NIGERIA: How not to lend in an emergency

Introduction

The COVID-19 pandemic confronted the International Monetary Fund (IMF, or “the Fund”) with an unusual challenge. Within weeks of the WHO’s pandemic declaration in March 2020, capital was fleeing emerging markets at a pace exceeding that seen in the 2008 global financial crisis. Between March 2020 and end-2021, the Fund deployed approximately US$170 billion across more than 80 countries. Nigeria received the largest single COVID-era emergency approval: US$3.4 billion, disbursed in a single tranche on April 28, 2020.

The Fund’s stated justification for the Nigeria loan was the convergence of COVID-19 and the oil price shock. This framing is not false but is incomplete in ways that matter for accountability. This monograph examines those gaps — in the epidemiological evidence, in the Fund’s communications, in its use of governance intelligence it already possessed, in the quality of the compliance it accepted, and in its silence about what happened next.

“Our message to governments has been very clear: in this time of crisis, please spend whatever is needed. But spend wisely and keep your receipts. We don’t want accountability to be lost.” — Kristalina Georgieva, IMF Managing Director, 2020

This post asks: whether the IMF’s institutional mechanism in Nigeria were equal to the aspirations of its Managing Director (MD), and whether the receipts were, from the beginning, worthless.

The COVID Question: Was the health emergency in Nigeria real?

Africa’s Anomalous COVID Profile

The premise of emergency health financing is that a genuine emergency justifies fast and unconditional disbursement. This premise was well-founded in much of the world. The premise was not well-founded in Nigeria, a fact known to Fund (and World Bank) staff at the time of approval.

Africa consistently recorded the world’s lowest COVID-19 mortality rates. As of end-2020, when emergency approvals had already occurred, Nigeria had a death rate of 6 per million population, compared to an Africa-wide value of less than 50, to a sub-Saharan African value of 75, to a Latin American and Caribbean value of 700-1000, and to an EU value greater than 850. Even allowing for the likely extreme undercounting of COVID mortality and morbidity in Nigeria, published work showed impacts in Nigeria that were not primarily an artifact of under-testing. Structural factors in Africa—younger populations, lower prevalence of cardiovascular comorbidities, different transmission dynamics—predicted significantly lower mortality.

The United Nations Economic Commission for Africa (UNECA) had predicted up to 3.3 million African deaths from COVID by end-2020. That figure proved to be an overestimate. What Africa recorded—even after aggressive upward adjustment by excess mortality modellers—was much lower mortality than in any other global region. The LSE’s analysis later showed that high excess death ratios cited for Africa were largely artefacts of applying models trained on global North data to African public health contexts.

Nigeria’s Crisis Was a BOP Emergency Wearing a COVID Label

The IMF’s staff report stated the matter directly: Nigeria faced an immediate balance of payments gap given the sharp contraction in oil prices and the projected costs of the COVID-19 pandemic. Nigeria’s oil exports were expected to fall by more than USUS$26 billion in 2020. Oil represented around 90 percent of exports and more than half of government revenue.

This vulnerability was already fully visible in the Fund’s pre-pandemic surveillance. Mission chief Amine Mati’s statement from the February 2020 Article IV consultation — six weeks before the WHO pandemic declaration — already described declining real incomes, external vulnerabilities increasing, a higher current account deficit, declining reserves, and a fiscal deficit mostly financed by the Central Bank. This was structural BOP fragility that predated COVID-19 entirely.

COVID and the associated oil demand collapse precipitated a crisis that was already latent. But the pandemic also provided a politically convenient framing that permitted deployment of emergency instruments calibrated for health emergencies rather than the kind of sustained structural engagement imposed by Nigeria’s underlying vulnerabilities. Had the crisis been framed primarily as a BOP challenge — which the evidence supported — an Upper Credit Tranche arrangement with genuine conditionality would have been the appropriate instrument.

The Rapid Financing Instrument (RFI) was chosen explicitly because, as IMF mission chief Mati stated, unlike the IMF’s standard financial package, there were no ex-post conditions attached. This design choice, justified by the supposed urgency of the pandemic, had the direct and foreseeable consequence of removing the conditionality architecture required by the underlying structural crisis. This was not hindsight. It was visible in the Fund’s own data at the time of approval.

The Rescue Narrative: What the IMF Said and Didn’t Say

IMF Press Statements at Approval

The Fund’s public communications around the Nigeria RFI followed a consistent pattern: insist on the speed, scale, and solidarity of the RFI; present governance commitments as meaningful protections against misuse of funds; suppress the degree to which the instrument was being stretched to address a problem for which it was not designed.

IMF Managing Director Georgieva’s April 7, 2020, statement described Nigeria’s economy as threatened by the twin shocks of COVID-19 and falling oil prices and framed the RFI as support to contain the spread of the virus and protect the most vulnerable. The health framing was prominent; the structural BOP framing was secondary.

The Executive Board press release on April 28 carried a statement from Mati:

“The implementation of proper governance arrangements — including through the publication and independent audit of crisis-mitigating spending and procurement processes — is crucial to ensure emergency funds are used for their intended purposes.” — Amine Mati, IMF Mission Chief for Nigeria, April 28, 2020

The statement is remarkable in retrospect. Mati described proper governance arrangements as crucial — while simultaneously presiding over an instrument design that made those arrangements entirely voluntary, unverifiable, and unenforceable. The language of necessity was deployed to describe an architecture of aspiration.

The Fund’s Factsheet on the Nigeria program of 2020 listed governance commitments in detail: dedicated budget lines, monthly portal reporting, procurement publication with beneficial ownership disclosure, and an independent audit by the Auditor General of the Federation within three to six months of fiscal year-end. The Factsheet presented these as tough safeguards, but they amounted to brave intentions without legal force. The Auditor General who was supposed to conduct the independent audit had previously served under the Accountant General who was, within two years, charged with lootingN109 billion from federal accounts.

The Pre-Pandemic Trail: What the IMF Knew

The contrast between the Fund’s pre-pandemic characterisation of Nigeria’s economy and its post-approval framing is instructive. In October 2019 Fund staff described a slowing recovery with declining reserves and a current account deficit; the Fund accordingly called for comprehensive reform. In February 2020 Fund staff identified rising external vulnerabilities and a tightening fiscal constraint. In April 2020, The Fund had reframed the same structural vulnerabilities as the consequence of an unprecedented COVID shock requiring emergency rescue.

The underlying conditions had not changed. COVID and oil prices had converted a chronic problem into an acute one. The shift in framing served institutional purposes — emergency instruments require emergency justification — but it obscured what the actual policy choice was: to provide balance-of-payments support at emergency-instrument governance standards to a country whose structural fragilities the Fund had been documenting and attempting to address for years.

What the IMF knew in 2019

The 2019 PEFA Assessment: A Documented Disaster

The 2019 PEFA assessment for the Federal Government of Nigeria was completed in late 2019 and publicly available at the time of the April 2020 RFI approval. It was jointly managed by the World Bank, UK-DFID, and the French Development Agency (AFD), with peer review from the World Bank, PEFA Secretariat, DFID, and AFD. It was a methodologically rigorous, external assessment of the governance environment into which US$3.4 billion would flow.

The PEFA’s findings were unambiguous: low budget credibility, insufficient disclosure of public finances, poor asset and liability management, anomalies in budget execution, low standards in financial reporting, and lack of auditor independence. On procurement — directly relevant to Nigeria’s commitment to publish contracts and beneficial ownership — the PEFA found weak procurement practices and fragmentation of internal controls. Both expenditure and revenue outturns were described as far below targets during all three fiscal years under review.

These were not new problems. The PEFA explicitly compared findings to the 2012 assessment and found that public financial management (FGM) in some areas of the Federal Government of Nigeria (FGN) had progressed slowly over seven years. On expenditure controls—the mechanisms determining whether emergency health spending reached its intended beneficiaries—the PEFA found them to be broadly ineffective. The PEFA further found auditor independence to be poor and legislative oversight to be limited.

The IMF’s Letter of Intent trusted the FGN’s PFM system to publish procurement contracts, to disclose beneficial ownership, to make monthly reports to a transparency portal, and to conduct an independent audit within six months of the end of the fiscal year. The gap between aspiration and reality was not merely foreseeable—it was known to the Fund had before program approval.

Institutional Knowledge without Institutional Consequence

The IMF’s knowledge of Nigeria’s public financial management went beyond external assessments. The Fund’s own AFRITAC (Africa Regional Technical Assistance Centre, West 2 regional technical assistance centre) had been established in Accra, Ghana in 2014. AFRICTAC was to serve Nigeria as one of its six core beneficiaries, providing capacity building to Nigerian institutions in tax administration, customs, public financial management, and macroeconomic statistics since its inception.

AFRITAC West 2’s Steering Committee reports document specific engagements with Nigerian counterparts including ICT strategy development for revenue administration, engagement with the Kaduna State Government on PFM reform, and broader work on fiscal reporting and budget credibility. By 2020 the centre had been working with Nigerian institutions for over six years.

The consequences of the AFRITAC-Nigeria relationship are significant. The IMF was not a distant observer of Nigeria’s PFM weaknesses—it was an active, embedded technical assistance partner that had spent six years attempting to address precisely those weaknesses. When it then deployed US$3.4 billion against a governance framework that trusted those same institutions to self-certify their use of emergency funds, it was choosing to disregard, for disbursement convenience, exactly what its own capacity development programme had been attempting to fix.

The IMF through AFRITAC West 2 had six years of direct, hands-on experience with the fragility of Nigeria’s PFM institutions before approving a US$3.4 billion emergency disbursement with no binding enforcement mechanism. The Fund cannot simultaneously claim technical knowledge of system weaknesses and institutional ignorance of their governance implications.

Performative Compliance: What the Portal Actually Showed

The Letter of Intent Commitment

Nigeria’s Letter of Intent committed to monthly reporting through the Open Treasury Portal (opentreasury.gov.ng), procurement publication with contract details and beneficial ownership, and—as the IMF’s Factsheet presented it—a functioning transparency platform as the primary mechanism for verifying that US$3.4 billion in emergency funds were reaching their stated purposes.

The IMF’s implementation tracking registered compliance as partial and delayed. This is an institutional understatement of what was happening in Nigeria. What the portal showed was not delayed compliance. It was, in large part, fabricated compliance.

What Independent Monitors Found

BudgIT, Nigeria’s leading civic data organisation, conducted the most comprehensive independent analysis of the Open Treasury Portal, examining over 100,000 payment entries from more than 600 individual files across the period September 2018 to May 2020—the period immediately preceding and overlapping the emergency disbursement. Its findings were specific and damning.

Between January and July 2019, BudgIT identified over 2,900 payments to individuals at an aggregate value of N51 billion. Multiple entries included payments of N2.04 billion, N2.04 billion, and N1 billion made to personal accounts on June 21, 2019, with no payment description whatsoever. Payments listed beneficiaries only as Ogunsuyi and international. The same analysis found payment records without descriptions or beneficiary information appearing throughout the dataset. The portal that Nigeria’s government presented to the IMF as its transparency mechanism was, in the assessment of those who analysed its data, not a transparency platform but a document dump of unverifiable transactions designed to create the appearance of disclosure.

The Open Contracting Partnership’s analysis of COVID emergency procurement data found that as of June 19, 2020—nearly two months after disbursement—only five procuring entities out of hundreds subject to the commitment had published any COVID emergency procurement data at all. Where data was published, details were conspicuous for their absence. One Ministry spentN39.3 million on face masks without stating how many were purchased or at what unit price. The Federal Ministry of Health paid companies up to four times local market value for infrared thermometers, with contracts awarded without competitive bidding to unregistered companies in violation of Bureau of Public Procurement guidelines. The Federal Road Safety Commission paidN5,600—approximately double market price—per 500ml hand sanitiser bottle.

Separately, a coalition of civil society organisations formally documented that COVID funds and grants from multilateral agencies had bypassed parliamentary budget oversight entirely. The CSO coalition included BudgIT, Connected Development, and the Women Advocates Research and Documentation Centre. Their joint report described poor financial management processes providing structured opportunities for corruption and a lack of transparency and accountability.

The Portal Goes Dark

The culmination of this compliance theatre was not partial reporting or delayed uploads. The Open Treasury Portal eventually went offline entirely, greeted by a blank page with the error message: the site can’t be reached. No official explanation was provided. The Nigerian government, which had presented the portal as a flagship anti-corruption initiative and committed to monthly reporting through it in the IMF’s Letter of Intent, offered no statement on its shutdown. The IMF’s implementation tracking, which had registered the portal’s inadequacy in polite institutional language, did not register its disappearance as a reportable event.

Transparency International’s (TI) August 2020 blog post on Nigeria’s IMF loan—published four months after disbursement—noted that the Ministry of Finance had committed to establishing a database for monitoring COVID emergency spending but that this database still did not exist even after three months since approval of the loan. TI stated that implicit statements and general phrases about structural deficiencies made by the Nigerian government must no longer be accepted by the IMF or other international lenders; this warning was not heeded.

Institutional Asymmetry: Compliance Theatre Accepted, No Consequences Drawn

What emerges from the documented record is not a picture of a government that tried and failed to implement transparency commitments. It is a picture of a government that produced the appearance of transparency—data uploads without meaningful content, portal reports without verifiable procurement information, commitments restated in successive monitoring periods without enforcement consequence—and an IMF that accepted this performance as sufficient.

The Fund’s implementation tracking methodology was not designed to detect performative compliance. It could log whether a portal existed, whether reports were filed, whether an audit had been commissioned. It could not assess whether the data in the portal meant anything, whether the contracts behind the reports had been competitively tendered, whether the audit would be conducted by an institution capable of independence from the very treasury officials it was meant to scrutinise. On all three of these questions—the questions that matter—the answer, as the documented record shows, was no.

The IMF accepted compliance reporting from a system whose outputs independent civil society organisations had found to be meaningless, from an Accountant General who was subsequently charged with lootingN109 billion, through a portal that eventually went offline with no explanation. This is not a monitoring failure. It is a systemic design failure in which the instruments for measuring compliance were incapable of detecting the absence of genuine compliance.

The Accountant General Affair and Broader Corruption in Nigeria

Ahmed Idris: The Officer at the Centre

On May 16, 2022—approximately two years after Nigeria’s US$3.4 billion emergency disbursement—operatives of Nigeria’s Economic and Financial Crimes Commission (EFCC) arrested Ahmed Idris, the serving Accountant General of the Federation, in Kano State. The EFCC stated that Idris had raked off funds through bogus consultancies and other illegal activities using proxies, family members and close associates, with proceeds laundered through real estate investments in Kano and Abuja. He was arrested after repeatedly failing to honour EFCC invitations for questioning.

By July 2022, when the EFCC formally arraigned Idris before the Federal Capital Territory High Court, the charges had expanded to N109,485,572,691.90—approximately USUS$265 million —on 14 counts of stealing and criminal breach of trust. Count one alleged that between February and December 2021—covering the COVID emergency spending execution period—Idris accepted gratification of over N15 billion for accelerating specific financial transfers through his office.

The Accountant General of the Federation is not a peripheral figure. The office is responsible for overseeing the management and accounting of all federal government funds—including the consolidated revenue fund through which emergency budget allocations flow. Nigeria’s RFI-supported COVID spending was executed through the federal budget system that this office was responsible for accounting and controlling. The individual heading that office during the emergency disbursement was, it is alleged, running a parallel system of systematic treasury diversion through exactly the kinds of intermediaries—bogus consultancies, family-owned companies—that emergency procurement controls are designed to detect.

The Systemic Pattern: One Man or a Cabal?

The Idris affair did not occur in an institutional vacuum. The documented record across Nigeria’s COVID emergency spending period shows a pattern that is too consistent across too many institutions to be attributable to one official acting alone.

The Ministry of Health awarded contracts to unregistered companies at four times market value for infrared thermometers, with no competitive bidding and in explicit violation of BPP procurement guidelines. Multiple MDAs uploaded procurement records to the portal showing payments to personal accounts without descriptions. The Federal Road Safety Commission—an institution with no obvious connection to health procurement—appears in COVID spending data paying double market price for hand sanitiser. A coalition of CSOs documented that funds from multilateral agencies including the IMF bypassed parliamentary oversight entirely. The Nigerian government’s own internal framework documentation acknowledged the trust gap it was attempting to bridge—revealing institutional awareness that the risk of diversion was real, widespread, and anticipated.

The EFCC’s charge against Idris specified that he operated through proxies, family members and close associates. This language describes a network, not an individual. The academic literature on corruption in Nigerian public financial management characterises what happened during COVID emergency spending as stakeholders using the pandemic to their advantage to increase private benefits—a systemic, multi-actor behaviour pattern enabled by the same structural weaknesses the PEFA had documented and AFRITAC had spent years attempting to remediate.

The relevant question for IMF accountability is not whether every corrupt official can be individually named and prosecuted. It is whether the institutional framework the IMF deployed was remotely adequate for an environment where systemic corruption was not merely possible but documented and predicted. The answer is clearly no.

The Institutional Asymmetry

The career trajectories of the two principal figures in this story embody its institutional logic with uncomfortable clarity.

Ahmed Idris—the Accountant General of the Federation who headed the office responsible for the management and accountability of federal funds during the emergency disbursement—was arrested in May 2022, suspended without pay, arraigned on 14 counts of theft and money laundering totalling N109 billion, and is subject to ongoing criminal prosecution.

Amine Mati—the IMF Senior Resident Representative and Mission Chief for Nigeria who presided over the governance safeguard architecture, accepted the Letter of Intent commitments, issued the press statement describing those commitments as crucial, and monitored their implementation—was promoted. From January 2022 he has served as Assistant Director in the IMF’s Middle East and Central Asia Department, heading the Fund’s mission for Saudi Arabia and the Gulf Cooperation Council division. His IMF biography describes his Nigeria work, including coronavirus pandemic emergency financial assistance, as part of a distinguished career.

The Nigerian official responsible for the compliance commitments went to jail. The IMF official responsible for designing and verifying those commitments was promoted. The IMF has published no retrospective examination of what the Idris affair means for the integrity of the 2020 emergency disbursement. This is institutional accountability in reverse: consequences fall on the borrower-side failure while the lender-side failure is absorbed into the career record as a completed assignment.

The Silence of the IMF

The IMF’s 2022 and 2023 implementation tracking reports on pandemic spending governance documented Nigeria’s compliance trajectory in institutional language. Neither mentions the Idris arrest. The Independent Evaluation Office of the IMF (IEO) March 2023 evaluation of the Fund’s pandemic response—a document of wide analytical ambition—does not engage with the Idris case as a case study or examine what it implies for the Fund’s monitoring methodology.

This silence is not accidental. Institutional self-assessment rarely foregrounds the worst outcomes of institutional choices. But it has consequences. The Fund’s credibility as a governance standard-setter depends on its willingness to account for governance failures that occur in programs where its frameworks proved inadequate. The question the Idris affair demands—to what extent did structural PFM weaknesses enable diversion of funds that were supposed to serve as COVID emergency relief—cannot be answered without a serious retrospective audit. It has not been commissioned.

The Program Architecture and the IEO’s Limited Reckoning

Four Structural Weaknesses

Full Upfront Disbursement Without Tranche Conditionality. The RFI disburses in a single tranche by design, eliminating the most powerful lever available to multilateral lenders: the credible threat of withheld subsequent financing. With nothing left to disburse, enforcement collapses to reputation management. The IEO found that 25 of 28 RFI recipients exhausted maximum available access, suggesting borrowing space rather than governance quality drove access determinations.

No Automatic Enforcement Trigger for Non-Compliance. IMF implementation tracking published in May 2021 and updated in July 2023 documented extensive delays and partial compliance across multiple COVID emergency borrowers. In Nigeria specifically, the commitments were not merely delayed—as shown in Section V, the compliance architecture itself was producing fabricated outputs that the Fund’s monitoring methodology was structurally incapable of detecting.

Macro Monitoring Instead of Transaction Verification. IMF monitoring calibrates to macroeconomic indicators: fiscal balances, reserve adequacy, monetary aggregates. These are wrong tools for verifying whether emergency funds reached intended beneficiaries. The IEO’s 2023 evaluation warned that commitments which cannot be verified create reputational exposure without providing genuine accountability. In Nigeria, the Fund accepted portal outputs that BudgIT’s analysis demonstrated were not verifiable by design.

Reputational Incentives in a Captured Environment. The theoretical logic of ex-post transparency commitments is that reputational costs of non-compliance exceed political costs of compliance. This logic fails when the accountability institutions themselves are part of the capture. Nigeria’s Auditor General—the designated independent auditor in the Letter of Intent (LOI)—operated within the same institutional environment that produced the Idris affair. The PEFA had documented lack of auditor independence as a core system characteristic. The commitment to an independent audit by this institution was not a safeguard. It was a formality.

What the IEO Said and Did Not Say

The IEO’s March 2023 evaluation found the Fund’s emergency response broadly effective and agile. The Board’s Summing Up acknowledged that initial emergency lending was not well tailored to countries’ needs and that assessment of risks to the Fund’s balance sheet was somewhat limited. The IEO’s recommendations called for developing crisis-activation policies and for reinforcing institutional preparedness as ways of addressing the timing problem.

The design problem remains unaddressed: the structural absence of enforcement architecture in the RFI instrument itself. The IEO identified one important operational concern—that requiring commitments staff cannot verify may be worse than fewer, more verifiable commitments, because unverified commitments create false assurance and reputational risk. This is precisely the problem of Nigeria. The IEO’s evaluation does not follow this logic to its conclusion—which is that in Nigeria, the Fund required unverifiable commitments in an environment where the institution responsible for generating the verification outputs was itself a site of systematic looting.

A Reform Framework for Emergency Governance Safeguards

The following six proposals form a package. Their value lies in combination—each addresses a different failure in the Nigeria case.

Risk-Tiered Governance Scoring. Pre-disbursement governance risk assessment should calibrate to PEFA scores, Transparency International CPI rankings, existing Article IV findings, and institutional capacity indicators. The output determines the applicable safeguard tier and monitoring intensity. A country where PEFA documents weak procurement controls and lack of auditor independence should not receive the same governance framework as a country with functional oversight institutions. Risk-tiering would have flagged Nigeria as requiring the most demanding safeguard tier. The current system treated it as equivalent to any other emergency borrower.

Mandatory Audit Timelines with Automatic Consequences. Transparency commitments without consequences are aspirations. Future emergency financing should include a limited set of commitments—audits and procurement disclosure at minimum—with defined timelines and automatic consequences for non-compliance: negative prior condition status for future financing and explicit treatment in subsequent Article IV reports. The current practice of logging non-compliance without drawing consequences is not monitoring. It is record-keeping.

Escrow and Phased Release for High-Risk Environments. In the highest-risk tier, a portion of disbursement should be held by a third-party institution and released upon independent certification of compliance with specified transparency milestones. This preserves emergency character for most of the disbursement while creating a genuine enforcement moment for the accountability-contingent tranche. Sovereignty objections are legitimate and should be weighed explicitly against the alternative—which is the Nigeria outcome.

Standardised Digital Procurement Portals. Procurement transparency commitments are only as meaningful as the platform on which they appear. Nigeria’s emergency commitment referenced opentreasury.gov.ng, which independent analysis found produced data that was systematically meaningless and which eventually went offline entirely. Future IMF governance safeguards should incorporate Open Contracting Partnership data standards by reference, require their implementation as a pre-disbursement technical assistance commitment in high-risk environments, and mandate independent third-party verification of portal data quality—not just portal existence.

Genuine Independent Third-Party Verification

The most significant verification gap in COVID-era safeguards was reliance on national audit institutions embedded in the governance environments under scrutiny. Nigeria’s Auditor General was designated as the independent auditor for a program whose treasury management was allegedly being systematically looted by the Accountant General to whom the Auditor General was institutionally proximate. Future high-risk emergency programs should require verification by institutions with no structural dependence on the borrowing government: through IMF technical assistance facilities, contracted international audit firms, or regional development bank oversight mechanisms.

A Retrospective Audit of the Nigeria 2020 RFI

The IMF should commission a public retrospective audit of the Nigeria 2020 RFI that examines: the use of disbursed funds during the COVID emergency period; the role of the Accountant General’s office in managing those funds; the relationship between the EFCC’s investigation of Ahmed Idris and COVID emergency allocations; the quality of data published on the Open Treasury Portal against the LOI commitments; and what IEO evaluation methodology changes would be needed to detect performative compliance of the kind documented in this case. This is not a punitive exercise. It is the minimum that the Fund’s stated commitment to transparency requires of itself.

Conclusion: The Receipts Were Worthless

The IMF Managing Director told governments to keep receipts for the use of funds related to the COVID shock. In Nigeria, the receipts were printed by an institution whose head was later charged with looting N109 billion. They were stored on a portal that published N51 billion in payments to personal accounts without descriptions and eventually went dark without explanation. They were verified by an audit institution that the PEFA had found to lack independence from the very officials whose spending it was supposed to scrutinise. The receipts were accepted by an organisation—the IMF—whose own monitoring was structurally incapable of distinguishing between genuine transparency and its theatrical simulation.

Nigeria’s RFI was, in narrow terms, a defensible response to an acute convergence of pressures. But the evidence assembled here points to a different overall conclusion. The Fund deployed its largest COVID emergency package, in one of its most governance-compromised major beneficiary, on the thinnest epidemiological justification, through a framework of unenforceable commitments, knowing from its own assessments and capacity development work exactly what the institutional risks were, and then accepted performance compliance that independent civil society organisations were simultaneously demonstrating was meaningless. It is also possible that senior Nigerian officials, and their former subordinates, of other international organizations put pressure on Fund management to approve this program quickly.

The institutional career asymmetry captures the problem with brutal clarity. The officer responsible for the compliance commitments the IMF accepted went to jail. The officer responsible for designing and accepting those commitments was promoted. The IEO found that governance safeguards could have been strengthened sooner. This monograph argues that sooner is an inadequate diagnosis of a structural design failure. The instruments were wrong, the oversight was inadequate, the knowledge was available, and the consequences have been real.

Accountability, the Fund said, means keeping the receipts. It is past time for the Fund to audit its own.

The Verdict

Let us be precise about what happened here. In April 2020, the IMF deployed its largest single COVID emergency package — $3.4 billion, disbursed in one shot, no structural conditionality, governance commitments that carried no enforcement mechanism — to a country whose own 2019 PEFA assessment had documented systemic procurement failure, whose auditor lacked independence, and whose senior treasury management was, as Nigerian prosecutors would later establish, already engaged in systematic looting.

The COVID justification was, in material terms, a pretext: Nigeria had recorded fewer than 150 COVID deaths at approval; the actual crisis was a structural oil-price-driven balance-of-payments shock the Fund had been tracking for years and which would have required structural conditionality under any instrument other than the RFI. The emergency label was used to deploy financing calibrated for genuine health crises, without the programme conditionality a structural BOP adjustment would have required, at a scale that placed $3.4 billion beyond the reach of any oversight architecture Nigeria possessed.

The money was looted — not metaphorically, not at the margins, but systematically: through personal accounts receiving N51 billion (~US$134 million at the average 2020 exchange rate of 380 Naira/US$) without payment descriptions, through ghost consultancies and family-owned companies, through contracts awarded to unregistered firms at multiples of market price, through a compliance portal that generated fabricated outputs before going dark. The Accountant General of the Federation — the officer who managed the flows through which the IMF’s disbursement moved — was arrested in May 2022 and charged with laundering N109 billion (~ US$286million).

The IMF mission chief who designed and accepted the governance framework was promoted to Assistant Director. Nigeria then repaid every cent: eight quarterly installments from July 2023 to April 2025, at effective borrowing costs of 5–7 percent, through the most acute phase of its structural adjustment programme, as the Naira collapsed and fuel subsidy removal compressed real incomes across the economy.

The IMF recovered its principal, its surcharges, and its institutional reputation intact. Nigeria recovered nothing. No retrospective audit was commissioned. No institutional post-mortem was published. No official on the Fund’s side was held to account. The officer who went to jail was Nigerian. The officer who was promoted was not. If this is what accountability in development finance looks like, the phrase has been emptied of meaning — and the institution that coined it owes its borrowers a more honest reckoning than it has so far been willing to provide.

References and Documentary Sources

I. Primary IMF Documents

1. IMF (2020). Nigeria: Request for Purchase Under the Rapid Financing Instrument. Country Report No. 20/142. April 28, 2020. https://www.imf.org/en/Publications/CR/Issues/2020/04/30/Nigeria-Request-for-Purchase-Under-the-Rapid-Financing-Instrument-Press-Release-494922. IMF Managing Director Georgieva (2020). Statement on Nigeria. Press Release No. 20/137. April 7, 2020. https://www.imf.org/en/News/Articles/2020/04/07/pr20137-nigeria-statement-by-imf-managing-director-kristalina-georgieva-on-nigeria3. IMF Executive Board (2020). Press Release: USUS$3.4 Billion Emergency Support to Nigeria. April 28, 2020 [includes Mati statement on governance]. https://www.imf.org/en/News/Articles/2020/04/28/pr20191-nigeria-imf-executive-board-approves-emergency-support-to-address-covid-194. IMF Country Focus / Amine Mati interview (2020). Nigeria’s IMF Financial Assistance to Support Health Care Sector, Protect Jobs and Businesses. April 29, 2020. [Mati: no ex-post conditions attached to this emergency loan]. https://www.imf.org/en/news/articles/2020/04/29/na042920-nigerias-imf-financial-assistance-to-support-health-care-sector-protect5. IMF / Amine Mati (2020). Nigeria: IMF Staff Concludes 2020 Article IV Mission. Pre-pandemic BOP vulnerability assessment. February 17, 2020. https://www.imf.org/en/News/Articles/2020/02/17/pr2053-IMF-Staff-Concludes-Article-IV-Consultation-to-Nigeria6. IMF / Amine Mati (2019). Nigeria: IMF Staff Concludes Visit. October 8, 2019. https://www.imf.org/en/News/Articles/2019/10/08/pr19368-nigeria-imf-staff-concludes-visit7. IMF (2021). Implementation of Governance Measures in Crisis-Related Spending. May 2021 Update. https://www.imf.org/-/media/Files/Topics/governance-and-anti-corruption/implementation-status-of-governance-commitments-on-crisis-related-spending-may-2021.ashx8. IMF (2022, 2023). Implementation of Governance Measures in Pandemic-Related Spending. May 2022 and July 2023 Updates.9. IMF IEO (2023). The IMF’s Emergency Response to the COVID-19 Pandemic. March 20, 2023. https://www.imf.org/en/Publications/IEO-Evaluations/Issues/2023/03/20/The-IMFs-Emergency-Response-to-the-COVID-19-Pandemic-5304610. IMF Executive Board (2023). Chair’s Summing Up: IEO Evaluation of IMF’s Pandemic Response. March 2023.11. Arab Gulf States Institute (2025). Amine Mati biography. [Documents promotion to IMF Assistant Director, MECA Department, Saudi Arabia/GCC Mission Chief from January 2022]. https://agsi.org/people/amine-mati/

II. PEFA and AFRITAC Documentation

12. PEFA (2019). Nigeria: Federal Government PEFA Assessment 2019 [full report, December 2019]. https://www.pefa.org/node/166 and https://www.pefa.org/sites/pefa/files/2021-03/NG-Dec19-PFMPR-Public.pdf13. AFRITAC West 2 (2014–). Background, Mandate, and Nigeria Country Programme. Accra, Ghana. https://www.afritacwest2.org/aboutus14. IMF Press Release (2013). Ghana and IMF Sign MOU to Create AFRITAC West 2. PR/13/134. https://www.imf.org/en/News/Articles/2015/09/14/01/49/pr13134

III. Open Treasury Portal and Procurement Compliance

15. BudgIT Foundation (2020). OpenTreasury.gov.ng: Nigeria’s Spending Platform: Review, Gaps and Recommendations. Analysis of 100,000+ payment entries, September 2018–May 2020 [N51bn to personal accounts, payments without descriptions]. https://budgit.org/our_programs/govspend/16. Open Contracting Partnership (2021). How Emergency COVID-19 Spending Rallied Open Data Activists in Nigeria to Push for Reforms. March 2, 2021. [As of June 19, 2020: only 5 procuring entities had published COVID emergency procurement data]. https://www.open-contracting.org/2021/03/02/how-emergency-covid-19-spending-rallied-open-data-activists-in-nigeria-to-push-for-reforms/17. The Cable (2021). Revealed: How MDAs Violate Presidential Directive on Open Treasury Portal. January 11, 2021. [Vague data, personal account payments, institutional non-compliance]. https://www.thecable.ng/revealed-how-mdas-violate-presidential-directive-on-open-treasury-portal/18. Sahara Reporters (2022). Secrecy Now in Nigerian Government’s Spending, Revenues as Open Treasury Portal Shuts Down. April 6, 2022. [Portal goes offline with no explanation]. https://saharareporters.com/2022/04/06/secrecy-now-nigerian-governments-spending-revenues-open-treasury-portal-shuts-down19. Transparency International (2020). Nigeria, IMF and COVID-19: Tracking the Trillions. August 14, 2020. [Fund database committed to in LOI does not exist three months post-approval; TI calls for rejection of general phrases about structural deficiencies]. https://www.transparency.org/en/blog/nigeria-imf-covid-1920. Sahara Reporters (2022). Civil Society Organisations Allege Massive Looting of Nigeria COVID-19 Funds. March 31, 2022. [Funds bypassed parliamentary oversight; WARDC, BudgIT, Connected Development, TIDES coalition]. https://saharareporters.com/2022/03/31/civil-society-organisations-allege-massive-looting-nigeria-covid-19-funds-spending21. ISS Africa (2022). Corruption in Africa Deepens the Wounds of COVID-19. [Nigeria: Federal Ministry of Health allegedly bought 1,808 face masks for USUS$96,000]. https://issafrica.org/iss-today/corruption-in-africa-deepens-the-wounds-of-covid-1922. LSE Africa at LSE (2022). Understanding How Corruption Impacted Nigeria’s COVID-19 Response. October 7, 2022. https://blogs.lse.ac.uk/africaatlse/2022/10/07/understanding-how-corruption-impacted-nigerias-covid-19-response/

IV. Accountant General Affair

23. EFCC (2022). EFCC Arrests Ahmed Idris, Accountant General of the Federation, for N80 Billion Fraud. Press Release, May 16, 2022. https://www.efcc.gov.ng/efcc/news-and-information/news-release/8028-efcc-arrests-ahmed-idris-accountant-general-of-the-federation-for-n80billion-fraud24. EFCC (2022).N109bn Fraud: EFCC to Arraign Former Accountant General Ahmed Idris. July 19, 2022. [14 counts, covering February–December 2021]. https://www.efcc.gov.ng/efcc/news-and-information/news-release/8304-n109bn-fraud-efcc-to-arraign-former-accountant-general-ahmed-idris-others-july-2225. Bloomberg (2022). Nigeria’s Top State Accountant Arrested Over US$193 Million Theft. May 17, 2022. https://www.bloomberg.com/news/articles/2022-05-17/nigeria-s-top-state-accountant-arrested-over-193-million-theft26. Al Jazeera (2022). Nigeria’s Treasury Chief Arrested Over Multimillion-Dollar Fraud. May 17, 2022. https://www.aljazeera.com/news/2022/5/17/nigerias-treasury-chief-arrested-over-multi-million-dollar-fraud27. Premium Times Nigeria (2022). Accountant General of the Federation Ahmed Idris Arrested. May 17, 2022. https://www.premiumtimesng.com/news/headlines/530277-breaking-accountant-general-of-the-federation-ahmed-idris-arrested.html

V. COVID Mortality Evidence

28. Population Reference Bureau (2021). COVID-19 Cases and Deaths in Sub-Saharan Africa Appear Vastly Undercounted. [Nigeria: 9 deaths per million vs. global average 316]. https://www.prb.org/articles/covid-19-cases-and-deaths-in-sub-saharan-africa-appear-vastly-undercounted/29. Lawal, Y. (2021). Africa’s Low COVID-19 Mortality Rate: A Paradox? International Journal of Infectious Diseases, 102, 118–122. [Standardized mortality ratio 4x lower in Africa than Europe]. https://www.sciencedirect.com/science/article/pii/S120197122032242630. Meagher, K. (2023). Africa’s COVID-19 Statistics Highlight Bias in Excess Death Modelling. LSE Impact Blog. May 11, 2023. [UNECA 3.3 million death prediction; model artefacts in excess mortality estimates]. https://blogs.lse.ac.uk/impactofsocialsciences/2023/05/11/africas-covid-19-statistics-highlight-bias-in-excess-death-modelling/31. Njenga, M.K. et al. (2020). Why is There Low Morbidity and Mortality of COVID-19 in Africa? American Journal of Tropical Medicine and Hygiene. https://pmc.ncbi.nlm.nih.gov/articles/PMC7410455/32. NCDC (2020). Nigeria COVID-19 Epidemiological Data [143 deaths at April 28, 2020 approval; 287 deaths by May 31, 2020].

https://www.ncdc.gov.ng

A guest post by

Parminder Brar

Over the past twenty-five years I have worked with the World Bank, IMF, and IFC. This publication is a space to share what that experience taught me about what works in the field. The full archive is at mdbreform.com, including an extended version of this post. — Parminder Brar