INTERNATIONALLY SUPERVISED ELECTORAL AUDITS. A Comparative Study of Haiti and Afghanistan

Transcription

1 INTERNATIONALLY SUPERVISED ELECTORAL AUDITS A Comparative Study of Haiti and Afghanistan Creative Associates International May 2015

2 Internationally Supervised Electoral Audits: A Comparative Study of Haiti and Afghanistan By Jeff Fischer Senior Electoral Advisor, Electoral Education and Integrity Practice Area, Creative Associates International Introduction In response to claims of widespread voting rigging, the international community has undertaken the supervision of two electoral audits over the past five years Haiti (2010) and Afghanistan (2014). In both cases, losing presidential candidates claimed widespread fraud and demanded investigations by impartial entities. In both cases, the political environment was fragile and, if not resolved, the disputed election results could harden existing political cleavages. As a result, an internationally supervised audit was viewed as the mechanism to resolve these differences. In Haiti, the Organization of America States (OAS) negotiated an agreement to conduct a verification of the first round presidential election results. In Afghanistan, the presidential candidates signed an agreement for the United Nations (UN) to audit the second round of the presidential election results. While both investigations were conducted under an international agreement framework, the two approaches ranged widely in their scale and the methodologies employed. This paper provides a narrative of the conduct of these investigations and a comparative discussion on their features. The perspectives found in this narrative reflect those of the author who was both named as a member of the 2011 Haiti Verification Expert Mission and a senior advisor to the UN and the Independent Election Commission of Afghanistan on the 2014 audit. This narrative is a personal account of both experiences and does not represent the views of any institution or organization. Haiti First Round, Presidential Election 2010 Background In response to the electoral violence triggered by the announcement of the November 28, 2010 first round presidential election results, President Rene Préval requested the 1

3 Organization of American States (OAS) to dispatch two expert missions to Haiti one mission to verify the results of the first round of presidential elections and the other to monitor electoral dispute resolution or the contestation process by parties and candidates. The agreement was signed by the Government of Haiti, the OAS and the Conseil Electoral Permanent. This action was taken after an agreement for a so-called Mixed Committee of Haitians and international representatives failed to perform the same tasks. The OAS Expert Verification of the Tabulation Mission was composed of nine members and began work on December 30, The terms of reference for the Expert Mission are shown below. Evaluate, in accordance with the Charter of the OAS, the Inter-American Democratic Charter and the standards developed and applied thereto by the GS/OAS for OAS electoral observation missions, the Constitution of the Republic of Haiti and the electoral law of July 9, 2008, the practices and procedures implemented during the November 28, 2010 Presidential elections relating to the vote tabulation and any other factors affecting and relating to the preliminary results published by the Conseil Electoral Permanente. 1 The Expert Mission conducted their activities at the Conseil Electoral Permanente s Center de Tabulation de Vote. Election observers and political party agents were not present. The principal audit trail taken was through an examination of Procès-Verbaux (PVs) or polling station vote tally sheets. These tally sheets were completed by poll workers and provided the official results of voting at those locations. The audit process The inspection of these tally sheets yielded two issues. First, 1,045 tally sheets, 9.3 percent of the total from the 11,181 polling stations, never arrived at the Center de Tabulation de Vote and were never identified as missing by the Conseil Electoral Permanent. Second, overall, voter turnout was 22.8 percent, but on 216 tally sheets the voter turnout was 75 percent and above. On 118 tally sheets it was 100 percent or more. A third issue that emerged was the inconsistency in criteria employed by the Center de Tabulation de Vote to include or exclude tally sheets from the tabulation. As a result, only 312 tally sheets were excluded by the Conseil Electoral Permanent is its tabulation of first round results. The Expert Mission established three criteria for tally sheets to be included in the tabulation. 1. The tally sheet should have the signatures of the polling officials. 2. The voter registry for that polling station should be included in the polling station package or sachet. 3. Identity numbers for voters should be recorded for all those who cast ballots at that poll. 1 Agreement on OAS Expert Mission, section 3.a, December 29,

4 Within these criteria, the Expert Mission examined unusual patterns of identity numbers or false identity numbers. Each of these provisions is found in the Haitian election law. However, the Expert Mission also established the criteria that the tally sheet should be excluded if obviously altered. There were three strategic underpinnings for the OAS approach to this task. While the terms of reference for the Expert Mission were established in a political agreement, the verification had to be conducted in accordance with Haitian election law. Next, the OAS had to maintain a transparent chain of custody of the documents it handled so as not to compromise them and open up opportunities for further claims of fraud. Third, while the tally sheets were a principal audit trail, the Expert Mission was also informed through multiple sources of information. These sources of information included the following: National survey sample of sachets; Tally sheets with unusual patterns of candidate totals or voter turnout; Excluded tally sheets ( mis à l'écart ) ; Sample voted ballots from each Bureau Electoral Departmental compared with official results at the Center de Tabulation de Vote; Election Day Call Log from the Conseil Electoral Permanent Emergency Call Center; International and domestic election observation reports; The United Nations Stabilization Mission in Haiti s Election Day incidents log; and User access logs for the Center de Tabulation de Vote tabulation system. Interviews were held with presidential candidates with the exception of candidate Mirlande Manigat who was not available to meet. Interviews were also conducted with representatives of civil society organizations including: Initiative de la Société Civile, Réseau National de Defense des Droits de l Homme and the Conseil National d Observation des Elections. The verification process The verification process commenced with a national statistical sampling examining candidates votes (receiving more than 150), voter turnout (more than 50 percent) and geography (polling station location). This survey also helped team members form a consensus about what constituted an irregularity. The Expert Mission defined an irregularity as the purposeful or erroneous violation of official electoral procedures resulting in the disputed validity of voted ballots, electoral documents, or voter eligibility and, as a consequence, electoral results. A verification checklist was also developed based upon this survey. 3

5 In the survey findings, the most prevalent irregularities were missing identity numbers on voter registries and missing documentation in general. Employing thresholds to evaluate candidate vote totals and voter turnout emerged as the most effective indicators of fraud. Operationally, each sachet was examined by a bi-national team of two experts, with a French language speaker assigned to each team. Each team member signed a document verifying that they had examined these sachets in order to assure chain of custody. Team members were rotated so that the judgments about irregularities could be routinized. Tally sheets were classified by problem indicators. Based upon the criteria developed through the survey, the Expert Mission examined every tally sheet with more than a 50 percent voter turnout and those where a single candidate obtained 150 votes or more. As a result, the Expert Mission verified 442 tally sheets from a national sample representing 71,423 votes and excluded 454 tally sheets, representing 118,478 votes. Twenty-three ballot bags were retrieved from all 11 Electoral Departments, representing 2,162 votes. In total, the Expert Mission reviewed 919 tally sheets, or 8.2 percent of the total tally sheets processed by the Center de Tabulation de Vote representing 192,063 votes or 16.9 percent of the total ballots tabulated. Findings and outcomes The Expert Mission analysis yielded the following findings. As the voter turnout rate and candidate total votes increased, so did the likelihood of irregularities. The irregularities had an impact on the vote tallies of two candidates in particular, Jude Celestin and Michel Martelly. Given the nature of the irregularities, most of them occurred at polling stations and, thus, were committed by poll workers. The initial reviews of tally sheets for inclusion or exclusion by the Center de Tabulation de Vote was performed in an inconsistent manner and contributed to the uncertainties over the first round outcomes. Recommendations With these findings in mind, there were four remedial actions that the Expert Commission considered: 1. Conduct a new, first round election; 2. Conduct a new election in certain locations where the irregularities were the highest: 3. Conduct a national recount of every ballot: 4. Or review tally sheets in areas with high irregularities in terms of voter turnout and candidate vote totals and exclude these ballots from the tabulation. The fourth option was selected because of the political and logistical difficulties associated with options one and two and the fact that Haitian election law does not allow for recounts as proposed in option three. 4

6 The Expert Mission recommended to the Conseil Electoral Permanent that the votes from 234 tally sheets that failed to meet the verification criteria be excluded from the total ballot tabulation. In doing so, candidate Michel Martelly moved from third place to second and candidate Jude Celestin moved from second place to third, eliminating Celestin from the second round of voting. The table below displays the impact on vote totals. Candidate First Round Total Disallowed Vote Amended First Round Totals Amended First Round Percentage Michel Joseph 234,617 7, , % Martelly Jude Celestin 241,462 17, , % Mirlande Manigat 336,878 13, , % The Conseil Electoral Permanent agreed to invalidate those tally sheets, and the amended results were certified. As a result, the outcomes from the first round of elections were changed. Afghanistan Second Round, Presidential Elections 2014 The audit framework From July 17 to September 5, an electoral audit of the second round of voting for the 2014 presidential election in Afghanistan was conducted by the Independent Election Commission under the supervision of the United Nations. The Technical Framework for the audit was put forward in a July 12, 2014 document agreed upon by the presidential candidates Ashraf Ghani, Ph.D., and Abdullah Abdullah, Ph.D. Four key features framed the outside parameters of the audit: 1. The audit will be a full audit examining 100 percent of the ballots; 2. The audit will be centralized at the Independent Election Commission compound in Kabul; 3. The audit will be internationally supervised in a manner proposed by the UN, in consultation with both candidates; and 4. Candidate agents will be permitted to observe the entire audit process. 2 The Framework also required the Independent Election Commission to provide a full explanation of the discrepancy between turn-out numbers announced on Election Day and (subsequently) those announced as part of the preliminary results on July 7 th. 3 2 Afghan Presidential Election Technical Framework, Point 7, July 12, Ibid. 5

7 However, while the political agreement mandated these provisions, the audit still required administration in accordance with Afghan law and recognition of Afghan sovereignty, as a member state of the UN. Authorization to conduct the audit required approval by the Independent Election Commission, which the commission granted on July 17, 2014 as Decision 27 of the Independent Election Commission. The process and obstacles Audit operations commenced July 17, the same day Decision 27 was passed. There were 30 two-person teams. Twenty-three of the auditors were women, most on sex-segregated teams; however, two teams were mixed with male and female auditors. International observers, political party agents, civil society organizations and Independent Electoral Complaints Commission representatives observed each table. There were several structural obstacles to ensuring a timely process, which extended the length of time it took to complete audit operations. Three main obstacles emerged. 1. Requirement that all stakeholders be present All audit stakeholders had to be in place for the audit to commence. Representatives from the Independent Election Commission, candidates political campaigns, the Independent Electoral Complaints Commission, the UN and the international community had to be present. If one representative was late, the process was delayed. 2. Limited availability of UN advisors to mediate UN advisors were deployed in a ratio of one advisor per two or three audit tables. If an advisor was called upon to mediate at a particular table, audit operations at the other tables were often halted. 3. Deliberate efforts to slow the process Such stoppage protocols also empowered the candidates agents to stage walkouts or fail to show up in an effort to slow the process to achieve some short-term political objective. United Nations role This dual mandate of political agreement and national law required a balanced approach by the UN in managing its relationships with national audit stakeholders and in defining the thresholds for action in its supervisory role. The UN positioned itself to exercise its supervisory mandate in a collegial manner with respect to its partnerships with the Independent Election Commission and the Independent Electoral Complaints Commission. Other international electoral supervisory mandates, such as Cambodia, Bosnia and Herzegovina, Kosovo, and East Timor, were not particularly instructive for the positioning of the UN as audit supervisor. This is because in the cases cited above, the international community was also the election authority, so electoral supervision was less nuanced and required less balance of electoral sovereignty with national authorities as was the case in Afghanistan. 6

8 In the case of Afghanistan, the audit required a working relationship between the UN and the statutory Afghanistan election authority, the Independent Election Commission. Even within the UN system, roles and relationships had to be established because of the multiple agencies involved. Basically, the division of labor was as follows. The United Nations Assistance Mission in Afghanistan conducted the political discussions with the candidates. The United Nations Development Programme oversaw audit operations. The Electoral Assistance Division at the UN Secretariat led the July effort to consult with the Independent Election Commission, Independent Election Complaints Commission and the presidential campaigns to develop the procedural framework. Other UN agencies contributed advisors to the audit including the UN s New York headquarters, United Nations Development Programme missions in Belgium, Colombia, Haiti, Jordan, Madagascar, Mexico, Romania, Solomon Islands, Thailand and Yemen; peace and political operations in Iraq, Lebanon and Libya, and Afghan-based international staff with the United Nations Development Programme, United Nations Assistance Mission in Afghanistan and the United Nations Educational, Scientific, and Cultural Organization. The deployment of UN advisors required global coordination involving hundreds of individuals in a compressed period of time. Implementing the framework In implementing the terms of the Framework on a practical level, the UN developed a checklist of 16 issues to evaluate and determine whether individual ballots or the entire polling stations should be validated, invalidated or subject to recount. The UN took a leading role in fostering the establishment of the 16-item checklist process. It invited the two candidates to submit the locations of 3,000 polling stations where they believed fraud had occurred for special scrutiny auditing. Strategically, this procedure was intended to red flag the most contentious cases so that these cases could be managed appropriately. Special scrutiny auditing commenced on August 16. Checklist item 16 is noteworthy. Under this provision, polling stations can be singled out for special scrutiny auditing. According to special scrutiny procedure, the contents of each ballot box are subject to a complete recount. Special scrutiny boxes were audited in secured areas of each warehouse with special teams of auditors, UN advisors, agents and observers assigned to the process. While it was originally thought that going directly to a recount would reduce the processing time for each polling station, the opposite occurred. Due to the sensitivities and contentiousness surrounding these polling stations, candidate agents from both camps were reluctant to acquiesce and close out a ballot box. Similarly marked ballots By far, the most prevalent and contentious issue surrounding the validation versus invalidation debate was that of similarly marked ballots. At the outset of the audit, the 7

9 procedural framework did not spell out criteria for UN advisors to make consistent determinations of similarly marked ballots and patterns of similarly marked ballots. Given the subjective nature of such decision-making and the interpretations being issued by UN advisors, the UN decided to establish a policy for the purposes of the audit about what constitutes a similarly marked ballot and how many similarly marked ballots constitute a pattern. The policy identified five criteria to be examined before making a decision on similarly marked ballots. These criteria included: 1. Shape of the mark; 2. Size of the mark; 3. Location of the mark; 4. Handwriting style; and 5. Color of ink. The UN introduced a threshold of 10 similarly marked ballots to constitute a pattern. The numerical threshold of 10 was agreed in consultation with the two campaign teams, along with the procedural clarification that a pattern of 20 or more similarly marked ballots, or two patterns of 10 or more similarly marked ballots each, would trigger a recount. The audit procedure also permitted that 15 percent of all similarly marked ballots per polling station would be included in the vote count in order to ensure a level of tolerance for those similarly marked ballots that would have been legally made by the polling station chairmen assisting illiterate or physically impaired voters. An overview of UN policy on similarly marked ballots was forwarded for peer review to Judge Johann Kriegler, Jørgen Elklit, Ph.D. and Horacio Boneo, Ph.D., all noted senior advisors on elections. Their pro bono review of the policy noted that there was little in the way of international guidance on what constitutes similarly marked ballots or precedents in this regard. They found no problems with the policy approach described in the paper. UN role in adjudication Outside of the special scrutiny category, ballot box intake procedures from warehouse to audit table were designed to process polling stations in a geographically and politically balanced manner. This procedure was introduced so that the appearance of the findings did not create a false impression of the status of the contest at arbitrary points in time. The UN exercised its role in the audit adjudication process on three levels. 1. UN advisors were present in the data entry centers to assure integrity in the software development, reporting, document intake and data entry activities; 2. UN advisors scrutinized the audit checklists to assure compliance with the criteria for validation, recount and invalidation. If non-compliance was identified, corrections were made; and 3. The UN provided guidance and recommendations to the Independent Election Commission in formulating its decisions about accepting or rejecting the findings 8

10 of the checklists. UN Advisors reviewed the checklist for all invalidations and recounts. Validation checklists were also reviewed in order to assure that the validation decision reflect the findings of the checklists. Their personal inspection of these checklists also permitted them to identify any notes on the checklist for other follow-up actions. In establishing daily dockets for the UN to recommend and the Independent Election Commission to decide upon, the findings of the checklist were grouped into 12 reports eight categories for invalidation, three categories for recount and one category finding no irregularities. There were 3,000 or more polling stations and checklists grouped into these reports for each daily docket. These adjudication sessions were open to the media, candidate agents and international observers. The polling stations that would be adjudicated were announced on the Independent Election Commission website 24 hours in advance of decision-making sessions. The decision-making was conducted in the presence of candidates agents, observers, UN advisors and media. The decisions, and the reasons behind them, were posted on the Independent Election Commission website daily. For most of the month of August, daily meetings were scheduled with representatives of the UN and Independent Election Commission, candidates agents and international observers to discuss issues that arose in the audit that day. Such meetings were opportunities for the candidates representatives to voice concerns about trends they observed in the audit and request procedural clarifications. These meetings also provided opportunities for the UN to brief the candidates representatives about activities including data entry of checklists, adjudication processes and checklist provisions. Incidents of electoral violence The audit experienced electoral violence in three manifestations: 1. Candidate agent altercations Candidates agents at the audit tables frequently engaged in heated verbal exchanges and physical altercations such as pushing and fist fights. 2. Violence in the streets On two occasions, violence spilled over onto the service road in front of the warehouses, involving dozens of individuals. On the first occasion, the fighting was between the candidates agents. In the second instance, the fighting was between Abdullah s agents and Independent Election Commission staff. In both cases, riot police were deployed to quell the disturbances. After the second incident, riot police were stationed on the audit premises for the balance of the process. 3. Verbal abuse and intimidation of UN advisors 9

11 Verbal abuse and intimidation tactics by candidates agents against UN advisors also occurred. Their photographs were taken, posted on Facebook sites and labeled with derogatory statements about their purported bias or unfairness. The audit was the target of intense interest from the Afghan media, in particular, the electronic media. Nearly every day, dozens of journalists and photographers were reporting from the warehouses on the progress of the audit. To obtain media coverage for themselves, some of the candidates agents also appeared to create conflict when television cameras were present. However, it is noteworthy there were no perimeter attacks or indirect fire incidents on the Independent Election Commission compound. International Security Assistance Force troops, Afghan National Army and Afghan National Police, private security contractors and Gurkha guards combined to provide perimeter and venue protection at the Independent Election Commission compound, outside and inside the warehouses. International Security Assistance Forces and the Afghan National Army also provided the logistical planning, assets and personnel to retrieve the ballot boxes and deliver them to Kabul. The international observer delegations were accompanied by private close protection contractors. However, except for official security forces, there was a no weapons policy inside the warehouses. Off-hours video surveillance was organized and managed by the International Security Assistance Forces at the four warehouses and the data entry center. Procedural debate The procedural framework itself was a source of continued debate. A number of discussions were held with both presidential campaigns about amendments to the framework. However, the UN s position was that the procedural framework was developed and agreed upon, and changing it during the course of the audit would effectively change the rules of the audit as it was being conducted. Nevertheless, if the practice of the audit revealed issues where the procedural framework could be refined, then the UN would explore such clarifications. Additional issues were raised during the procedural debate, including: Definition of a numerical measure to define a pattern of similarly marked ballots The UN decided that 10 similarly marked ballots constituted a pattern. If 20 similarly marked ballots in more or two patterns were detected, then auditors triggered a polling station recount. The creasing/folding of ballots A further request was made to invalidate ballots which did not show a crease mark. The contention was that ballots had to be creased/folded to fit in the ballot box opening. However, while this connection may have had validity in past 10

12 presidential elections, the 2014 ballot did not require folding to be inserted in the ballot box. Security of election document storage facilities The presidential campaigns requested that the International Security Assistance Force make available surveillance footage of data entry centers, and especially footage of the secure storage locations for election documents that constituted audit evidence. The International Security Assistance Force agreed to provide this video. Similarly signed polling station results forms A request was made to the UN to review 1,700 cases of polling station results forms, based on the contention that they were similarly signed. However, the UN and Independent Election Commission conducted an investigation of these claims and found similarly signed results sheets considered fraudulent in small number of cases. The findings from the audit were first released to the presidential candidates and then the public. While the audit recommended the invalidation of ballots, it did not change the outcome of the second round voting. Comparative Analysis The comparative analysis of these two processes is structured according to the following topics: 1) legal and regulatory framework; 2) methodology and operation; 3) stakeholder communication; 4) traditional and social media; and 5) leveraging audit findings. Legal and regulatory frameworks In both cases, the legal and regulatory framework involved a combination of national election law and the terms of a political agreement. In addition, since these audits were conducted by intergovernmental organizations of which both Afghanistan and Haiti are member states. The terms of the charters of the OAS or UN were also applicable. Election laws provide the statutory parameters that must be observed in an audit s scope, and political agreements mandates an organization to supervise the audit. However, in both cases, the scope of the international supervision remained ill-defined. In Afghanistan, the open ended manner in which it was addressed in the July 12 document led to different interpretations on the weight and reach of the supervisory role for the UN versus that of the Independent Election Commission and Independent Election Complaints Commission. Assessment These legal and political sources of authorities and parameters must be implemented through a regulatory framework, established by the audit authority. The audits in Afghanistan and Haiti were standalone events and, as such, were constructed for that sole purpose. Given the ad hoc dimension to such arrangements, regulatory frameworks have 11

13 not been tested and the audit itself may reveal irregularities unforeseen in the original agreement. A degree of flexibility that does not move the goal lines should exist to refine the regulatory framework as new irregularities are revealed. There should also be established criteria about the triggers for initiating such an audit. Otherwise, political demands for audits can become easy tools for spoilers not wishing to respect election results. These audits were scoped to focus on Election Day irregularities and irregularities associated with the subsequent chain of custody for sensitive electoral materials. The audits did not examine any reports of acts of coercion, such as vote buying or intimidation, which may have impacted voter s candidate selections; nor did it track instances of denials of services, that is, refusals to permit voting or arbitrary polling station closures. Fraudulent voter registration was also not considered. Methodologies and operations In both cases, audit checklists were developed for a consistent review of the election documents for irregularities. In both cases, all of the documents associated with voting in a particular polling station were subject to review. However, there is a divergence when it comes to the use of ballots as audit trails. In Afghanistan, the audit was 100 percent and each ballot was subject to scrutiny. In Haiti, the audit took a statistical sampling and inspection approach. Relatively few individual ballot inspections were performed by comparison. This difference in approach between these two audits drove the scale of each operation. The Afghanistan case involved hundreds of UN staff, hundreds of domestic observers and party agents, the Afghan National Police, and International Security Assistance Force troops and assets. In Haiti, the Expert Mission and support staff numbered no more than twenty, with the UN providing helicopter transport of the ballot box samples from each departmental election office. Stakeholder communications International and domestic observers as well as political party agents were present in Afghanistan, but there was no such observer presence in Haiti. While the Expert Mission in Haiti organized individual briefings with several civil society organizations, they were not part of an organized outreach effort. In Afghanistan, the Audit Committee became an effective mechanism to broker issues between the campaigns, discuss concerns, identify procedural clarifications, and inform the presidential campaigns on next steps or new phases of the audit. In this way, the Audit Committee also served to de-conflict the audit by providing a structured platform for the candidates representatives to debate procedural issues. The presence of international observers served to inform international stakeholders about the issues of the day. 12

14 Traditional and social media While election audits should be open to the media, the unbridled, all access approach taken in Afghanistan added to the congestion and tension within the audit facilities. Access policies should be adopted to reduce the disruptive effect of media presence on audit operations. There was no such media intensity in Haiti. In Afghanistan, social media coverage of the audit was employed both as a documentation and intimidation mechanism. Candidates agents regularly took photographs of ballots and voter lists on mobile devices to document the infractions they claimed were not being invalidated. Such an allowance provided an enhanced transparency to the audit process. However, these same devices were employed to photograph UN advisors for the purposes of intimidation. Haiti saw little in the form of social media interaction with the verification mission. Leveraging audit findings In Afghanistan, the audit revealed an array of malpractice tactics that were perpetrated in the presidential election. This process has publically revealed these tactics. In principle, this means that Afghan stakeholders, seeking accountability in the electoral process, have awareness of such tactics that can be monitored in the next electoral cycle. However, it must also be noted that public revelations about these tactics may drive the perpetrators to change their tactics and use them earlier in the electoral process. For example, lacking the agility to mark multiple ballots, the perpetrators could attempt to influence the voters selections through vote buying or intimidation. Under Afghanistan s Unity government, a Special Electoral Reform Commission has been established. The findings of this audit can be leveraged to define the specific targets for reform. However, at this writing, the Special Electoral Reform Commission has not yet become operational. Conversely, in Haiti, political stalemate and election delays have dominated the electoral landscape for President Martelly s term of office. While elections have been ostensibly scheduled for later this year, politics remains fractured and no such consensus for reform can yet be leveraged. Given these two precedents, the international community could be requested again to supervise an audit for a disputed election. The dilemma posed here is that while the international community can play a role in resolving electoral disputes, the threshold for such engagement should be relatively high so that every cry of foul is met with a an internationally supervised audit. However, if such an action is justified, these two cases can frame comparative approaches on the policy options concerning audit planning, scope, procedures and administration. 13