MIIF Audit Breach: GH¢11 Million Unapproved Overseas Travels Exposed by Confidential Report

Introduction

A confidential audit by the Ghana Audit Service has spotlighted a significant breach at the Minerals Income Investment Fund (MIIF), where the board and key staff expended over GH¢11 million on overseas travels in 2024 without required executive approvals. This revelation, first detailed through documents obtained by JoyNews, underscores critical lapses in compliance with Ghana’s public sector travel protocols. MIIF, established under the Minerals Income Investment Fund Act, 2018 (Act 978), manages revenues from Ghana’s mineral resources to fund developmental projects, making fiscal accountability essential.

Why does this matter for transparency in Ghana’s sovereign wealth management? Public funds demand strict oversight to prevent misuse, and violations of the Ministry of Finance’s October 2020 Administrative Guidelines for Foreign Travel Allowances highlight systemic risks. This article breaks down the audit findings, official responses, and broader implications for MIIF unapproved travels and public expenditure controls.

Analysis

The core issue revolves around non-adherence to established protocols for international business trips by public officers. In-depth examination of the confidential report reveals how MIIF’s leadership bypassed mandatory clearances, exposing vulnerabilities in internal governance.

The Audit Revelations

The Ghana Audit Service document explicitly states that MIIF’s board members and senior startup team spent more than GH¢11 million on overseas journeys in 2024 without prior authorization from the Chief of Staff, the sector minister, or the Chief Director. This contravenes the 2020 Ministry of Finance directive, which mandates that no public officer undertake official foreign travel without clearance via the Chief of Staff’s office. For officers at Director level and below, approvals must come from the sector minister or Chief Director—a step entirely omitted here.

Auditors emphasized MIIF’s disregard for these guidelines, noting the absence of any supporting documentation. This breach not only inflated travel costs but also questioned the necessity and oversight of such expenditures in a fund tasked with prudent mineral revenue investment.

Official Responses and Defenses

MIIF’s Head of Human Resources countered that all travels needing CEO or Chief Director approval were duly processed, with multinational trip requests for senior staff handled per directives from the CEO’s secretariat. Verification memos were claimed to be available. Former MIIF CEO Edward Nana Yaw Koranteng asserted that the Chief of Staff had been informed of all trips, though auditors found no corroborating correspondence.

During a recent Public Accounts Committee (PAC) appearance, Acting MIIF CEO Justina Nelson justified high meeting-related spending as vital for enhancing the Fund’s visibility and operational capacity at its new office. These responses, while providing context, did not fully address the audit’s evidentiary gaps.

Summary

In summary, a Ghana Audit Service confidential report exposed the Minerals Income Investment Fund (MIIF) board and key staff’s expenditure of over GH¢11 million on unapproved overseas travels in 2024, violating Ministry of Finance guidelines requiring Chief of Staff and ministerial clearances. Additional audits flagged GH¢2 million in sitting allowances over two years, with GH¢1.2 million in 2024 alone. Despite defenses from MIIF officials citing internal processes and notifications, no proof satisfied auditors. This case exemplifies challenges in enforcing travel protocols amid Ghana’s public funds management.

Key Points

Practical Advice

For public institutions like MIIF navigating Ghana overseas travel approvals, adherence to protocols is non-negotiable. Here’s pedagogical guidance drawn from the guidelines:

Step-by-Step Approval Process

1. Pre-Approval Submission: Submit detailed trip memos to the CEO/Chief Director for internal review, including purpose, itinerary, and budget.
2. Escalation to Authorities: For Director-level and below, route via sector minister/Chief Director; senior officers via Chief of Staff.
3. Documentation Retention: Maintain verifiable correspondence, approvals, and expense receipts for audits.
4. Budget Justification: Link travels to core mandates, like MIIF’s mineral investment goals, with cost-benefit analysis.

Implement digital tracking systems for requests to enhance transparency. Training on these guidelines, as per Ministry directives, equips staff to avoid breaches.

Points of Caution

Non-compliance with travel rules carries substantial risks for entities like the Minerals Income Investment Fund. Key cautions include:

• Audit Exposure: Confidential reports can surface via media like JoyNews, leading to public scrutiny.
• Financial Clawbacks: PAC may surcharge individuals for unauthorized spending, as seen in prior Ghanaian cases.
• Reputational Damage: Scandals erode trust in sovereign funds managing vital mineral revenues.
• Operational Halts: High-visibility expenditures without proof can delay project funding.
• Board Accountability: A 9-member board’s collective lapses amplify personal liability under public finance laws.

Proactive compliance prevents escalation, safeguarding public resources.

Comparison

Contrasting MIIF’s GH¢11 million unapproved travels with other public entities reveals patterns in Ghana’s fiscal oversight. For instance, the same audit period noted MIIF’s GH¢2 million sitting allowances over two years—far exceeding typical benchmarks for a 9-member board. In 2024 alone, GH¢1.2 million dwarfed 2023’s ~GH¢1 million, signaling unchecked escalation.

Versus National Guidelines

The 2020 Ministry guidelines cap allowances and mandate approvals uniformly across public carriers. MIIF’s breach mirrors isolated incidents in other funds but stands out due to scale relative to its mineral revenue mandate. Compared to approved travels in peer funds like the Ghana Petroleum Funds, MIIF’s lack of documentation highlights governance disparities.

Year-on-Year Trends

Travel spikes in 2024 align with new office setup claims, yet without approvals, they contrast with budgeted, verified expenditures elsewhere.

Legal Implications

This MIIF audit breach triggers administrative and potential accountability measures under Ghanaian law. The Public Financial Management Act, 2016 (Act 921), mandates lawful expenditure of public funds, with violations reportable to PAC for surcharges or disallowances. The Minerals Income Investment Fund Act, 2018, requires the Fund to operate transparently, amplifying scrutiny.

No criminal charges are cited in the report, but PAC proceedings—as attended by Acting CEO Justina Nelson—can lead to personal financial recovery. Breaching travel guidelines constitutes a procedural infraction, enforceable via internal discipline or ministerial directives. Verifiable precedents include PAC surcharges in similar audit findings across Ghanaian institutions.

Conclusion

The exposure of GH¢11 million in MIIF unapproved overseas travels via a confidential audit serves as a stark reminder of the need for rigorous compliance in Ghana’s public sector. While MIIF officials defend the expenditures as essential for visibility and operations, the absence of approval evidence underscores gaps in accountability. Strengthening internal controls, documentation, and training will mitigate future Minerals Income Investment Fund scandals. Ultimately, safeguarding mineral revenues demands unwavering adherence to protocols, ensuring funds benefit national development.

This incident reinforces the role of audits and media in fostering transparency, urging all public entities to prioritize verifiable processes.

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