WHEN ASYCUDA CANNOT TELL THE WHOLE STORY

By Mahmud Tim Kargbo

The real question in Sierra Leone’s revenue controversy is not simply whether money was lost. It is whether the State can reconstruct, transaction by transaction, what happened to public money after it was assessed. The Anti-Corruption Commission has confirmed that it has taken over from the Sierra Leone Police an investigation into alleged revenue diversion at the National Revenue Authority involving possible collusion between certain NRA staff, commercial bank tellers and other individuals. That investigation follows audit findings which had already identified weaknesses linking revenue assessment, payment, banking and the Consolidated Fund. The audit reports do not prove the allegations. They explain why the records require forensic scrutiny. Reference: Anti-Corruption Commission, https://www.anticorruption.gov.sl/blog/anti-corruption-commission-sl-news-room-1/post/acc-takes-over-investigation-bordering-on-revenue-diversion-at-the-national-revenue-authority-nra-1493

The distinction between allegation and established fact must remain central. Claims of deleted ASYCUDA declarations, receipts allegedly issued without corresponding Government credits and the reported allegation that more than Le300 billion was diverted require evidence capable of independent verification. The ACC has confirmed an investigation, not the alleged amount or anyone’s guilt. Investigators must therefore establish what ASYCUDA recorded, what Customs assessed, what was paid, which bank received the payment, what reached the Consolidated Fund and what the Treasury recorded. Where records were allegedly altered or deleted, they must determine who accessed them, when, whether the changes were authorised and whether the original evidence survives. Reference: Anti-Corruption Commission, https://www.anticorruption.gov.sl/blog/anti-corruption-commission-sl-news-room-1/post/acc-takes-over-investigation-bordering-on-revenue-diversion-at-the-national-revenue-authority-nra-1493

The Auditor General’s 2023 Report had already highlighted weaknesses in that revenue chain. It found that transactions totaling NLe34,527,680.85 from GST and Income Tax remittances and ASYCUDA World prepayment accounts of oil marketing and mining companies could not be traced to the Consolidated Fund at the Bank of Sierra Leone. This included NLe494,059.87 in GST remittances, NLe1,033,094.07 in Income Tax remittances and NLe33,000,526.91 in ASYCUDA World prepayment transactions. The report did not conclude that the sums had been stolen. It recorded failures of traceability and noted that requested SWIFT evidence had not been produced. It also found that reconciliations between the ASYCUDA World prepayment account and the Consolidated Fund had not been performed, describing this as a significant internal control weakness because inconsistencies between NRA and Accountant-General records could not be ruled out. Reference: Audit Service Sierra Leone, Auditor General’s Annual Report 2023, https://website.auditservice.gov.sl/wp-content/uploads/2024/12/2023-AGs-REPORT-Final-2-12-24.pdf

The 2024 Auditor General’s Report showed that similar reconciliation problems persisted. It found that NLe29,394,709 in GST and Income Tax remittances and prepayment accounts could not be traced to the Consolidated Fund, while NLe7,042,879.47 in petroleum transactions recorded in ASYCUDA World prepayment accounts also could not be traced. These figures should not be merged with the reported Le300 billion allegation or treated as proof of theft. They are separate audit findings demonstrating continuing gaps between recorded revenue transactions and the Government account into which those revenues should ultimately flow. Reference: Audit Service Sierra Leone, Auditor General’s Annual Report 2024, https://website.auditservice.gov.sl/wp-content/uploads/2025/12/Auditor-Generals-Annual-Report-2024.pdf

The same report identified wider weaknesses in the digital revenue environment. ASYCUDA World was not integrated with the Integrated Tax Administration System, making reconciliation and taxpayer updates difficult. The Auditor General linked that deficiency to false GST refund claims amounting to NLe34,073,158 and also found 644 declarations with assessed duties and taxes totalling NLe111,892,600.60 that remained pending without evidence of follow-up. The report further identified incorrect application of National Petroleum Regulatory Authority pricing rates, resulting in unpaid import duties, excise duties and Infrastructure Development Fund levies. None of these findings establishes criminal diversion. They identify weaknesses in assessment, reconciliation and system controls that can expose public revenue to loss and complicate reconstruction of the audit trail. Reference: Audit Service Sierra Leone, Auditor General’s Annual Report 2024, https://website.auditservice.gov.sl/wp-content/uploads/2025/12/Auditor-Generals-Annual-Report-2024.pdf

The strongest link between the audit record and the present investigation lies in the NRA’s own response. On 3 April 2025 the Authority issued a Request for Expression of Interest for an independent audit firm to reconcile Customs revenue with transit bank records. The assignment called for reconciliation between ASYCUDA World and bank records, verification of assessed revenue against bank receipts and examination of deletions, additions, misclassifications and internal controls. The document does not establish fraud, but it shows that the NRA itself recognised the need for an independent examination of the same digital and banking trail now relevant to the ACC investigation. Reference: National Revenue Authority, Request for Expression of Interest, 3 April 2025, https://www.nra.gov.sl/notices

This provides the proper bridge between the Auditor General’s reports and the ACC investigation. The Auditor General identified weaknesses in traceability and reconciliation. The NRA sought an independent reconciliation of ASYCUDA transactions against transit bank records. The ACC has now confirmed an investigation into alleged revenue diversion. These developments should neither be collapsed into a single finding nor treated as unrelated events. They converge on one question: can the State reconcile the records describing the same revenue transaction? References: Audit Service Sierra Leone, https://website.auditservice.gov.sl; National Revenue Authority, https://www.nra.gov.sl/notices; Anti-Corruption Commission, https://www.anticorruption.gov.sl/blog/anti-corruption-commission-sl-news-room-1/post/acc-takes-over-investigation-bordering-on-revenue-diversion-at-the-national-revenue-authority-nra-1493

Commercial banks are central to answering that question because public revenue passes through several institutional stages. A Customs declaration recorded in ASYCUDA World proceeds to assessment, payment, receipt by a designated transit bank and eventual transfer to the Consolidated Fund. Every stage should leave documentary evidence. Where ASYCUDA records, bank records, transfer records and Treasury entries correspond, investigators can reconstruct the transaction. Where they do not, the discrepancy requires explanation. An exception is not proof of fraud, but it is precisely where forensic investigation should focus. Reference: National Revenue Authority, https://www.nra.gov.sl/notices

The reported allegation of more than Le300 billion therefore demands exceptional precision. It should not be combined with the Auditor General’s findings to create a larger headline figure because the audit observations concern different transaction populations and control failures. None establishes that the alleged Le300 billion was lost. The task is to identify the relevant declarations, assessments, payment references, bank entries, transfers and Treasury records, then determine which transactions reconcile and which do not. Only then can any discrepancy be properly valued, dated and explained. References: Audit Service Sierra Leone, https://website.auditservice.gov.sl; Anti-Corruption Commission, https://www.anticorruption.gov.sl/blog/anti-corruption-commission-sl-news-room-1/post/acc-takes-over-investigation-bordering-on-revenue-diversion-at-the-national-revenue-authority-nra-1493

The investigation should therefore begin with individual transactions rather than aggregate figures. Investigators should establish the declaration, importer or clearing agent, assessment, payment reference, receiving bank, amount, date credited, transfer to the Consolidated Fund and corresponding Treasury entry. Every deletion, amendment, reversal or refund should be matched with the responsible user, timestamp, authorisation and supporting documentation. Database logs should be compared with bank and Treasury records, while backups and audit logs should be examined where records have been deleted. This process distinguishes error from negligence, negligence from control failure and control failure from deliberate wrongdoing. References: National Revenue Authority, https://www.nra.gov.sl/notices; Anti-Corruption Commission, https://www.anticorruption.gov.sl/blog/anti-corruption-commission-sl-news-room-1/post/acc-takes-over-investigation-bordering-on-revenue-diversion-at-the-national-revenue-authority-nra-1493

The public debate should therefore move beyond the spectacle of a large alleged figure. The Auditor General documented weaknesses in revenue traceability, reconciliation and ASYCUDA controls in both 2023 and 2024. The NRA subsequently sought an independent reconciliation of ASYCUDA World transactions against transit bank records, while the ACC has confirmed an investigation into alleged revenue diversion. None of these facts, standing alone, proves criminal conduct. Together, they explain why the investigation deserves careful scrutiny and why its conclusions must ultimately rest on evidence rather than speculation.

If public money was properly assessed, paid, transferred and recorded, the documentary trail should demonstrate it. If it was unlawfully diverted, that same trail should reveal where the chain failed, how it failed and who was responsible. In public finance, ASYCUDA cannot tell the whole story on its own. Only when its records are reconciled with bank and Treasury evidence can allegations be tested and accountability established. The audit trail is not a footnote. It is the evidence.

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