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Who paid the price for Uganda’s refugee fraud scandal (and who didn’t)?

Some say the international community’s investment in a ‘role model’ refugee hosting country constrained the push for accountability.

South Sudanese refugees displaced by fighting receive food rations at Imvepi settlement in northern Uganda, in April 2017. The following year, the refugee response was hit by a major corruption and mismanagement scandal. James Akena/Reuters
South Sudanese refugees displaced by fighting receive food rations at Imvepi settlement in northern Uganda, in April 2017. The following year, the refugee response was hit by a major corruption and mismanagement scandal.

In 2018, as Uganda was catering for hundreds of thousands of South Sudanese escaping conflict across the border, a major corruption and mismanagement scandal hit the country's widely praised refugee programme.

The scandal, which implicated both government officials and the UN’s refugee agency (UNHCR), made global headlines. Yet almost five years on, many of those most involved appear to have avoided legal or professional repercussions, Kristof Titeca, an associate professor of international development at the University of Antwerp in Belgium, believes.

“Little meaningful accountability occurred on the side of the Ugandan government,” Titeca told The New Humanitarian, summarising the findings of several years he spent researching the fallout of the case. “And though individual accountability for UNHCR officials was hard to research, the available evidence raises many questions.”

  • Five years on: Accountability shortfalls and continued corruption

  • Ugandan civil servants were prosecuted but seen as “sacrificial lambs” for higher-level government officials who did not face trial.
  • The international community’s investment in Uganda’s progressive refugee policy constrained its ability to push for accountability, Titeca believes.
  • Accountability and transparency at UNHCR were perceived to be insufficient by diplomats, senior UN officials, aid workers, and Ugandan journalists.
  • Individual donor countries pursued UNHCR less vigorously than the Ugandan government, internal donor documents suggest.
  • Corruption scandals have continued to plague the Ugandan Office of the Prime Minister, which oversees refugee affairs.
  • A 2021 audit of UNHCR Uganda raised fresh concerns about the reliability of refugee registration data and other management issues.

For more than a year prior to the scandal breaking, aid workers had complained that refugee numbers – captured and recorded by the government – were being inflated, and that control measures were severely lacking from UNHCR, which co-managed the response.

The fraud concerns eventually led to a joint UN-government probe that uncovered 300,000 “ghost refugees” in the country. The distortion may have resulted in millions of dollars of relief supplies being diverted, though the government said there were justified explanations for the mismatch.

UNHCR was subjected to an audit by the UN’s main oversight body, OIOS. The review found that the agency had mismanaged up to $214 million and did too little to prevent fraud by its government partner.

Titeca, who has been studying governance issues in Uganda for two decades, shared his findings – along with internal UN and donor documents, and transcripts from dozens of interviews with UN staff, aid workers, donors, journalists, and Ugandan officials – with The New Humanitarian. 

His research offers a rare glimpse into how the humanitarian sector – both aid agencies and their government counterparts – deals with wrongdoing long after headlines have faded and damage control statements have been written. It also points to how political leverage – and deference to personal and longstanding relationships – can dilute accountability efforts.

According to Titeca’s investigation, Uganda appears to have avoided full accountability by leveraging its position as Africa’s largest refugee-hosting country – one with a progressive, open-door policy that has garnered credit from around the world.

“This gave the country important political capital towards the international community,” Titeca said. “It affected the leverage of international actors to demand accountability from the Ugandan government.”

Criminal trials were held in Uganda, but Titeca’s research suggests they mostly targeted lower-level civil servants who became “sacrificial lambs” for higher-level government workers – a pattern that can be observed in past anti-corruption investigations in the country.

Refugee-hosting districts in Uganda 

uganda map districts

Among those who avoided trial was the former commissioner for refugees at the Ugandan Office of the Prime Minister (OPM), which oversees refugee affairs. The official was widely believed by diplomats, humanitarian workers, and journalists to be central to the problems at the OPM, though he denied any wrongdoing at the time. 

For its part, UNHCR dismissed its former country representative in Uganda and “several” other staff members following reviews by OIOS and the agency’s own internal oversight entity, a spokesperson told Titeca via email.  

The spokesperson also said that UNHCR Uganda had “made good progress in strengthening its systems and controls” since 2018, citing conclusions from a separate 2021 OIOS audit.

Still, citing privacy concerns, the spokesperson provided no details on how many staff were let go and for what reasons. And half a dozen UN officials and diplomats who spoke with Titeca told him they perceived accountability and transparency to be insufficient at the agency.

Although audits and investigations found UNHCR staff guilty of both fraud and mismanagement, individual donor countries also pursued the UN agency less vigorously than the Ugandan government, documents obtained by Titeca suggest. 

Inadequate accountability has had a longlasting impact, often entrenching impunity, Titeca said. He noted the corruption scandals that have continued to surround the OPM, which did not respond to requests for comment by The New Humanitarian. And although the 2021 OIOS audit showed that UNHCR has tightened up procedures, it also described lingering fraud risks and management problems.

In this emailed Q&A, Titeca summarises what happened in 2018 and outlines the main findings of his research.

The New Humanitarian: How did the corruption case come about – who was accused of what?

Problems emerged as fighting erupted in South Sudan in mid-2016. Thousands of refugees were arriving in Uganda every day, and the country’s response was impressive: It kept its borders open, offered protection, and shared land.

Yet questions about the reliability of the government’s refugee numbers – recorded on a platform paid for by UNHCR – soon became a major concern in the humanitarian community. Several aid workers told me they shared concerns about bloated figures with UNHCR but found the agency deferential towards the government. 

They said the government bluntly refused to let them see the refugee figures, and that high-level officials went to the extent of threatening to move away from progressive policies – granting refugees freedom of movement, the right to seek work, and access to public services – if UNHCR pushed too hard to be allowed onto the registration platform.

Several aid workers told me they shared concerns about bloated figures with UNHCR but found the agency deferential towards the government. 

In early 2018, the UN shared fraud concerns with the prime minister, resulting in the suspension of several OPM workers, including its top official for refugee affairs, Apollo Kazungu. A subsequent UN-government probe found that only 1.1 million of the 1.4 million supposedly registered refugees actually existed.

The October 2018 audit by OIOS then looked into problems at UNHCR Uganda. The report concluded that the agency had failed to leverage its funding to the OPM to access the refugee registration data. It described this as “a major failure”.

The audit – which prompted some donors to freeze funding to UNHCR – also found that the agency had mishandled anywhere between $44 million and $214 million during the refugee influx from South Sudan. Weak internal controls led to eye-popping over-expenditures, poor procurement procedures, and non-respect of systems for contracting partners.

The New Humanitarian: Which Ugandan officials were charged?

Several OPM officials were suspended after the scandal broke, while Uganda’s Inspectorate of Government (IG) – an institution that probes corruption – completed investigations into eight members of the office, according to case files shared with me in September 2022 by an IG spokesperson.

However, the case files do not specifically mention fraud related to the inflation of refugee numbers. And they show that, of the four individuals who have appeared in front of a court and been sentenced (three others got administrative sanctions and one court case is ongoing), none held high-level positions at the OPM.

One was an IT assistant who was convicted of money laundering and told to return a few thousands dollars, while two others were camp managers convicted of corruption and abuse of office. They received prison sentences of two-and-a-half and three years respectively. The fourth individual – who was also a camp manager – was barred from holding public office for 10 years.

Ugandan journalist Eriasa Mukiibi, who has followed the case closely, described those prosecuted as “sacrificial lambs”. “Other than a few isolated cases – small fish which were obliged to return a few thousand dollars – nothing happened,” Mukiibi told me.

The OPM commissioner in charge of refugees, Apollo Kazungu, never faced trial, according to the IG spokesperson. He was one of those initially suspended, and all the donors, diplomats, and humanitarian workers I spoke to who were familiar with the situation said he was considered to be central to the problems at the OPM.

After initial attention on the corruption case faded, Kazungu was reappointed to his role in late 2020. That outcome shocked donors, many of whom had lost funds in the scandal and had sunk money into the accountability process too.

“Other than a few isolated cases – small fish which were obliged to return a few thousand dollars – nothing happened.”

Though donor pressure – and a reconfiguration of Uganda’s political landscape – eventually saw Kazungu removed from his position, this gesture amounted to little: According to several sources, he got a new post at the presidential state house.

Kazungu did not provide full answers to questions sent last week by The New Humanitarian. However, he said investigations were carried out “on all staff whether senior or junior”, and that the cases of those found responsible for misconduct had been “handled”.

According to earlier media reports, Kazungu had sued the Ugandan government in 2019. He claimed he should be reinstated to the OPM because his suspension was not substantiated.

In messages to The New Humanitarian – sent over WhatsApp – Kazungu said 90% of refugee funds were controlled by the UN and its partners and argued that “no accountability has been produced by them”.

He also forwarded a link to a letter written by Uganda’s refugees minister. Addressed to Western ambassadors, it accuses UN agencies and NGOs of being responsible for most of the corruption involving refugee funds and argues that “the general public has been made to believe” that the only funds misused were by the government.

Still, the perceived lack of justice for Ugandan officials has had a long-lasting impact, according to my sources in the aid and diplomat community – all of whom requested anonymity to avoid jeopardising relationships with the Ugandan government. For example, until midway through this year, some NGOs were being told by their donors not to formally engage with the OPM refugee department.

“If fraud and corruption are not addressed through consistent application of Ugandan law, the perception of impunity prevails, jeopardising the credibility and effectiveness of actors in the refugee response.”

Three well-placed sources said the rationale for this de facto boycott wasn’t entirely clear to them, but that they understood it as a reaction to the lack of accountability and the risk of corruption at the OPM, even after Kazungu’s departure.  

Meeting minutes I obtained from the Risk Advisory Group (RAG) – a UN/NGO/donor structure set up in Uganda in the aftermath of the scandal – also articulate fears that a lack of justice is entrenching corruption.

“If fraud and corruption are not addressed through consistent application of Ugandan law, the perception of impunity prevails, jeopardising the credibility and effectiveness of actors in the refugee response,” a December 2021 RAG report stated.

Nor is this the first time that justice for corruption at the OPM has been questioned. Court records from a separate case detail accusations that lower-level OPM officers were pressured to divert aid funds in 2013-2014 by the same refugee commissioner.

Yet here too, the refugee commissioner stayed out of reach and did not appear before court, much to the dismay of the judge, who said: “Big fish continue to swim in the sea of corruption”.

The New Humanitarian: Your sources argue that Uganda avoided full accountability. What were the main factors that enabled this?

It is connected to the geopolitics of Uganda’s refugee policy, which has bought President Yoweri Museveni’s government lots of international credit from across the ideological spectrum in the Global North.

For those in favour of more restrictive immigration policies, Uganda is considered a testimony to the success of regional refugee hosting. For those in favour of more generous policies, it is considered an example that Northern actors should follow.

Either way, the government’s ability to host large numbers of refugees in an unstable region gives Kampala important political capital and affects the leverage of international actors to criticise the government.

Calling for justice for a fraud case that occurred years ago came second fiddle to the need for a place to host refugees.

This is particularly true for UNHCR, which continues to describe Uganda as a “role model” and a pioneer in implementing the agency’s flagship programme – the Comprehensive Refugee Response Framework.

Uganda has also been appointed a co-convenor of UNHCR’s second Global Refugee Forum, to be held in 2023 – further highlighting its position as a “role model”; and signalling that a line may have been drawn under the corruption scandal.

UNHCR’s dependence on Uganda’s position as a “role model” affected its ability to push for accountability after the scandal broke. Calling for justice for a fraud case that occurred years ago came second fiddle to the need for a place to host refugees.

As one diplomat put it to me. “For UNHCR, Uganda remains its poster boy, and that remains the emphasis in this story. The corruption case: It’s not that they don’t want to look at it, but the feeling is: ‘We’re very sorry it happened, but it is behind us’.”

The rapid turnover at international organisations – and their lack of institutional memory – works in Kampala’s favour.

A UNHCR Uganda spokesperson disagreed with this assessment. They said UNHCR had “cooperated fully” with Ugandan accountability processes and supported the government to undertake a country-wide recounting of refugees and asylum seekers.

To avoid accountability, the government also deployed its more standard strategy of dealing with pressure from the international community, particularly when it comes to issues of corruption and aid money: the waiting game. 

Generally, this strategy sees complaints disappear in murky processes until it is no longer a priority for the international community. The rapid turnover at international organisations – and their lack of institutional memory – works in Kampala’s favour.

The New Humanitarian: What steps has UNHCR taken since 2018, and has anybody from the agency been held to account?

UNHCR took steps to rectify problems after the scandal came to light. The 2018 audit made 12 recommendations (of which six were deemed “critical”) – and 11 of those 12 have now been resolved, according to the more recent audit published last year.

UNHCR’s oversight body – the Inspector General’s Office (IGO) – began separate misconduct investigations into staff in 2018. According to a 2019 annual IGO report, 33 cases were opened, of which 17 were referred for disciplinary action.

According to the report – which covers IGO’s work around the world – the investigations involved fraud relating to refugee resettlement, entitlements, and benefits. Fraud involving the inflation of refugee numbers is not mentioned.

Local journalists and other sources told me they had hoped for more detailed and accessible updates from the IGO, rather than a summary in online reports and in speeches at standing committee meetings.

“Apart from the audits, we have not seen open communication of what went wrong [at UNHCR],” Mukiibi, the journalist, told me. “The Inspector General, they promised periodic reports, but… in the end, I have no idea what happened within UNHCR,” he added.

I asked UNHCR for their view on this. A spokesperson said the agency had “continuously provided updates” to donors, partners, and the diplomatic community on its implementation of the audit recommendations and the accountability measures it had taken. 

Still, despite the number of cases substantiated by the IGO, I found it difficult to establish who had been sanctioned other than the former country representative, Bornwell Kantande.

“All those directly involved, all of them are leading a good life.”

Kantande – who died last year, before I could contact him for comment – was let go in 2020 after UNHCR had initially promoted him and defended his “stellar work”. UNHCR did not clarify to me why he was dismissed.

Though UNHCR’s spokesperson did say other members of staff were dismissed, they did not specify how many people this included, the positions they held, and the reasons they were let go.

One senior UNHCR official with close knowledge of the accountability process described Kantande as a “sacrificial lamb”. They said others were let go for reasons “unrelated” to the more serious mismanagement and corruption claims.

This source also argued that UN officials who oversaw the Uganda operation – from various regional and global offices – faced no professional consequences. In their opinion, such officials were promoted, moved to other postings, or retired. 

“All those directly involved, all of them are leading a good life,” said the senior UNHCR official, who requested anonymity due to the risk of professional reprisals.

I tried to get more answers from four diplomats from donor countries who had received briefings from UNHCR on accountability actions taken by the agency in the aftermath of the scandal.

But these diplomats said the information provided to them was also vague, and they did not know who or how many people had been let go. All four were frustrated by this and described accountability as either insufficient or totally lacking.

The alleged lack of transparency raises a broader question: What is the use of accountability processes if few people actually know about them? In such circumstances, how can future abuse and misconduct really be prevented?

The New Humanitarian: Do you think there was more of a focus on holding Ugandan officials to account than the UN? If so, why?

Most of the attention on the refugee corruption and mismanagement scandal – and much of the follow-up by the international community – has focused on the involvement of the Ugandan government, and the OPM in particular.

By contrast, donor countries pursued UNHCR far less vigorously. This can be seen in the Risk Advisory Group documents I obtained – none of which refer to accountability processes at UNHCR.

Questions should be asked about why this was the case. UNHCR was found to have mismanaged up to $214 million by the 2018 audit, which had more critical recommendations than any of the other 907 OIOS reviews published in the five years prior. By comparison, a 2018 audit into the UN Environment Programme, which had only one critical recommendation, led to the resignation of its chief, Erik Solheim.

“There was a very sympathetic view of most of the donors towards UNHCR. The [feeling] was that the internationals were all in this together.”

So why didn’t donors put the same pressure on UNHCR as they did with the government? A common thread throughout my research was the reputation of UNHCR among donors: As a UN institution, it was considered more reliable than the Ugandan government, even if there were frustrations around transparency and accountability.

Another explanation I heard was that donors had too close and cosy a relationship with the UN. As one journalist (who requested anonymity due to risks facing reporters in Uganda) looking into the case put it: “There was a very sympathetic view of most of the donors towards UNHCR. The [feeling] was that the internationals were all in this together.”

A last explanation highlighted the need to protect UNHCR and the refugee response in the country. As UNHCR Uganda is almost constantly in major financial need, it was felt a continued push for accountability would ultimately hurt the refugee response. 

The New Humanitarian: Have there been any further corruption concerns since the refugee scandal broke?

After the refugee scandal broke, the then-speaker of Uganda’s parliament requested a motion for refugee care to be transferred to a “less corrupt” government ministry. The establishment of a committee of inquiry to investigate the OPM was also suggested.

But none of this happened, and the OPM has continued to be accused of being involved in numerous corruption scandals. In 2018, the ministry was accused of corruption involving housing and land deals, some of which exposed people to landslides

In 2020, OPM officials were accused of being involved in fraud related to COVID-19 funds; in 2021, officials were accused of extracting money from refugees in exchange for promises to fast-track them onto resettlement programmes; and in 2022, new stories emerged concerning accusations of OPM officials using refugee funds fraudulently. 

Reports in 2019 also accused individuals working for UNHCR’s Uganda operation of demanding bribes from refugees for resettlement abroad. UNHCR rejected the allegations at the time.

The 2021 internal audit of UNHCR, meanwhile, raised concerns for the agency's Uganda operation, including in areas such as water trucking, fuel management, and relations with external partners, one of which was re-engaged despite previously over-charging the agency. Problems were also identified with the reliability of refugee registration data – the main area of concern back in 2018.

Edited by Philip Kleinfeld.

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