The Association of Southeast Asian Nations (ASEAN) is taking a major step toward greater regional economic integration at the end of this year, with the long-awaited launch of the “ASEAN Economic Community”, a region-wide agreement designed (among other things) to promote the freer movement of goods, capital, and labor throughout the region. Yet many worry that this greater economic integration might exacerbate the region’s already serious struggles with corruption, especially cross-border corruption. Largely in response to that concern, last April Transparency International published a report calling for the creation of an “ASEAN Integrity Community” (AIC) that would, in the words of the report, “create a coherent regional anti-corruption strategy” and “provide space for civil society and the business sector to be able to have input into and shape this regional anti-corruption agenda.”

It’s an intriguing idea, and the report is worth reading. (Full disclosure: I wrote a background paper for one of the meetings TI organized last September to discuss corruption challenges in ASEAN. Indeed, substantial chunks of the background paper that I wrote appear – uncredited – in the TI Report on the AIC.) Certainly, there’s a good case to be made for greater regional cooperation on anticorruption challenges within ASEAN. That said, I found the TI report on the proposed AIC frustrating in several respects, most significantly the vagueness regarding how, exactly, the AIC would operate, and how it would add value above and beyond the existing regional forms and groupings that address corruption issues. I realize that this is an early-stage proposal, designed to generate political momentum for greater action and political buy-in (particularly in advance of the International Anti-Corruption Conference in Malaysia next week), so it may not really fair to criticize the report for being a bit light on specifics. Still, it’s worth reflecting a bit more on what we might hope to get out of something like an AIC, and whether this is the right way to go about tackling what most experts would agree is a genuine and serious set of problems and challenges.

One unfortunate feature of the report is that it’s not really structured around the specific AIC proposal, what it would do, how it would operate, etc. Rather, a great deal of the report is about corruption in Southeast Asia generally (with the typical semi-random collection of statistics and quotes from other reports), and the need for various reforms (most of which seem like excellent ideas, but that don’t have much to do with the specific proposal for an AIC per se). But from my reading of the report, I can glean four main contributions that I think TI believes the AIC could make:

• First, the AIC could serve as a high-level form for coordinating international cooperation among ASEAN member states on transnational corruption issues within the region.
• Second, the AIC could help the ASEAN member states develop a common set of priorities, and a general strategy, for combating corruption at the national level, including (presumably) a forum that would put more political pressure on laggard states to address high-priority issues (such as freedom of information, asset declaration, etc.).
• Third, and as a kind of supplement to the first two goals, the AIC could give civil society and the business community more of an opportunity to interact with, and influence, high-level government officials on issues relating to anticorruption strategy.
• Fourth, the AIC could monitor progress toward meeting both regional and global anticorruption goals, through setting of benchmarks and engaging in monitoring.

As I said, I’m sympathetic to all of these objectives, and therefore sympathetic to the overall idea. But I do think that a few skeptical observations are in order, if only to press proponents of the AIC idea to further develop this idea.

First off, although the report mentions in passing that “there are already a number of collaborations in existence, including … regional anti-corruption authority networks … and various regional initiatives [such as] the Asian Development Bank/OECD Anti-Corruption Initiative for Asia and the Pacific and [the Southeast Asian Partners Against Corruption (SEA-PAC)],” I think the report tends to understate just how many different forums, groupings, bodies, etc. have already emerged in ASEAN or the Asia-Pacific region more broadly that are intended to promote discussion and collaboration on anticorruption issues. In addition to the ABD/OECD Initiative (which primarily provides policy analysis, a discussion forum, and high-level strategic advice), and SEA-PAC (a grouping of ASEAN anticorruption agencies that holds annual meetings to discuss issues of common concern), we also have: the Asia Pacific Economic Cooperation (APEC) Anti-Corruption and Transparency Experts’ Working Group (APEC-ACTWG), and its associated APEC Network of Anti-Corruption Authorities and Law Enforcement Agencies (ACT-NET), as well as the nascent Asset Recovery Inter-Agency Network of the Asia Pacific (ARIN-AP), the ASEAN Corporate Social Responsibility (CSR) Network, and countless regional conferences, discussion forums, high-level meetings, etc.

The TI report on the AIC claims (perhaps correctly, though maybe a tad unfairly) that “the visible impact of these collaborations has so far been limited.” The proposed AIC, TI says, will enable ASEAN leaders to “shift from a sporadic opportunistic approach to collaboration to a more strategic one based on ongoing analysis of regional priorities,” and more generally the AIC “will provide a framework to integrate these … existing initiatives to create a coherent regional anti-corruption strategy.” Perhaps. But I confess that I’m somewhat skeptical that the creation of yet another regional forum will prove that much more successful than the existing forums (particularly those that specifically aim for high-level strategy discussions, like the ABD/OECD Initiative, SEA-PAC, and the APEC-ACTWG). And as for more hands-on, focused, technical law enforcement collaboration, again it’s not clear what the big advantage of an AIC would be over, say, the ACT-NET or other, less formal forms of bilateral and multilateral law enforcement cooperation. I can’t help but recall a comment I heard from several of the experts I interviewed for the background paper on corruption in ASEAN: variations on (and I’m paraphrasing here, but trying to capture accurately the exasperated tone): “For God’s sake, we don’t need yet another forum in ASEAN where fancy government officials give high-minded speeches about how corruption is bad, and then everyone blathers for a few days, and then everyone goes home. We have plenty of those already.” I do think the proponents of the AIC have the burden of showing that their proposal isn’t just another “talk shop,” or further developing the proposal in a way that avoids that particular pitfall.

One of the other big goals of the AIC is to give civil society (and the business community) more of a voice in developing and shaping anticorruption strategy and priorities in the region. TI is obviously somewhat self-interested in calling for governments to create a forum that will give civil society groups more input into anticorruption policy, but I’m nonetheless quite sympathetic. That said, I’m not convinced that the failure of civil society groups (including TI) to have more influence on policymakers in the region really has that much to do with a lack of a forum that will enable them to provide input. Indeed, every year there are probably at least a dozen conferences, meetings, and other events in the ASEAN region where civil society and business representatives meet and talk with senior government officials and others about anticorruption policy and strategy. I’ve had the opportunity to attend several of those meetings myself. The problem, in my view, is not that civil society groups and the private sector have no opportunity to present their views and participate in the broader conversation about anticorruption strategy. The problem is more often that in many of these countries, the powers-that-be simply do not care about (or strongly disagree with) the positions that civil society groups like TI are advocating. That’s not to say that it wouldn’t make any difference if we gave, say, the presidents of the various TI chapters in Southeast Asia more direct access to senior government ministers, say through a regular meeting of something like the AIC. But I don’t think it would make all that much difference.

Finally, a quick word about the proposal that the AIC could help supplement the existing UN Convention Against Corruption implementation reports by “building on these existing reports and providing benchmarking and comparison across the region.” TI states that an AIC could play a role in conducting such independent monitoring, and that the AIC would “collaboratively defin[e] specific annual indicators and assess[] their implementation.” This strikes me as an intriguing idea, but as-yet too underdeveloped to assess. What, exactly, does TI envision that the AIC would do with respect to benchmarking, monitoring, and assessment? Would the AIC (that is, the community of ASEAN states) provide additional reviews on UNCAC compliance, above and beyond the UNCAC review mechanism itself? Would there be some supplement to UNCAC? New indicators? What would those indicators be? And is it realistic to expect that the ASEAN countries, many of which are extremely sensitive to any external criticism or interference with “sovereignty”, would go along with a more intrusive regional monitoring regime? So while I do think this is an idea worth exploring, I do think that TI and other AIC proponents need to flesh out this idea more fully.

In sum, I guess my position right now is that the proposed AIC is an intriguing idea, but still a bit half-baked. Again, this is not necessarily a criticism of TI or its April report – the goal at this stage is clearly to get people talking, particularly at next week’s meeting in Malaysia and into the coming year, and that’s a goal I definitely support. But I do think the TI report makes some quite strong claims on behalf of the AIC – for example, that an AIC is “essential” to promoting the vision of shared prosperity throughout ASEAN, and that without the creation of an AIC “the achievements of the post-2015 ASEAN Vision will not be sustainable” – which strike me as hyperbolic and as-yet unsubstantiated. I very much look forward to continuing the conversation, though, and I appreciate TI for getting this ball rolling.