Legislation: Corruption in the form of active and passive bribery is covered by the Sudan Penal Code 2003. In addition, the major forms of corrupt activity, including attempted corruption, extortion, bribing a foreign official, and money laundering are criminalised. Moreover, Sudan signed the United Nations Convention against Corruption (UNCAC) in 2005 and the African Union Convention on Preventing and Combating Corruption in 2008, but has not yet ratified either of them. According to the Heritage Foundation 2011, laws that increase transparency, such as access to public information and financial disclosure of public officials, do not exist in Sudan. In an effort to combat corruption, Southern Sudan's Legislative Assembly passed a long awaited Anti-Corruption Bill in March 2009, thus supplying the legal framework of the Southern Sudan Anti-Corruption Commission (SSACC). As reported in a March 2009 news article by The New Sudan Vision, the law provides for the establishment and governance of an independent commission to prevent and combat corruption at all levels of government and institutions. The law will make it possible for the SSACC to investigate the many corruption complaints it has received over its years in existence. Access the Lexadin World Law Guide for a collection of legislation in Sudan.

Government Strategies: The federal Government of Sudan does not seem to prioritise anti-corruption measures. There are no sources indicating that anti-corruption policies are being formulated or that institution-building is taking place. The overall national focus is mainly on national security. Southern Sudan has taken the initial steps towards combating corruption with the announcement of a zero-tolerance attitude towards corruption and the passing of an anti-corruption law in 2009. However, as Southern Sudan has only existed for a few years, it is politically inexperienced and its capacity to govern is very frail. Hence, it remains to be seen if Southern Sudan can make any concrete improvement vis-a-vis containing corruption. In December 2009, the Southern Sudan Anti-Corruption Commission (SSACC) launched a five-year Anti-Corruption Strategy and Action Plan 2010-2014, which have been developed through consultation with stakeholders in the government, private sector and civil society. The Anti-Corruption Strategy involves a number of strategic goals, including combating corruption, promoting good governance, investigating and prosecuting corrupt individuals, and promoting cooperation among different stakeholders in fighting corruption. As part of the Anti-Corruption Strategy, the SSACC issued a Declaration of Income, Assets and Liabilities Form to all executive and legislative officials and senior civil servants to disclose their income and assets by the end of February of each year, as reported by The New Sudan Vision in 2010. This initiative is aimed at combating corruption among public officials and bringing them to account, given the rampant corruption among high level officials.

Anti-Corruption Agency: There is no anti-corruption agency at the federal level in North Sudan. In Southern Sudan, the Southern Sudan Anti-Corruption Commission (SSACC) was created by the Interim Constitution of Southern Sudan and the SSACC Act in 2006, and has a mandate to investigate both public and private corruption in the semi-autonomous region. According to a 2009 news article by Sudan Tribune, the SSACC were to be empowered to investigate and prosecute those suspected of corruption - tasks formerly left to the Ministry of Legal Affairs and Constitutional Development (MOLACD). According to the UNDP Southern Sudan Update October 2009, the SSACC has established offices in six out of ten states, and trained its employees. However, issues such as under-staffing and insufficient funding remain some of the challenges it faces. The SSACC runs education and awareness-raising programmes about corruption, and the SSACC has also been called upon to take part in several national and GoSS level corruption investigation committees. Before 2009, the SSACC did not have any legal mandate to carry out its duties. Such mandate came in March 2009, with the passing of the Anti-Corruption Bill. In July 2009, the SSACC conducted induction training for several investigators from law enforcement agencies. Staff at the SSACC has announced that it will use the legislation to initiate at least 10 new investigations. The SSACC has recently been given a special status beyond other public institutions. Hence, according to a resolution passed in August 2009 by the Council of Ministers, the employees of the SSACC will have their salaries increased above the normal public service increment regulations. In addition, the status of the Chairperson of the SSACC has been upgraded to the status of a minister in the government, as reported by Sudan Tribune in August 2009. In January 2011, the SSACC stated that it has gathered relevant information about suspected government officials who had stolen money, mostly from the oil revenues, and deposited it in foreign banks. However, the head of the SSACC revealed that the Commission lacks power to prosecute suspects. The Commission refers cases to the MOLACD which, will proceed with further action. However, according to a 2011 news article by Sudan Tribune, the latter has been criticised by the public for not prosecuting suspects for many years.

Auditor General: Sudan has an Auditor General's Chamber which, in law, is protected from political interference. However, according to Global Integrity 2006, it is subject to political interference and suffers from a lack of resources. Appointments are often made based on political criteria. It is further reported that the Auditor General makes reports publicly available, but that the government rarely reacts to the reports' findings. Three high-ranking employees of the Auditor General's Chamber, including the Deputy Auditor General, have been suspended on corruption charges pending investigation in a 2007 corruption case in which USD 85,000 were allegedly siphoned off the finance ministry, as reported by Miraya FM in 2008. In fact, this type of alleged embezzlement is not uncommon in Sudan. For instance, the Auditor General Report 2008 found that USD 2.3 billion was embezzled from government institutions, according to the US Department of State 2009. Nonetheless, at the same time, the Auditor General has emphasised that less public funds were embezzled in 2009 as compared to the previous year, which could be considered as a slight improvement.

Fiscal, Financial Allocation and Monitoring Commission (FFAMC): The FFAMC was established by the Southern Sudanese government to promote transparency and fairness in relation to the allocation of funds to the states and local governments in Southern Sudan. The FFAMC reports on a quarterly basis to the President and the Southern Sudan Legislative Assembly. Read more about the FFAMC here.

Ombudsman: The National Commission for Redress of Public Sector Grievances (NCR) is Sudan's equivalent to an Ombudsman. According to Global Integrity 2006, the NCR is poorly protected from political interference in practice. Furthermore, according to the report, the government does not act on the findings of the NCR; in fact, the agency's reports are usually ignored or given superficial attention. The NCR is poorly staffed and underfunded. If the NCR makes reports, they are either outdated or unavailable to the public.

E-Governance: In general, e-governance in Sudan is not well-developed and federal or local governments and ministries offer very little information online about the country and public services. Companies considering investing in Sudan, however, may find the website of the Ministry of Investment useful. Apart from providing investment information, it also has several online services concerning registration, licences and permits.

Public Procurement: According to Global Integrity 2006, Sudan drafted and passed a public procurement law in 2006. The law demands that major public procurement projects go through a competitive bidding process. According to the law, companies that violate procurement rules can be barred from participating in future tenders. Unsuccessful bidders may challenge the procurement decision in court. However, the enforcement is very weak. For example, companies with good political connections are in fact not barred from the procurement process despite having broken the procurement law. The public procurement law also covers conflicts of interest for procurement officials. According to Global Integrity 2006, major public procurements are typically advertised in Khartoum daily newspapers, but in most cases not for more than a week due to the cost of advertisement.

Whistle-Blowing: By law, whistleblowers in Sudan are protected from recrimination when reporting corruption (Criminal Law, Article 57). However, according to Global Integrity 2006, in practice, whistleblowers are not protected from recrimination, particularly if the person implicated in corruption has political connections. Hence, the report assesses whistle-blowing measures in Sudan as 'very weak'. Allegedly, the Southern Sudan Anti-Corruption Commission (SSACC) has an internal reporting mechanism through which citizens can report corruption. However, since the SSACC does not have an official website, it is unknown how complaints are submitted.

General Comments on the Public Anti-Corruption Initiatives: Sudan's legislation criminalises corruption, but anti-corruption laws are not effectively enforced in reality. Public institutions and both high and low-ranking public officials are criticised for being poorly trained and highly corrupt. South Sudan gained regional autonomy from the North in 2005, and the formal declaration of independence will take place in July 2011, after nearly 99% of South Sudanese voted for separation in the January referendum. South Sudan’s President, Salva Kiir, has announced a ‘zero-tolerance policy’ on corruption in the new nation. Several steps have been taken in combating corruption, such as ordering all of its government officials to declare assets and income annually, and the passing of the Anti-Corruption Bill in 2009. Nevertheless, the institutional setup for countering corruption remains weak, and further measures are needed in order to combat corruption fully.