
way of relating can be modifi ed depending
on the existence of a level of subjectivity on
the part of the person carrying out the analy-
sis, or on the availability of more precise in-
formation, which allows for a greater degree
of accuracy in the assessment.
Additionally, it must be taken into account
that SAIs, by themselves, do not have the ca-
pacity to contain the phenomenon of corrup-
tion or limit it in an absolute way; the use of
graphic resources makes it possible to show
the considerable number of actors involved,
as well as the way in which they interact.
Finally, this type of exercise offers a clearer
visualization of the levels of responsibility,
and the identifi cation of key actors that SAIs
must take into account in the development
of their audits. On the other hand, the gene-
ration of knowledge derived from the privile-
ged position occupied by those in charge of
governmental external control to know how
these processes operate in depth can serve
as an important input in terms of advice to the other participating entities; the inter-
-institutional exchange of information –with
due attention to the provisions on confi den-
tiality– represents an important tool to ad-
vance in the abatement of irregular practi-
ces that affect the environment.
As texts of interest, complementary to the
elements proposed here, it is recommen-
ded that the following technical documents
developed by the WGEA be reviewed, among
others: “Addressing Fraud and Corruption Is-
sues when Auditing Environmental and Na-
tural Resource Management: Guidance for
Supreme Audit Institutions”
14; “Auditing Bio-
diversity: Guidance for Supreme Audit Insti-
15; as well as its 2019 update in En-
16; “Environmental Accounting: Current
Status and Options for SAIs”
17; “Evolution and
Trends in Environmental Auditing”
18; “Coope-
ration between Supreme Audit Institutions:
Tips and Examples for Cooperative Audits”
“Environmental Audit and Regularity Audi-
20; “Guidance on Conducting Audits of
Activities with an Environmental Perspecti-
21; “Auditing International Environmental
22; “Forms of Collaboration of
SAIs in Auditing International Agreements
on the Environment”
23; and “Auditing Forests:
Guidance for Supreme Audit Institutions”
14. Available in English at


GTCT Corrupción Transnacional
 Practical example: the commercialization of 
the Ecuadorian shark
The theoretical and methodological elements
raised by Barrionuevo (2021c) regarding the
impact of corruption in the processes for le-
gal export of wildlife species are derived from
her research on the problems surrounding
the exploitation and trade of shark fi ns in the
survival of different species of shark that live
both in the 12 nautical miles of the territorial
sea and in the 200 of the Exclusive Economic
Zone of the Republic of Ecuador.
The shark, despite being a central part of
the food chain that maintains the stability
and conservation of marine ecosystems, has
become a merecommodity, a good to satisfy
the needs of essentially foreign markets. Al-
though the meat and cartilage of this orga-
nism have a certain economic value, shark
fi ns represent millions of dollars in trade
when they are placed in Asian markets, the
main consumers of these goods. For this rea-
son, sharks have become the target of inten-
se fi shing activity, in order to obtain a consi-
derable profi t margin, mainly in the fi nal part
of the commercial cycle.
The lucrative nature of this trade still makes
it possible to ignore, among those who fi sh
this species, the cruelty and destructiveness
of this work, symbolized by the “fi nning” pro-
cedure, through which sharks are caught to cut off their appendages and return them
mutilated to the sea, where they invariably
die of exsanguination and suffocation. Dis-
patching a shipment of 100,000 fi ns presu-
pposes, for example, the sacrifi ce of 25,000
specimens. Such practices are not sustaina-
ble and put a considerable number of shark
species at risk.
The country has a broad institutional appa-
ratus and a broad legal framework for the
protection of its environmental assets. Ar-
ticles 10 and 71 of the Constitution of the
Republic of Ecuador recognize nature as a
subject of rights; likewise, the applicable
law –Regulation of the Organic Code on the
Environment– in line with the commitments
assumed within the scope of CITES, repre-
sent considerable efforts to prevent the irre-
gular exploitation of different shark species.
Additionally, the Comprehensive Organic
Criminal Code provides penalties of depriva-
tion of liberty of 1 to 3 years for the capture,
transport or commercialization of protected
species. Although the Organic Law for the
Development of Aquaculture and Fisheries
and Executive Decree No. 486 determine the
prohibition of directed fi shing of ten shark
species; they contemplate the possibility
that, in the event that specimens are caught

GTCT Corrupción Transnacional
incidentally in the course of fi shing for other
species, it is legal to give a commercial use
to the species or their derivatives, provided
that the requirement to report these catches
to the inspectors is met.
The Ministry of the Environment and Water,
the Ministry of Production, Foreign Trade,
Investment and Fisheries (MPCEIP), and the
National Customs Service of Ecuador, contri-
bute, in their respective areas of responsibili-
ty, to control the use of this natural resource;
meanwhile, the Ecuadorian Navy supervises
the process of leaving the ports and can car-
ry out periodic and random inspections of
fi shing vessels on the high seas. There are
also public policies and programs such as
the National Action Plan for the Conservation
of Sharks, the Program to Improve the Com-
petitiveness of the Aquaculture and Fishe-
ries Sector and the Shark Action Program.
However, the national and international
press, as well as different NGOs, continue to
denounce cases in which it is evident that
there is an overexploitation of the resource
as a result of different practices for its sale
abroad, not only by local fi shermen and tra-
ders on an artisanal or industrial scale –and
who, in principle, have the permits and li-
censes to carry out these types of activities,
issued by the responsible authorities– but
by fl eets from other countries that operate in
Ecuadorian waters, and that have developed
different practices to evade the inspection
and control actions of the authorities.
The enormous discrepancy between the vo-
lumes of fi ns located in warehouses in the
national territory or in importing countries, and those reported to the authorities as a re-
sult of incidental fi shing of shark in Ecuador,
makes it possible to deduce the existence
of defi ciencies or failures in the activities of
control, attributable from the limitation of
material and human resources to carry out
the actions required by the regulations, to
the possibility of alleged acts of corruption.
Based on the proposed methodology, Bar-
rionuevo (2021c) divides the process for the
export of sharks and their parts into fi ve sub-
-processes, which in turn allow the detection
of different critical nodes that could be affec-
ted by corruption and, therefore, become the
object of public auditing.
The fi rst sub-process refers to the proce-
dures to obtain authorization to carry out
fi shing activities. The MPCEIP receives the
application, reviews the documentation,
and issues a ministerial authorization agre-
ement, or else makes observations to be ad-
dressed by the applicant. The critical nodes
to observe are the obtaining of the certifi ca-
te and the due accreditation of the legal par-
ty responsible.
The second sub-process covers the extrac-
tion of hydrobiological resources: it begins
with the authorization to set sail –granted
to fi shermen who have the corresponding
permits– by the Ecuadorian Navy through
the port captain’s offi ce, and provides for the
carrying out of inspections of both fi shing
and gear manifested as offi cial documen-
tation, through inspection personnel of the
Navy or of the MPCEIP itself, and who must
report any irregularity. The critical nodes are
the control and monitoring actions, the de-

GTCT Corrupción Transnacional
tection of practices of evasion of said con-
trols and the inter-institutional coordination
processes, which can hinder the oversight
and control tasks if they are not carried out
The third sub-process corresponds to the
report of incidental fi shing of sharks; since
the commercial use of shark is only allowed
if it was caught while fi shing for other spe-
cies, the fi sherman must notify the MCPEIC
inspectors to obtain a monitoring certifi ca-
te, which includes the species of the speci-
men and the volume landed, as well as the
corresponding mobilization guide, so that
these products can be sold. The critical no-
des identifi ed are the detection of disguised
fi shing, the control of the fi shing landing,
and the inspection of the product.
The fourth sub-process covers obtaining
authorizations for export; the fi sherman
processes the necessary certifi cates; in the
case of species included in any of the CI-
TES appendices, including the applicable
criteria of the scientifi c authority, the cor-
responding authorization must be obtained
through the MPCEIP. Likewise, the Certifi ca-
te of Legal Origin for Fishery Products and
the export authorization are required. As
critical nodes, the possibility was detected
that the excess of procedures operates as
an incentive to seek clandestine or fraudu-
lent means to be able to commercialize the
fi shery product abroad, as well as the tech-
nical diffi culties involved in the identifi ca-tion and tariff classifi cation of species deri-
vatives at risk.
The fi fth sub-process, with which the main
process closes, refers to the export of the
species. The exporter issues a Customs Ex-
port Declaration, which includes a descrip-
tion of the merchandise, details of who con-
signs the load, destination, quantities and
weight; to this is added the invoice and the
documentation of the shipment. The mer-
chandise is checked through documents or
physically by Ecuadorian Customs, where, if
the requirements are satisfi ed, it will grant
the exit authorization. Obviously, critical no-
des refer to the oversight and control of cus-
toms personnel, including inspections and
the issuance of the corresponding documen-
tation; it is also necessary to determine the
level of international cooperation available
since the customs authorities of the impor-
ting country continue the process and can
provide information that allows the follow up
of shipments across national borders.
The application of the rest of the methodolo-
gy suggested by Barrionuevo (2021b) regar-
ding the identifi cation of the relevant actors,
the defi nition of their roles and the charac-
terization of their interactions in each sub-
-process, will allow a systematic approach
to the subject of the audit, which will allow
focusing the effort of the public auditing on
those aspects that may have a greater im-
pact on the possibility of committing acts of
corruption in the process.


GTCT Corrupción Transnacional
Opinions of specialized organizations
Different organizations, both in the public
and private spheres, represent potential
strategic supports for governmental ex-
ternal control efforts. The technical expe-
rience they have accumulated over time,
as well as the networks they have esta-
blished with international organizations,
groups of academics and researchers and
civil society actors, as well as the prestige
they enjoy among different sectors, makes
them valid interlocutors and sources of in-
formation relevant to SAIs, which some-
times do not have the qualified staff ne-
cessary to undertake, autonomously, the
analysis of environmental conservation and
care issues.
This section summarizes the responses of
two organizations interested in the com-
mercialization of wildlife species, the Wil-
dlife Conservation Society Andes-Amazon
& Orinoco (WCS) Regional Program and the
MarViva Foundation (MarViva), to different
questions about the actions they develop on
the matter in the Latin American and Cari-
bbean region.
What should SAIs and the international
community do to work collaboratively to pre-
vent corruption in the traffi cking of marine
species?WCS: We work to address wildlife traffi cking
in origin, transit and consumer countries,
focusing on Asia, Africa and Latin America,
with a permanent presence in the Amazon
through national programs in Colombia,
Ecuador, Peru, Brazil and Bolivia, to improve
the understanding of the dynamics of wildli-
fe traffi cking, strengthen the capacity of the
actors involved in control and investigation,
offer support for the development of policies,
facilitate national and international coope-
ration, and carry out preventative actions
with civil society to reduce illegal demand,
among others.
MarViva: There must be a real regional
diagnosis that allows analyzing the causes
of corrupt acts, as well as the magnitude
of the diversion of resources, the manage-
ment of legal species and the identifi cation
and assessment of all the actors involved
in this chain. It is essential to carry out an
evaluation on the types, patterns and im-
pacts of corruption nodes, which facilitates
the exchange of information between SAIs
at the regional level and has a joint pers-
pective of the problem. It is essential to
share and analyze information transnatio-
nally, and to identify fraudulent documen-
tation across borders. The Central Ameri-
can Integration System (SICA), the Central

GTCT Corrupción Transnacional
American Commission for Environment and
Development, the Pacifi c Alliance and the
Mesoamerican Strategy for Environmen-
tal Sustainability (EMSA) can serve as the
basis for SAIs to train staff on corruption
issues and improve the knowledge and
ethics of the offi cials, as well as generating
greater coordination between the fi sheries
and customs authorities. Financial investi-
gation is essential to follow up on resour-
ces and detect the actors in the corruption
chain who are profi ting from it. To achieve
this, the security and traceability of fi nan-
cial information systems and their elec-
tronic records must be protected, verifi ed
and preferably automated. Corruption also
thrives because of the lack of opportunities
in rural communities. Illegal activity links
communities through improper payments
to facilitate the illegal capture of marine
fauna, so strategies must be created that
strengthen the social fabric of these mar-
ginalized communities and generate in-
come opportunities through projects and
investments that make marine life conser-
vation cost-effective. SAIs should create
community alliances to increase the spec-
trum of control mechanisms and outsource
their work to make it more effective.
Does your institution have ongoing projects
to combat wildlife and/or marine traffi cking?
WCS: WCS currently executes several fede-
rally funded projects from the United States
government through its offi ces of the Fish
and Wildlife Service and the Bureau of In-ternational Narcotics and Law Enforcement
Affairs (INL), as well as the British and Eu-
ropean Union Governments. Currently, with
the INL, we have implemented two projects
at the Latin American level: (1) to improve
the legislative and regulatory frameworks
related to wildlife, train the authorities of
the judicial sector and the forces of civil or-
der in order to prevent, investigate and take
legal action against poaching and illegal
traffi cking, as well as improve cooperation
in countries in order to detect, investigate
and prosecute criminal organizations invol-
ved in wildlife traffi cking, and (2) strengthen
the investigative and law enforcement ca-
pacities of authorities to improve synergies
between government agencies to combat
international and cross-border wildlife traffi –
cking in Peru and Ecuador, with an emphasis
on marine wildlife, by improving cross-bor-
der cooperation and information sharing to
investigate illegal wildlife trade networks, as
well as strengthening anti-corruption efforts
within relevant government agencies and
improving accountability for illegal wildlife
trade in Peru and Ecuador.
MarViva: Currently, there is an ongoing follow
up of the proper implementation of the CITES
Convention by national authorities. Recently,
MarViva challenged, through contentious-
-administrative actions, the granting of ex-
port permits for wildlife species of fi shery
interest included in the CITES Appendix II,
since the authority granting these permits
is legally disqualifi ed from doing so. Legal
actions continue to be promoted in order to

GTCT Corrupción Transnacional
ensure the effective exercise of the right to
public participation in this matter, as well
as the prevalence of scientifi c evidence as
a guiding criterion for decision-making on
international trade in species protected by
the CITES. Likewise, the ratifi cation of the
AMERP is sought to provide the competent
authorities with the mechanisms and pro-
tocols that allow them to act if events of il-
legal fi shing occur in cold storage, means
of transport and confi nement of vessels, as
well as to standardize the inspection requi-
rements and information at ports of landing
regarding fi shery catches. We seek to requi-
re minimum information requirements in the
labeling of fi shery products to ensure trans-
parency for the consumer, informed deci-
sion-making and the conservation of fi shery
Is there a project led by your institution in
the fi ght against wildlife and/or marine traf-
fi cking in which the Supreme Audit Institu-
tions could collaborate?
WCS: With the fi nancial support of the Euro-
pean Union, WCS leads a regional initiative,
in collaboration with WWF, called the “Allian-
ce for Wildlife and Forests.” The success of
this initiative depends on the active and per-
manent participation of multiple actors from
civil society, public sector entities and the
private sector. The participation of SAIs in
the region, and especially the GTCT, can play
a key role in strengthening the capacities of
states to effectively combat wildlife traffi –
cking.Comment on the importance, verifi cation
and improvement of internal controls in the
legal processes of commercialization of ma-
rine life.
WCS: The participation of State entities is
essential. The administrative, regulatory and
control institutions, as well as law enforce-
ment agencies and justice operators, par-
ticipate actively in the projects led by WCS.
However, work must still be done at the exe-
cutive branch level so that there is greater
attention and support, especially fi nancial,
to the different entities that are currently
joining the efforts to combat wildlife traffi –
cking. The participation of public offi cials in
illegal activities must be detected, investi-
gated and sanctioned in order to dismantle
possible organized networks that promo-
te or facilitate wildlife traffi cking from sta-
te institutions. In this sense, SAIs have the
task and responsibility of reviewing, auditing
and investigating possible weaknesses in
the public management systems of entities
related to wildlife management or directly
with activities for the prevention and control
of crimes against nature, including wildlife
traffi cking, for the purpose of correcting and
strengthening them.
MarViva: Cooperative work between envi-
ronmental and fi scal institutions, together
with police and surveillance activity at bor-
der controls, generates a network of infor-
mation on the origin of the species traded.
However, the effectiveness of these control
protocols lies in the commercialization tra-

GTCT Corrupción Transnacional
ceability system that they manage to con-
solidate. Many challenges remain regarding
the management of corruption in the legal
traffi cking of species: many countries do not
have an informative label that guarantees
the consumer that the product comes from
a legal and sustainable commercialization
chain. There is an urgent need for coordi-
nation between the control of species traf-
fi cking and their commercialization to gua-rantee the effective protection of marine life
from illegal fi shing activities. It is essential
that, in each domestic legislation, species
traffi cking and corruption related to mari-
ne life are classifi ed as punishable behavior,
and that the judicial system ensures that
those responsible are brought to justice; the
training of prosecutors and judges can be ef-
fective in facilitating the analysis of evidence
and the execution of sentences.
FOTO: Nariman Mesharrafa – Unsplash

GTCT Corrupción Transnacional
The link between issues of corruption and
deterioration of the environment has beco-
me a concern with greater presence among
public opinion and government programs
and policies; a greater incidence of alterna-
tive communication media, the greater avai-
lability of information, and the incidence of
international organizations, citizen groups
and NGOs, has placed this complex problem
on the public agenda of different countries.
In this sense, a greater sensitivity of SAIs to
environmental issues, as well as a greater
scientifi c and technical preparation of their
auditors, will translate into a presence with
greater impact for these institutions.
It is reasonable to assume that practically
all the countries of the Latin American re-
gion have faced, or are facing, different pro-
cesses of environment impact derived from
human activity; in the most extreme cases,
the existence of certain species is seriously
threatened. The disappearance of a species
has a multiplier effect in terms of destabi-
lizing the balance in an ecosystem, so that
current losses guarantee, in some way, fu-
ture ones. It is therefore a priority, as an act
of responsibility in the face of current ne-
eds and the interests of future generations,
to reverse these processes through greater
vigilance and establish conditions for sus-
tainable development, especially in terms of closing the opportunities exploited by com-
mitting corrupt actions. The SAIs, must act
in a coordinated manner with those bodies
and public and private organizations, natio-
nal and abroad, with an interest in the sub-
ject, as well as with elements to assist in the
integration of a coordinated strategy to atta-
ck this problem.
The elements provided in this text, as well
as the analysis of Barrionuevo’s research do-
cuments that constitutes its basis, offer the
user the necessary elements to be able to
replicate, in their scope of action, and with
respect to a theme specifi c to their geogra-
phical space, the steps followed to determine
the object, scope and relational environment
of an audit, whose nature –compliance, fi –
nancial, performance, coordinated, foren-
sic– will correspond to the type of approach
that is intended to be given to the process:
preventative, in order to detect weaknesses
and correct them in a timely manner, or cor-
rective, if it is necessary to determine res-
Over time, SAIs in the region have accu-
mulated growing experience in the fi eld
of environmental audits, however, in spite
of their relevance, there are still important
areas of opportunity in terms of the integra-
tion of specialized areas on the topic. Hence
the importance of establishing institutional

PHOTO: Benjamin Suter – Unsplash
links with different groups and organizations
that can offer important inputs, information
and training to auditing bodies. Public audi-
ting is called upon to play a key role in the
process of reducing the corruption that en-
dangers the survival of wild flora and fauna
species. In order to meet this expectation, it is necessary to capitalize and transform the
results of academic research into applicab-
le instruments; hence the GTCT reiterates its
commitment to make proposals, such as the
one contained in this document, available to
the Latin American and Caribbean auditing

GTCT Corrupción Transnacional
List of Acronyms
CBDConvention on Biological Diversity
CITES Convention on International Trade in Endangered Species of Wild Fauna and
COMTEMA Comisión Técnica Especial de Medio Ambiente de la OLACEFS (OLACEFS
Special Technical Commission on the Environment)
GIZ Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
GTCT Grupo de Trabajo de la OLACEFS Especializado en la Lucha contra la
Corrupción Transnacional
(OLACEFS Specialized Working Group in the Fight against Transnational
ICCWC International Consortium on Combating Wildlife Crime
INL Bureau of International Narcotics and Law Enforcement Affairs
INTERPOL International Criminal Police Organization
INTOSAI International Association of Supreme Auditing Institutions
MPCEIP Ministerio de Producción, Comercio Exterior, Inversiones y Pesca del Ecuador
(Ministry of Production, Foreign Trade, Investments and Fisheries of Ecuador)
OLACEFS Organización Latinoamericana y del Caribe de Entidades Fiscalizadoras
Superiores (Organization of Latin American and Caribbean Supreme Audit
NGOs Non-Governmental Organizations
ONU United Nations
IUCN International Union for Conservation of Nature
SAI Supreme Audit Institution
UNODC United Nations Offi ce on Drugs and Crime
WCS Wildlife Conservation Society
WGEA Working Group on Environmental Auditing
WWF World Wide Fund for Nature

GTCT Corrupción Transnacional
2030 Agenda
Global action plan for people, planet and pros-
perity, based on seventeen Sustainable Deve-
lopment Goals, which aims to ensure sustai-
nable social and economic progress worldwide
and strengthen universal peace within a broa-
der concept of freedom.
Variability of living organisms from all sources,
including, inter alia, terrestrial, marine and
other aquatic ecosystems and the ecological
complexes of which they are part; includes di-
versity within species, between species and of
Bonded warehouse
A place administered by private individuals
under concession from the customs authority
for private individuals to provide the handling,
storage and custody services for merchandise.
Compliance audit
Independent evaluation to determine if a mat-
ter complies with the applicable authorities
identifi ed as criteria evaluating whether the
activities, fi nancial operations and informa-
tion comply, in all material respects, with the
authorities governing the audited entity.
Coordinated audit
Form of collaboration between SAIs to exer-
cise control over issues of an international or
regional nature that are of interest to the cou-
ntries involved.
Environmental asset
An element incorporated into the assets of an
entity for the purpose of being used on a las-
ting basis in its activity, the main purpose of
which is to minimize environmental impact
and protect and improve the environment, in-
cluding the reduction or elimination of future
pollution from the entity’s operations.
Environmental audit
Review of environmental assets and liabilities,
compliance with legislation and conventions
–both international and domestic– as well as
measures instituted by the audited entity to
promote economy, effi ciency and effective-
Fiscal precinct
Physical places where the customs authorities
indistinctly carry out the functions of han-
dling, storage, custody, loading and unloading
of foreign trade merchandise, inspection, as
well as customs clearance of the same.

GTCT Corrupción Transnacional
Forensic audit
Audit methodology that involves a rigorous
and detailed review of processes, facts and
evidence, in order to document the existence
of an alleged irregular act.
Governmental external control
Process by which the authority monitors the
use of public resources to evaluate and review
the actions of the government considering
their veracity, rationality and adherence to
the law; review of the effi cient and effective
functioning of the planning, organization and
execution of the public administration.
Performance audit
Objective and reliable review of whether pu-
blic policies are operating under the principles
of effectiveness, effi ciency and economy.
Phyto and zoosanitary standards
Measures to ensure the safety of food products
intended for human consumption and to pre-
vent the spread of pests or diseases among
animal and plant species.
Rules of origin
Criteria necessary to determine the national
origin of a product; their importance is explai-
ned by the fact that the duties and restrictions
applied to imports may vary according to the
origin of the imported products.
Species traffi cking
Legal and illegal trade in wild animal species
and/or their derived products. Illegal wildlife
traffi cking encompasses the sale, smuggling,
capture or collection of endangered animals,
protected wildlife (fauna and fl ora, subject to
quotas and regulated by legal permits), poa-
ching, their derivatives or products, in contra-
vention of national and international laws and
Tariff classifi cation
Assignment of a numerical code of a recogni-
zed nomenclature to the merchandise, so that
each and every one of them can be classifi ed
under some tariff heading, with its correspon-
ding import and export tariff.
Transnational corruption
The offering of an undue pecuniary or other
undue advantage to a foreign public offi cial,
for his or her benefi t or for the benefi t of a
third party, so that this agent acts or refrains
from acting in the performance of offi cial du-
ties, with a view to obtaining or preserving a
market in international trade.

GTCT Corrupción Transnacional
• Barrionuevo, M. (2021a). Consultancy to diagnose the susceptibility to corruption of processes for legal export of wildlife species: Selection of the Case Study, Species and Country.
• Barrionuevo, M. (2021b). Consultancy to diagnose the susceptibility to corruption of processes for legal export of wildlife species: Mapping of actors.
• Barrionuevo, M. (2021c). Consultancy to diagnose the susceptibility to corruption of processes for legal export of wildlife species: Case Study.
• Camis, I., Casanova, C., Brizi, L. (2010). International trade in exotic species: black market, March 29, 2021, from the website
of Universitat Autónoma de Barcelona:
• CITES (1973) Convention text, March 29, 2021, from the website: les/
• Cooney, R., Kasterine, A., MacMillan, D., Milledge, S., Nossal, K., Roe, D. and S., ‘t Sas-Rolfes, M. (2015). Trade in Wild Fauna and Flora: A Framework for Improving Sustainable Use of Biodiversity
and Livelihoods. Centro de Comercio Internacional
• Fernández, V., Lauxmann, C. & Trevignani, M. (2014). Emergence of the Global South. Prospects for the development of the Latin American periphery. Economia e Sociedade, 23, 3 (52), p. 611-643.
• Nadal, L., Antero, O. and Trouyet, M. (2013). Illegal wildlife traffi cking. Secretaría de Medio Ambiente y Recursos Naturales.
• United Nations (UN). Sustainable Development Goals, March 29, 2021, from website https://www.
• Reuter, A. and Mosig, P. (2010). Trade and use of wildlife species in Mexico: observations on management, trends and related challenges. Mexico, Ofi cina de México de TRAFFIC Norteamérica.
• Sinovas, P., Price, B., King, E., Hinsley, A. and Pavitt, A. (2017). Wildlife trade in Amazonian countries: analysis of trade in CITES-listed species. Technical report prepared for the Amazon Regional Program
(BMZ / DGIS / GIZ). Cambridge, UN Environment – World Conservation Monitoring Centre.
• UN WCMC (2020). Biodiversity a-z, March 29, 2021, from website:
content/megadiverse-countries.pdf .
• UNODC (2012). Transnational Organized Crime – The Globalized Illegal Economy, March 29, 2021, from website: .
• Valencia, C. (2018). Wildlife in Colombia: between illegality and international trade opportunities in CITES. Virtual Magazine Universidad Católica del Norte, 55, (128-145).
• WWF / Dalberg (2012). The Fight Against Illicit Wildlife Traffi cking: A Consultation with Governments. Switzerland: WWF International.

GTCT Corrupción Transnacional
Presidency of OLACEFS
Contraloría General de la República del Perú
Executive Secretariat of OLACEFS
Contraloría General de la República de Chile
Presidency of the Specialized Working Group in the Fight against Transnational Corruption Contraloría General del Estado de la República del Ecuador
Entity responsible for the contents of this publicatio n
Working Group Specialized in the Fight against Transnational Corruption
Graphics project, cover, layour, and revision
Project Strengthening External Control in the Environmental Field. Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
Contraloría General del Estado de la República del Ecuador Av. Amazonas N35-181 y Japón. Quito – Ecuador (593) 2 3987-310

Corrupción Transnacional
OLACEFS is an autonomous, independent and apolitical body, created
as a permanent organization in charge of performing specialized
scientifi c research functions and of developing study, capacity building,
professional qualifi cation, technical consulting and assistance, training,
and coordination activities in the service of its members, with the goal of
fostering their development and improvement.
The Specialized Working Group in the Fight against Transnational
Corruption (GTCT) has the objective of promoting the interchange of
timely information between the region’s Superior Audit Institutions (SAI)
to improve the performance of their investigation and government audit
processes which contribute to the fi ght against transnational corruption,
as well as the interchange of experiences and best practices in this area.

Nota: El texto extraído es sólo una aproximación del contenido del documento, puede contener caracteres especiales no legibles.

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