Nicaragua has a well-developed legislative framework criminalizing acts of corruption, but the rampant corruption in Nicaragua begins at the top and pervades every element of government, including the national police, judiciary, customs authorities, and tax authorities.  There is no expectation that the framework be enforced other than token cases to pretend compliance.  A general state of permissiveness, lack of strong institutions, ineffective system of checks and balances, and the FSLN’s complete control of government institutions create conditions for corruption to thrive.  The judicial system remained particularly susceptible to bribes, manipulation, and political influence.  Companies reported that bribery of public officials, unlawful seizures, and arbitrary assessments by customs and tax authorities were common.

The government does not require private companies to establish internal controls.  However, Nicaraguan banks have robust compliance and monitoring programs that detect corruption and also attempt to pierce the façade of front men seeking to process transactions for OFAC-sanctioned and other actors.  Multiple government officials and government-controlled entities have been sanctioned for corruption.

Nicaragua ratified the United Nations Convention against Corruption (UNCAC) in 2006 and the Inter-American Convention Against Corruption in 1999.  It is not party to the OECD Convention on Combatting Bribery of Foreign Public Officials in International Business Transactions.

Businesses reported that corruption is an obstacle to FDI, particularly in government procurement, licensing, and customs and taxation.

Resources to Report Corruption

Nicaragua’s supreme audit institution is the Contraloria General de la República de Nicaragua (CGR).  The CGR can be reached at +505 2265-2072 and more information is available at its website www.cgr.gob.ni .