Breaking News: Final Report for the Audit of Gambia High Commission London

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REPUBLIC OF THE GAMBIA
DIRECTORATE OF INTERNAL AUDIT MINISTRY OF FINANCE AND ECONOMIC AFFAIRS
76th INDEPENDENCE DRIVE, BANJUL, THE GAMBIA.
FINAL AUDIT REPORT
Gambian Embassy London, United Kingdom
Final Audit Report for the period 1stJanuary 2018 to 30th November, 2019
25th January, 2020
Assignment Ref: JD10/21/01 pt.9 (96)
Embassy Audit, London pg. 1

REPUBLIC OF THE GAMBIA
DIRECTORATE OF INTERNAL AUDIT
MINISTRY OF FINANCE AND ECONOMIC AFFAIRS
76th INDEPENDENCE DRIVE, BANJUL, THE GAMBIA.
Assignment Ref: JD10/21/01 pt.9 (96)
The High Commissioner Gambia High Commission London
United Kingdom
Dear Sir
25th January 2020
Final Report for the Audit of Gambia High Commission in London for the period 1st January 2018 -30th November, 2019
I am pleased to present the final audit report on the above mentioned audit.
A management response was received from the High Commission on the 21st February, 2020 to our audit findings and recommendations. This final report incorporates the management response to our findings and recommendations as well as the agreed upon timelines for the implementation of these proposed recommendations aimed at improving the internal control environment. Please note that follow-up audits will be conducted to ascertain the progress being made by management to address the issues raised.
We would like to take this opportunity to express our gratitude to all the staff of the Mission for their cooperation and support during the audit.
Please do not hesitate to get in touch with us should you need any clarification on any component of this report.
Regards
………………………………..
Modou Ceesay Director General
Cc: Secretary General, Office of the President
Embassy Audit, London pg. 2

Permanent Secretary, Ministry of Foreign Affairs
Permanent Secretary, Ministry of Finance and Economic Affairs Accountant General, Accountant General Department
Auditor General, National Audit Office
Permanent Secretary, Personnel Management Office Permanent Secretary, Ministry of Tourism
File
Embassy Audit, London pg. 3

Contents
1 Introduction ……………………………………………………………………………………………………………………. 6
2 Background……………………………………………………………………………………………………………………… 6
3 Audit Objective……………………………………………………………………………………………………………….. 8
4 Audit Scope……………………………………………………………………………………………………………………… 8
5 Audit Methodology…………………………………………………………………………………………………………. 8
6 Audit Findings and Recommendation………………………………………………………………………….8
6.1 Accounts and Finance ………………………………………………………………………………………………… 8
6.1.1 Suspected fraud and embezzlement of Public Funds ……………………………………. 8
6.1.1.1 Falsification of contract documents thereby misleading the Mission ……. 9
6.1.1.2 0verstating rent payments amounting to £2,200.00………………………………… 9
6.1.1.3 Illegally subletting government rented property for personal gain ………. 9
6.1.1.4 Falsely claiming deposit payment of £800.00 ………………………………………….. 10
6.1.1.5 Making false claims for rental accommodation………………………………………..10
6.1.1.6 Forgery of signatures with the intention of committing fraud ……………… 10
6.1.1.7 Subletting Council Tax exempted property………………………………………………. 10
6.1.2 Misclassification…………………………………………………………………………………………………. 12
6.1.3 Purchase of furniture, equipment and other items for home-base staff…..12
6.1.4 Frequent payment for taxi and other commercial transport ……………………… 14
6.1.5 Delays in banking ………………………………………………………………………………………………. 15
6.1.6 Unclaimed Value Added Tax payment ……………………………………………………………. 16
6.1.7 Balance of funds for medical treatment amounting to £6,274.61 not
refunded ……………………………………………………………………………………………………………………………. 16
6.2 Noncompliance to procurement procedures…………………………………………………………17
6.3 Other Operational Issues ………………………………………………………………………………………… 18
6.3.1 6.3.2 6.3.3 6.3.4
Annual staff report not prepared by the Mission………………………………………….. 18 High cost of service charges for the Finance Attaché residence ……………….. 18 Unoccupied Government Property…………………………………………………………………..19 Mission not providing oversight over the Tourism Attaché…………………………20
6.4.5
6.3.6
Conclusion: …………………………………………………………………………………………………………………………… 23
Official Car and Utility Car …………………………………………………………………………………… 21 Staff Annual Leave…………………………………………………………………………………………………22
Embassy Audit, London pg. 4

Acronyms
MOFEA Ministry of Finance and Economic Affairs MOFA Ministry Foreign Affairs
ADG Accountant General Department
FSR Foreign Service Regulations
PFA Public Finance Act
HMD Deputy Head of Mission FR Financial Instructions GMD Gambian Dalasi
PV Payment Vouchers
PS Permanent Secretary
People Interviewed During the Engagements
Name
Alieu Njie
Sulayman Suntu Touray Binta Charty
Bamba Mass
Mr. Alieu Jeng
Mrs. Ramou Ceeay
Mrs. Mariama Jammeh Fatajo Mrs. Amina
Designation
Deputy Head of Mission Counsellor
Finance Attaché Protocol Officer Tourism attaché Landlady
Gambian UK Resident
Tanzanian Immigrant Residing in the UK
Embassy Audit, London pg. 5

1 Introduction
The Internal Audit Directorate is mandated by the Public Finance Act and the Internal Audit Charter to conduct an audit on all government institutions including Ministries, Departments, Agencies and other institutions allocated directly or government funds.
The audit of the Gambia High Commissioner was part of the 2019 annual risk-based plan of the directorate.
During the audit engagement, an entrance meeting was held with the officials of the Mission to discuss the audit objective, the scope and the methodology to be applied during the audit.
At the completion of the audit field work, an exit meeting was conducted to brief management on the audit observations as well as sought clarification where required.
Based on the work we have performed during our audit of the Gambian mission in Jeddah, the assessment of the design of the selected controls within the cycles evaluated is as follows:
Process / Business Objective
Number of findings identified as:
Summary of
Evaluation
Low Risk
Medium Risk
High Risk
Control Issues Compliance Issues Governance Issues Fraud Issues
Total
Risk Classification
2 Background
– 4 3 07 – 2 2 04 – 0 4 04 – 0 6 06 – 6 15 21
It is probable that the identified risks have a negative impact on the audited body. Corrective action should be taken immediately.
There is a medium probability that the identified risks will have a negative impact on the audited body. Corrective action should be taken as soon as possible within the year. There is a low probability that the identified risks will have a negative impact on the audited body. Corrective action should be taken in order to enhance efficiency in the system.
Risk Type
Classification
High
Medium
Low
The Gambia High Commission in London is one of the oldest diplomatic Missions established by the Government of The Gambia. The Embassy is set to represent Gambians in providing efficient and responsive consular services to the Gambians in The United Kingdom and other accredited countries. It is also set to establish effective bilateral relations with accredited countries and other international organisations and further support the implementation and promotion of the Gambia’s foreign policy to advance our national interest.
Embassy Audit, London pg. 6

The Head of the mission is charged with the overall responsibility of the activities of the mission and he is assisted by other home-based staff and local staff in the discharge of his duties.
The day to day administration and coordination of the activities of the mission is delegated to the Deputy Head of Mission. The HMD is also responsible for the proper financial management of the Mission’s budget and its timely preparation for submission to the Permanent Secretary, Ministry of Foreign Affairs. He is assisted in this task by the Finance Attaché who is directly responsible to him.
The Finance Attaché is responsible for all the disbursements and receipt of revenue. These duties are exercised under the supervision of the Deputy Head of Mission and in compliance with the Public Finance Act and the Financial Regulations.
Source of Revenue
The main source of revenue for the Mission are visa fees, Authentication of Document, Emergency Travel Document and Legalization of Document
Accreditation
The Mission is accredited to the following countries in addition to the United Kingdom: • Ireland;
• Finland;
• Norway;
• Sweden;
• Israel;
• Austria; and
• Denmark;
Additionally, the Mission is also accredited to The Vatican;
Details of properties owned:
Address of Properties
Occupant
Status
57 Kensington London
92 Ledbury London
Court; Road;
Kensington, NottingHill,
Chancery Building Currently unoccupied
H.E The High Commissioner Finance attaché
High Commissioner Deputy Head of Mission Counsellor
Finance Attaché Protocol Officer
First Secretary Registered Address
Building in good condition but requires additional furnishing
Requires Maintenance and furnishing
Building in good condition and fully furnished
Building in good condition and fully furnished
35 The Avenue in Kilburn, London
Flat 12, Matlock Court, Kensington Park Road, London
Personnel Details: Home-Based Staff
H.E Francis Blain
Alieu Njie
Sulayman Suntu Touray Binta Charty
Bamba Mass Abu Bakr Jawara Bankers
Name of Staff
Designation
Embassy Audit, London pg. 7

Local Staff
Mrs Mama Conateh
Mr Buddhike Jayakody Mr Lamin B. Daffeh
Mr Kingsley Kofi Wilson Saffiatou Dodo
Mrs Maimuna Coker
3 Audit Objective
Personal Assistant Chauffuer
Cook
Cleaner
Maid Receptionist
Name of Staff
Designation
The key objective of this audit was to assess and evaluate the adequacy and effectiveness of the internal controls, risk management and governance processes of the Mission.
4 Audit Scope
The scope of the audit was from the 1st January, 2018 to the 30th November, 2019.
5 Audit Methodology
The audit methodology includes review of:
• Policies and procedures surrounding the Mission’s operations to assess adequacy of internal controls and governances processes.
• The Mission’s accounting records to ensure compliance with regulations;
• The Mission’s revenue collections and banking to ascertain accountability of government revenue;
• The Mission’s bank statement and bank reconciliations to ensure reconciliations are conducted accordingly;
• The assets and inventory register to assess and evaluate the adequacy of internal controls surrounding assets
and stores management;
• The personnel and payroll records to ensure compliance with government regulations;
• The day to day operations and discussed with management surrounding constrains faced by the mission.
We also conducted physical verification of government properties and other properties rented by government for home- based staff.
6 Audit Findings and Recommendation 6.1 Accounts and Finance
6.1.1 Suspected fraud and embezzlement of Public Funds
According to Sections 33 (7), 9 (7), 43 (c) and 39 (6) of the Financial Regulations:
1) The Vote Controller shall closely supervise and frequently monitor the transactions of each Sub-Treasury
because of the sensitive nature of cash transactions and the necessity to prevent fraudulent transactions,
forged signatures, false situations, etc.
2) A Sub-Treasury accounts officer or Finance Attaché shall take precautions against the occurrence of fraud,
embezzlement or carelessness by the maintenance of sufficient checks.
3) Vote Controllers shall ensure that adequate safeguards against evasion, fraud and carelessness are in
operation; and
4) The Permanent Secretary shall, where he or she is aware of, or suspects an Accounting Officer of, theft or
fraud, request the Inspector General of Police to carry out an investigation.
Section 0906 of the Foreign Service Regulations also states that: “The Head of Chancery must ensure that appropriate tenancy arrangements are entered into before any officer occupies a property rented. For all officers paid rent allowance it is mandatory to produce evidence of payment of rent for a period not less than 12 months”.
Embassy Audit, London pg. 8

Observations
During review of rent contract files, payment vouchers and other supporting documents presented to the audit team, we noted the following anomalies carried were out by Mr. Bamba Mass, Protocol Officer, surrounding his official accommodation:
6.1.1.1 Falsification of contract documents thereby misleading the Mission
Review of rent contract files, payment vouchers and other information gathered by the audit team revealed that Mr. Bamba Mass signed a rent contract document with a Landlady name Mrs. Ramou Ceesay for a 3 (three) bedroom property located at 72 Harrow Road, East Ham, London, effective 22nd May, 2018 for a period of three years as his official residence as protocol officer to The Gambian High Commission in London. The rental amount for this property was at a rate of £1,400.00 (One Thousand and Four Hundred British Pounds Sterling, GBP) per month. See Appendix 1
However, we noted that Mr. Bamba Mass did not present this said contract to the High Commission but instead presented a falsified contract using the same property address as above but at a rate of £1,600.00 (One Thousand Six Hundred GBP) per month signed by Ms. Mariama Fatajo Jammeh who falsely claimed to be the landlady. See Appendix 2
Both Mr. Bamba Mass and Mariama Fatajo Jammeh informed the audit team in the presence of the Deputy Head of Mission and the Finance Attaché that the contract Mr. Bamba Mass presented to the High Commission was false and it was intended to mislead the Mission to pay £200.00 (Two Hundred GBP) more than the actual contract amount.
6.1.1.2 0verstating rent payments amounting to £2,200.00
As evident in appendix 3 and appendix 4, the Mission was paying £1,600.00 (One Thousand and Six Hundred GBP) per month to Mariama Fatajo Jammeh base on the falsified contract presented by Mr. Bamba Mass. Documentary evidence presented to the audit team together with an interview with both Mr. Bamba Mass and Mariama Fatajo Jammeh in the presence of the Finance Attaché and the Deputy Head of Mission shows that Mrs. Jammeh transfers only £1,400.00 to Mrs. Ramou Ceesay (the rightful owner of the property) upon receipt of payment from the Embassy. The remaining £200.00 (Two Hundred GBP) is paid to Mr. Bamba Mass as instructed by him.
6.1.1.3 Illegally subletting government rented property for personal gain
Information gathered during the engagement revealed that Mr. Bamba Mass had rented part of his government rented residence to other tenants and collected revenue from them for his personal use. Documentary evidence provided by Ms. Mariama Fatajo Jammeh, a tenant and a Tanzanian lady called Mrs. Amina shows payment made from their bank accounts to Mr. Bamba Mass’s bank account in respect of their rent payments to him. See appendix 5 and appendix 6.
Mrs. Laila informed the audit team that she moved into the property on the 9th December, 2018 at an agreed rental amount of £350.00 (Three Hundred and Fifty GBP) per month with Mr. Bamba Mass. According to her, she made her first payment to Mr. Mass in cash on the 9th December, 2018. The second and third payments representing the months of January and February were also paid in cash but the March and April payments were made through bank transfer from her account to Mr. Bamba Mass’s account as shown in appendix 6.
The total amount collected by Mr. Mass from Mrs. Amina as rent payments in his government rented residence amounted to £1750.00 (One Thousand Seven Hundred and Fifty GBP).
Mrs. Mariama Fatajo Jammeh on the other hand informed us that she moved into the property with her daughter in May 2018 and was asked to pay £500.00 (Five Hundred GBP) by Mr. Mass. She informed us that she made payments to Mr. Mass both in cash and bank transfers. She also purchases gas and electricity during her stay in the property which is deducted from her monthly rent payments. See appendix 7
In addition, Ms. Jammeh had paid Mr. Mass £1,000.00 (One Thousand Pounds GBP) as deposit which he never paid to the landlady or disclosed to the Mission. This payment was confirmed by Mr. Mass during a meeting between internal audit, Mr. Mass, Ms. Jammeh, the Finance Attaché, the Deputy Head of Mission and Mrs. Ramou Ceesay.
Embassy Audit, London pg. 9

Therefore the total amount collected by Mr. Mass from Ms. Jammeh from a government rented residence amounted to £6,000.00 (Six Thousand GBP). This includes the £1,000.00 collected as deposit and Ten Months rented payment for the duration Ms. Jammeh stayed in the property.
6.1.1.4 Falsely claiming deposit payment of £800.00
Mr. Mass has claimed for refund of £800.00 (Eight Hundred GBP) as deposit he paid in respect of his accommodation. Interview with the landlady and a subsequent meeting between the audit team, Mr. Mass himself, the Deputy Head of Mission, Ms. Jammeh and the Finance attaché has revealed that Mr. Mass did not pay the deposit he claimed thereby diverting government funds for his personal use. Mr. Mass previously denied not paying the £800.00 but only decided to tell the truth following the presentation of evidence of nonpayment during the meeting. See Appendix 8
6.1.1.5 Making false claims for rental accommodation.
We noted that Mr. Bamba Mass was paid on the 6th August, 2018 a total amount of £5,585.00 as refund for rent payments for the period November to March at a rate of £1,000.00 per month and £1,600.00 for the month of April. See appendix 9. We noted that the claims for refund were made without a tenancy agreement and valid receipts. Only invoices were issued which did not have a business name, business address, contact details and other relevant information. In addition, we noted forgery of signatures on the invoices which were confirmed by Mr. Bamba Mass. An example, is the signatures in the invoice that was claimed to be issued by Dayna Luzuriaga which was different from the other signatures by the same person in the other documents reviewed by the audit team. See appendix 10 and 11.
A further review has revealed that the First claim of £5,000.00 for the months of November to March was for a property located at Birmingham, West of Midlands. Mr. Mass informed the audit team during an interview that he has lived in that property for several years prior to his appointment as a protocol officer at the Gambian High Commission in London. We also noted that the property is the address of the online media newspaper, the Kibaaro Newspaper, where he is an executive member.
Finally, Mr. Mass has acknowledged that he was not commuting to London from the said residence in Birmingham but instead, stayed with friends during the week in London and visits his family in Birmingham during the weekend. In addition, we have gathered information that he stayed with a friend called Ousman Minteh in his bed room during the month of April, 2018. However evidence has shown that he had claimed rent for the same month amounting to £1,600.00 (One Thousand and Six Hundred GBP) for a four bedroom house in the same address he was lodged by Mr. Ousman Minteh. See Appendix 12
Base on the above findings, we conclude that Mr. Mass’s claims were not genuine and were supported by falsified documents with the intention of committing fraud.
6.1.1.6 Forgery of signatures with the intention of committing fraud
We noted different signatures from the same person on different documents presented by Mr. Bamba Mass. Invoices presented by Mr. Mass claiming refund for payment of rent for the month of April, 2018 allegedly issued and signed by one Mrs. Dayna Luzuriaga and the signatures on documents allegedly signed by the same Mrs. Dayna Luzuriaga were found to be different. See appendix 10 and 11. This evidence was presented to Mr. Mass in the presence of the Deputy Head of Mission and The Finance Attaché during which Mr. Mass agreed that the signatures were different but he could not provide an explanation.
6.1.1.7 Subletting Council Tax exempted property
Mr. Bamba Mass was issued an exemption for the payment of council tax on the above mentioned property based on his status as a foreign diplomat. However, the other tenants residing in the property and paying rent to him were ordinary people who were not covered by the council tax exemption. See Appendix 13
Embassy Audit, London pg. 10

Summary of Suspected Fraud Committed by Mr. Bamba Mass, Protocol Officer
Details
Amount in GBP (£)
Amount in GMD (Rate as at 10th January, 2020
Overstating Rent Contract Falsely Claiming Rent Deposit Subletting Government Rented Property to Mrs. Dania, Tenant Subletting Government Rented Property to Ms. Mariama Fatajo Jammeh, Tenant
Making False Claims for Rental Accommodation
Implication
2,200.00 146,938.00 800.00 58,432.00
1750.00 6,000.00
5,585.00
116,882.50 400,740.00
372,693.20
Total
16,335.00
1,095,685.70
Risk Rating
High
The occurrence of such fraud, evasion and embezzlement of public funds as well as misleading the local authority in aiding the nonpayment of local council tax could expose the Mission to a serious reputational damage.
Recommendation
The Permanent Secretary, Ministry of Foreign Affairs and the Permanent Secretary, Ministry of Finance and Economic Affairs should take appropriate action to ensure the lost funds are recouped.
We also recommend that relevant disciplinary action is taken against Mr. Bamba Mass in accordance with the Public Finance Act, the Financial Regulations and the General Orders.
Finally the Permanent Secretary, Ministry of Foreign Affairs should ensure that rent contract agreements are signed by appropriate officers to avoid such anomalies.
Management Response
Action Plan
You wish to note that the issue of Mr Mass has been brought to the attention of the authorities in the communication GHC/L7/KB/ (13) 17 April 2019, a Circular within the Mission GHC/L43/FRB/ (150) of 31 August 2018 and the Internal Memo GHC/L43/KB/ (149) of 30 August 2018, all regarding his behavior and action has not been taken (copies attached).
With regards to the bogus arrangements he made for his accommodation, management have since moved him out to another property. Falsification of contract documents to mislead the High Commission, overstating rent payments, illegally subletting government rented property for personal gain, falsely claiming deposit payment, making false claims for rental accommodation, forgery of signatures with intention of committing fraud, subletting Council tax exempted property are unacceptable and both morally and procedurally indefensible. This is the highest level of fraud and Management awaits the relevant authorities to take appropriate action on the matter.
Honesty is paramount in any working environment without which it would be like spraying fertilizer on a dry empty land. The auditor team has done a brilliant job in unearthing all these discrepancies. The Deputy Head of Mission will ensure such discrepancies do not occur in the Mission.
Embassy Audit, London pg. 11

Responsibility
Time Frame
6.1.2 Misclassification
High Commissioner; Permanent Secretary, MOFA; Permanent Secretary, MoFEA Immediate
Section 9 (7) Duties of other financial officers; A Sub-Treasury accounts officer or finance attaché shall charge promptly in his accounts under the proper Heads, Sub-Heads and Items of expenditure all disbursement of public funds.
Observation
Review of the Mission’s payment vouchers, cash book and Vote Charge Book shows that some payments were made from incorrect budget lines. The Finance Attaché has acknowledged that the misclassifications were made due to budget shortfalls. See table below
Samples of misclassifications noted during the review:
101 Refund for cost of Sony Miscellaneous Budget line TV and Sofa Bed
405 Microwave for Finance Miscellaneous Budget line Attaché
Implication
71,703.29 2,472.34
PV #
Description
Account Paid From
Amount (GMD)
Risk Rating
Medium
Charging transactions to incorrect budget lines could lead to unnecessarily exhausting relevant budget lines.
This will also lead to inaccurate financial reporting since it does not provide management with accurate and realistic information on the Mission’s expenditure details.
Recommendations
The Finance Attaché should ensure that payments are charged against the correct budget lines in accordance with the Financial Regulations and the Accounting Procedure Manual.
The Head of Mission should ensure payment vouchers are approved only when transactions are charged to the correct budget lines.
Management Response
NA
Deputy Head Mission and Finance Attaché
Immediate
6.1.3 Purchase of furniture, equipment and other items for home-base staff
Section 0901 of the Foreign Service Regulations States that: ”The Head of Mission shall be provided with an official residence furnished and equipped to a standard commensurate with the requirements of his rank as listed in Appendix 1 to these Rules”.
Action Plan
Responsibility
Time Frame
Embassy Audit, London pg. 12

Section 0903 of the Foreign Service Regulations also states that: “All other Home-based Officers will be provided with suitably furnished accommodation commensurate with his/her rank and status as listed in Appendix 2. Rents allowance payable to officers in this case shall be on the basis of geographical regions defined hereunder”.
Observation
We noted that the Embassy procured furniture and fittings, household equipment and other items for home-based staff other than the Head of Mission contrary to the Foreign Service regulations. See table below
Items Procured for Home-Based Staff
PV #
Beneficiary Officer
Designation
Items Purchased
Cost (GMD)
69 Bojang
70 Bojang
81 Bojang
241 Abubakr Jawara 101 Abubakr Jawara
Implication
Deputy Head of Mission
Deputy Head of Mission Deputy Head of Mission First Secretary
First Secretary
TV Stand for DHM Bojang’s residence
Household items Household items
Bed and Matress
Sony TV and Sofa Bed
7,371.47
14,416.60 2,488.83 9,219.87 71,703.29
Risk Rating
High
The wrongful purchase of furniture and fittings, equipment and other household items for home-based staff who are not eligible for such entitlements would lead to nonconformance with the Foreign Service Regulations and the Financial Regulations as well as unnecessary budget overrun.
Recommendations
The Deputy Head of Mission should ensure that procurement for household items and other consumables are provided only for the Head of Mission.
The Permanent Secretary and the Deputy Head of Mission should ensure that all other Home-based Officers are provided with furnished accommodation as required by the Foreign Service Regulations.
Management Response
Action Plan
The Management has taken note of the observations and ensure that properties rented for staff are fully furnished by the landlord/landlady. The only properties to be furnished by the Mission would be the ones that belongs to the government of the Republic of The Gambia.
You may please note that furniture at the High Commissioner’s residence are old and need to be replaced. Quotations were forwarded to the Ministry of Foreign Affairs but I will endeavor to send more recent quotations for their perusal and necessary action.
The Finance Attaché and DHM in consultation with His Excellency the High Commissioner will ensure that properties are furnish before renting. Also purchase of household items will only for the His Excellency the High Commissioner.
Responsibility
Time Frame
Deputy Head Mission and Finance Attaché This will be with immediate effect
Embassy Audit, London pg. 13

6.1.4 Frequent payment for taxi and other commercial transport
Observation
We observed that the Mission has spent an exorbitant amount of fund on local transport. This includes taxi fares and train tickets. We also noted that some of the transport cost were made for receiving government officials from Airports on official visits to the United Kingdom. These officials are paid per diem to take care of their local transport needs and other related expenditures.
The audit team could not verify some of the transport cost since they could not be link to any official activity. However, we were informed by the mission that those activities were related to protocol and welfare engagements carried out by the Mission.
Implication
The payment of transport cost for government officials from Airports to various destinations would lead to duplicate payment since local transport cost are included in the Per Diem allowances paid.
There is also risk of unnecessary budget overrun by paying for unbudgeted and unauthorized expenditures.
Recommendations
The Deputy Head of Mission and Finance Attaché should ensure transport expenditures are made on only the mission’s official activities as budgeted.
The Deputy Head of Mission and the Finance Attaché should ensure sufficient supporting documents are provided for all transactions to further ensure accountability and transparency.
Management Response
Risk Rating
Medium
Action Plan
As you may be aware this Mission has been without a single vehicle for two and half years. The flag car was not roadworthy and cost the government fortune for maintenance. In June 2019 when I assumed the position of the Deputy Head of Mission, Management agreed that transportation could only be provided for the visiting Vice President, the Speaker of the National Assembly and the Chief Justice, since we do not have a utility car.
Recently, a flag car has been purchased for His Excellency the High Commissioner. The Mission still do not have a utility car that can be used for other official errands and also picking government officials to and from the airports in the United Kingdom. The hiring of taxis is quite exorbitant, but we have no alternative except to use them from time to time and provide receipts as evidence since we have no utility car to attend our respective meetings. You may note that there are a large number of Gambian communities in the United Kingdom and it is appropriate to attend their gatherings/meetings.
We have also realized that there is no 2020 vehicle budget line created for this Mission and therefore the struggle for transportation continues.
Responsibility
Time Frame
The High Commissioner and the Permanent Secretary, MOFA Immediate
Embassy Audit, London pg. 14

6.1.5 Delays in banking
According to Section 18 of the Public Finance Act 2014, Duty of Public Officer to Bank Public Money Received states that: “A public officer who receives public money shall promptly bank it in accordance with the Act, unless he or she is instructed in writing by the minister to do otherwise”.
Section 55 of the Financial Regulations, Daily Banking states that: “The total receipts of each day must be banked or handed over to a Sub-Treasury Accounts Officer the following day. This daily procedure may be waived by the Accountant General for revenue collectors at a distance from a bank or Sub-Treasury but in no case may the total sum held by a revenue collector in such circumstances exceeds D1, 000 or the period exceed one month, as the case may be”.
Observation
Receipt books, bank statements and other supporting documents reviewed during the engagement shows there was a delay in revenue banking. Documentary evidence reviewed by the audit team shows that revenues collected are sometimes banked two to three weeks or at times over a month after collection.
The Finance Attaché informed the audit team that the delays were as a result of transport constraints faced by the Mission. However, we noted that there was no formal authority from the Accountant General authorizing such delays as prescribed in the Financial Regulations.
Implication
The delays in banking revenues collected could lead to fraud, theft and misappropriation of hospital funds. Additionally the funds could be diverted for personal use which also leads to fraud.
There is also liquidity risk and risk to loss of interest realizable from bank balances due to delays in banking.
Recommendations
The Deputy Head of Mission should ensure that all revenues collected are promptly banked in accordance with the
Financial Regulations.
The Deputy Head of Mission should request for approval for delays in banking if required by the Mission in accordance with the Financial Regulations.
Management Response
Risk Rating
Medium
Action Plan
This is a catch 22 situation, simply because we have also been advised before, that it is not safe for the Finance Attaché to travel with government funds by public transport. As I mentioned earlier, the Mission had no vehicle, so it was either she take the risk of using the public transport or hire a taxi to go and deposit the money. But it also do not make sense after collecting an amount of £100.00 or less from revenue (for example) and hire a taxi for an amount of £35.00 every week. This is one of the reason why the revenue collected is bank at the end of every month.
Management will consider the risk involve as per your advised, but you may also note that revenue collection is currently far less now simply because most countries have been exempted from issuance of visas going to The Gambia.
Responsibility
Time Frame
Deputy Head of Mission Immediate
Embassy Audit, London pg. 15

6.1.6 Unclaimed Value Added Tax payment
The Mission is exempted from Value Added Tax and all other tax charges as a diplomatic mission based on the Geneva Convention, 1961. An exemption should be sought from the relevant authorities and where payment had already been made, the Mission should immediately apply for refund accordingly.
Observation
The audit team has noted that the Mission has being paying Value Added Tax (VAT) during the period under review contrary to the Geneva Convention 1961. There was also no evident of claims for VAT refund for the period under review.
Implication
The wrongful payment and lack of attempt to claim for VAT refund would lead to loss of revenue to the Mission.
Recommendations
The Deputy Head of Mission should ensure VAT exemption is applied for all payments made by the Mission in accordance with the Geneva Convention, 1961.
Where exemption could not be provided in making payments, the Mission should apply for refund from the relevant authorities based on the above convention to avoid loss of revenue.
Management Response
Deputy Head of Mission Immediate
6.1.7 Balance of funds for medical treatment amounting to £6,274.61 not refunded
Section 26 of the Financial Regulations, Execution of government budget states that: “A Vote Controller shall liaise with the Permanent Secretary to amend allocations and to initiate necessary supplementary appropriations and virements as a result of excesses discovered in the reconciliation process”.
Observation
Information gathered by the audit team revealed that payment was made by the Government the Gambia for three Gambians, Mr. Lamin Jawla, Mr. Demba Khan and Mrs. Njammeh Jallow to undergo medical treatment in the United Kingdom. We noted that funds were transferred to the Mission for their medical bills based on the Proforma invoices issued by the various hospitals.
However, review of payment vouchers and the Mission’s cash books presented to the audit team revealed that the actual amount paid for their medical treatment was less that the amount in the Proforma invoices thus leading to a balance of £6,274.61 (Six Thousand, Two Hundred and Seventy-Four GBP and Sixty-One pence).
Implication
Risk Rating
High
Action Plan
You may note that all diplomatic Missions are exempted from payment of tax based on the Geneva Convention 1961. The VAT refund is usually claim within the financial year of the host country. It may be an oversight by the former Deputy Head of Mission, but I (Deputy Head of Mission) will take it up with the Finance Attaché to claim for refund.
Responsibility
Time Frame
Risk Rating
Medium
Embassy Audit, London pg. 16

The funds may be used for non-budgeted expenditures if necessary actions are not taken to recover the balance or approval granted for virement or reallocation to other budget lines for their appropriate used as in accordance with the Financial Regulations.
Recommendations
The Deputy Head of Mission should notify the Accountant General of the remaining balance of funds to ensure the overpayment is recovered and accounted for accordingly.
Management should ensure there is a report surrounding medical treatment facilitated through the Mission including relevant financial information such as the amount of funds received for the treatment and related expenditures, the actual payment made by the Mission and any remaining balances or shortfall.
Management Response
Deputy Head of Mission; The Accountant General Immediate
6.2 Noncompliance to procurement procedures
According to Section 25 (3) of the GPPA Regulations, “procuring organizations shall devise procurement planning strategies and procurement packages taking into account the following factors and steps as appropriate under the circumstances:
(a) Identification and assessment of the need for the procurement;
(c) Conducting market research in order to identify various technical solutions, in particular in the commercial market, to identify the range of available suppliers, contractors, and consultants, and to determine the most favorable contractual and guarantee terms available in the commercial market place that would be suitable for public procurement;
(d) Studying acquisition history for similar objects of procurement;
(e) Conducting feasibility and other pre-contract studies;
(f) Defining and describing the requirement;
(g) Estimation of the cost of a proposed procurement;
(i) Selection of contracting approach and structure, including verification of possible availability of umbrella or framework contract arrangements for the item in question; and
(j) Selection of appropriate procurement method.
Observation
Review of the Mission’s procurement processes revealed that procurement for goods and services were made without formal requisition and approval before procurements are conducted as required by the regulations. However, we noted that necessary quotations were solicited and where necessary, contracts were signed as per the regulations.
Implication
The lack of proper review and approval at the initiation of procurement proceedings may lead to ineffectiveness and inefficiency in the Mission’s procurement process.
Recommendations
Action Plan
The above mentioned balance of funds have been in the Mission’s account for some years now and it is always indicated in the cash book at the end of every month. This Mission would appreciate if it would be augmented to our furniture and fittings budget line to enable us to furnish our conference hall. This is because returning the amount would be very costly through the bank transfer.
Responsibility
Time Frame
Risk Rating
Medium
Embassy Audit, London pg. 17

The Deputy Head of Mission should ensure a requisition is raised and approved before procurements are conducted by the Mission as required by the Public Procurement Regulations.
Management Response
Deputy Head of Mission Immediate
6.3 Other Operational Issues
6.3.1 Annual staff report not prepared by the Mission
Section 0222 of the Foreign Service Regulations, Annual Staff Report states that: “Annual Staff Reports shall be submitted in accordance with the Regulations and Procedures in force in the Civil Service. Reports on the Head of Chancery and officers above his/her rank shall be prepared by the Head of Mission. For other home- based officers, it is the responsibility of the Head of Chancery to prepare and submit reports on them through the Head of Mission”.
Observation
Review of staff files and interview with management revealed that the Mission had not prepared and submitted annual staff report as required by the Foreign Service Regulations during the period under review.
Implication
The absence of annual staff report would lead to ineffective appraisal and evaluation of staff performance to ensure activities are align to the Mission’s strategic and operational objectives.
Relevant information to identify and established capacity gaps may not also be available in the absence of annual staff reports.
Recommendations
The High Commissioner and Deputy Head of Mission should ensure annual staff reports are prepared and submitted as required by the regulations.
Action Plan
I have made emphasis of having three quotations for every item we are purchasing and also to follow the normal administrative procedures by submitting an internal memo request for the approval of His Excellency the High Commission for appropriate action. The Deputy Head of Mission (myself) will guide every staff for this smooth implementation.
Responsibility
Time Frame
Risk Rating
Medium
Management Response
Action Plan
We have taken note of your observation and wish to inform you that the Deputy Head of Mission (my humble self) will endeavor to submit annual staff report during my tenure in this Mission. I am aware that it has not been submitted all these years. Deputy Head of Mission
Immediate
Responsibility
Time Frame
6.3.2 High cost of service charges for the Finance Attaché residence
Section 38 of the Financial Regulations, Government stores: “The Permanent Secretary may, on the advice of the Accountant General and the Vote Controller of the department concerned, lease or sell land and buildings owned by the Government”.
Observation
Embassy Audit, London pg. 18

The Government of The Gambia has owned among other properties an apartment located at Matlock Court, Kensington Park Road, London. This property is within an apartment complex under the management of Burlington Estate Agency. The agency is responsible for providing necessary maintenance of the apartment and its surrounding. They also provide security services for the complex. However, there is a substantial service fee levied on each apartment owner including the Gambia High Commission to cover these cost.
We noted that an amount of £9,160.66 (Nine Thousand, One Hundred GPB and Sixty-Six cense) is paid annually as maintenance cost. (Obtain the details of charges as per the email forward)
However, we noted that the Mission has engaged the Ministry of Foreign Affairs to sought approval to sell and purchase a cheaper property so as to avoid high cost maintenance.
Implication
There is risk of legal action from the property manager/estate manager due to nonpayment or delays in payment.
The High maintenance cost would also lead to financial burden on the Missions budget.
Recommendations
We recommend that the apartment should be sold to purchase a cheaper property to avoid the exorbitant payment of service charges in maintaining the property.
To ensure value for money, the Ministry could also consider renting the property and used proceeds from the rent to pay for accommodation for the home-based staff instead of allocating the property to staff at high maintenance cost.
Management Response
Permanent Secretary, MOFA; The High Commissioner Under implementation
6.3.3 Unoccupied Government Property
Observation
The Mission had relocated to the new Chancery building located at 57 Kensington Court; Kensington, London, following the rehabilitation of the property. This has left the former Chancery building at Number 92 Ledbury road unoccupied. Physical inspection of the property in the presence of the Deputy Head of Mission has shown that the property is in need of rehabilitation to make it suitable for accommodation. Thus it could be a potential official residence for home- based staff or rented out by the Mission to generate income based on its strategic location.
Implication
The building may continue to dilapidate if necessary maintenance work is not carried work and this could further affect the economic value of the property.
Recommendations
Risk Rating
High
Action Plan
I have been instructed by His Excellency the High Commissioner to find quotations for the sale of the said property and then search for the cost of three more properties. This is since the cost of maintaining the property is quite expensive and cost Government fortune. I (Deputy Head of Mission) have taken some sale agents to the property to view it and we are expecting the quotations which will be forwarded to Banjul for appropriate action.
Responsibility
Time Frame
Risk Rating
High
Embassy Audit, London pg. 19

The Permanent Secretary, Ministry of Foreign Affairs and the High Commissioner should further engage the Ministry of Finance to provide the necessary funds required for the rehabilitation of the property.
The Permanent Secretary Ministry of Foreign Affairs should consider renting the property including the based for potential revenue source or relocate some of the home-based staff to save cost.
Management Response
Permanent Secretary, MOFA; The High Commissioner Immediate
6.3.4 Mission not providing oversight over the Tourism Attaché
Attaché are officers from outside the Ministry of Foreign Affairs posted to overseas Missions to perform special duties on behalf of the parent government institution.
Observation
We noted with concern that the Tourism Attaché posted to the Mission does not report functionally or administratively to the Head of Mission. Interview with the Head of Mission and the Tourism Attaché revealed that there is no functional reporting line between the Mission and the Attaché. The Tourism Attaché reports directly to Tourism Board.
He also received allocations including his monthly salary and other operational expenses directly from the Gambia Tourism Board through his personal account.
Additionally, the tourism attaché carries out expenditures and other financial commitments relevant to his office operations all by himself without the required segregation of duties as required by Public Finance Act and the Financial Regulations.
Implication
The lack of functional and administrative reporting to the Head of Mission would lead to inadequate oversight on the work of the tourism attaché.
There would also be ineffective coordination of government activities at the level of the Mission if the work of the tourism attaché is isolated from other responsibilities of the Mission.
Recommendations
The Permanent Secretary, Ministry of Foreign Affairs and the Permanent Secretary, Ministry of Tourism and Culture should ensure that the Attaché reports functionally and administratively to the Head of Mission. This does that affect his reporting requirements to his/her parent ministry as in the case of the Finance Attaché.
All financial transactions and other financial commitments relating to the activities of the Tourism Attaché should be facilitated by the Mission.
Management Response
Action Plan
The 92 Ledbury Road is a property of the Government of the Republic of The Gambia and it used to be the chancery building up to December 2018. As the auditor indicated, this is unoccupied and some damages have occurred on both internal and external part of the building. It needs urgent refurbishment for a member of staff to occupy the property.
I have been inviting contractors to view the property and to provide us with three quotations as soon as possible in accordance with the GPPA rules. This will reduce the cost of rent for at least one member of staff.
Responsibility
Time Frame
Risk Rating
High
Embassy Audit, London pg. 20

Action Plan
Ministry of Tourism: The Tourism Attaché (Destination manager) is posted by the Gambia Tourism Board based on government’s initiative to employ the service of home based staff to support the promotion of tourism and tourism related activities in the United Kingdom. However, he/she is required to liaise with the mission as well as be under the supervision and oversight of the head of mission. However, he should also be accountable and report functionally to the Gambia Tourism Board.
High Commission: The past few years the tourism section of this Mission has been functioning independently, since the posting of the current Tourism Destination, it would be ideal if it is under the purview of the Mission in order to help in the promotion of the Gambia’s tourism sector.
Responsibility
Time Frame
Destination Manager; The High Commissioner; Permanent Secretary, Ministry of Tourism and Culture
Immediate
6.4.5 Official Car and Utility Car
SECTION 6 of the Foreign Service Regulations, Transport, states that: “The Government shall provide an Official Car and a utility car for all Heads of Mission. A utility car shall be provided for the day to day services of the Mission. The control of the utility car is delegated to the Head of Chancery for official services. In the event the Mission has only one utility car, it should only be used for the day to day running of the Mission”.
Observation
The Mission was without an Official Car and a Utility Car during the period under review. Review of the Mission’s cash books and Bank Statements shows that there was a transfer of funds for the purchase of Official Car and the procurement for the said car was also being carried out as shown in the procurement files presented to the audit team during the engagement.
We were informed by management that the procurement for the Official Car was completed and the vehicle had been delivered to the Mission by the supplier.
However, the Mission is still not provided with a Utility Car to enhance their day to day official activities as required by the Foreign Service Regulations.
This has led to the high transport cost incurred by the Mission due to hiring of commercial transport.
Implication
The absence of a Utility Car would adversely affect the operation of the Mission and further lead to increase in transport cost as evident during the review.
Recommendations
The Permanent Secretary, MOFA should ensure the allocation of Utility Car to the Mission as required by the Foreign Service Regulations.
Risk Rating
High
Management Response
Action Plan
Responsibility
Time Frame
Please be informed that the official (flag car) that was recently purchased has been delivered to this Mission. It is a BMW 740 li petrol but still we do not have a utility as mentioned earlier in the report.
Permanent Secretary, MOFA
To be communicated
Embassy Audit, London pg. 21

6.3.6 Staff Annual Leave
Section 04102 of the General Order states that: “Leave Entitlements shall be taken by all Civil Servants on an annual basis. Failure to abide by this requirement automatically leads to forfeiture of earned leave, unless deferment is considered to be in the interest of the Public Service, and is permitted by the Heads of Department. All Departments and Ministries shall maintain Annual Leave Rosters for all staff, which shall be strictly adhered to”.
Observation
We noted with concern that most of the Home-Based staff were on leave as at the start of this review. Among the seven home-based staff posted to the Mission, only three were on duties. The remaining officials were on leave. There was no annual leave roster.
It was further observed that the service delivery and necessary segregation of duties was also affected during the engagement since there were only three staff on duties including the Finance Attaché and the Tourism Attaché.
Implication
The functions of the Mission could be affected due to the high rate of absence of key staff.
Recommendations
The High Commissioner and the Deputy Head of Mission should maintain an Annual leave Roster and ensure approval for annual leave is granted according to the roster as required by the General Order.
Management Response
Risk Rating
High
Action Plan
Management will prepare a new annual leave roster in which none of the home based will proceed on leave at the same time. The previous one was prepared before I assumed the position of Deputy Head of Mission.
Conclusion:
On behalf of the staff of the Mission and my humble self, I wish express sincere thanks and appreciation to the staff of the Internal Audit for carrying out this exercise. The final report will be a guiding document for every member of staff of the Mission. I hope this type of auditing exercise continues from time to time.
Please be informed that Management has taken note of the issues raised in the draft audit report very seriously and wishes to assure that will not leave any stone unturned in ensuring such discrepancy will never be repeated in this Mission.
Responsibility
Time Frame
Permanent Secretary, MOFA; The High Commissioner Immediate
Embassy Audit, London pg. 22

Conclusion:
The audit was conducted with due regards to independence, objectivity and professionalism to ensure sufficient evidence was gathered to support our findings. Recommendations were made related to the findings to help management better managed public funds efficiently and effectively towards achieving better public service delivery.
Our audit reveals that, there are significant suspected fraudulent activities perpetuated by Mr. Mass and hence we strongly advised that the suspected fraud is immediately reported to the necessary authorities for further actions.
We advise that the Head of Mission, Permanent Secretary, MoFA and the Accountant General should investigate the misused public monies and fraudulent claims immediately and take necessary disciplinary actions as prescribed in the Financial Regulations and other laws.
We recommend that all misappropriated funds be fully recovered and paid immediately into the mission’s bank account.
We do hope that management will find it useful to act on the recommendations and work on strengthening and improving on the internal controls, risk management and governance issues surrounding the process within the Mission, to ensure that public funds are manage efficiently and effectively for the purpose they are meant for and in compliance with the regulatory frameworks.
The Directorate of Internal Audit would like to thank the Gambia High Commission London for their cooperation during the audit and the support given to the team.
Embassy Audit, London pg. 23

Appendix 1
Embassy Audit, London pg. 24

Embassy Audit, London pg. 25

Appendix 2
Embassy Audit, London pg. 26

Embassy Audit, London pg. 27

Appendix 3
Embassy Audit, London pg. 28

Appendix 4
Payment of remaining balance to Mr. Bamba Mass from the amount paid by The Mission
Embassy Audit, London pg. 29

Appendix 5
Rent payment by Mrs. Mariama Fatajo Jammeh to Mr. Bamba Mass
Embassy Audit, London pg. 30

Appendix 6
Sample of Rent Payment from Mrs. Lalia to Mr. Bamba Mass
Embassy Audit, London pg. 31

Appendix 8
Falsely Claimed Deposit payment in respect of Bamba Mass’s Residence
Embassy Audit, London pg. 32

Appendix 9
Payment for Refund of House Rent Allowance to Mr. Bamba Mass
Embassy Audit, London pg. 33

Appendix 10
Signature of Dania Luzuriaga Different from her Signature in Appendix 11
Embassy Audit, London pg. 34

Appendix 11
Signature of Dania Luzuriaga Different from her Signature in Appendix 10
Embassy Audit, London pg. 35

Appendix 12
One Month Rent Falsely Claimed by Mr. Bamba Mass for the Month he was lodged by a Friend
Embassy Audit, London pg. 36

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