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reliability and probity of government accounts, usually for the legislature to consider. Germany, Netherlands, Sweden, and, in Latin America, Argentina and Nicaragua follow this model.

All three models share a central common feature: their independence from the executive (except in Bolivia). They are also linked, to varying degrees, to the legislature. The court model has closer ties to the judiciary, as in the case of the Brazilian TCU, the board model to the legislature, as in the case of the Argentine AGN, and the monocratic model to the bureaucracy, as in the case of the Chilean CGR. Figure 2 illustrates the typology of AAAs and situates the cases of Argentina, Brazil and Chile within it.


International auditing standards underscore that for the external audit process to function effectively and impartially, AAAs must be independent from the executive. Nevertheless, to have a meaningful impact on bureaucratic behavior, they must also develop close working relationships with the bureaucracy they audit. Furthermore, as oversight agencies with limited sanctioning powers, they must also develop effective linkages with those institutions with the powers to bring government to account, namely the legislature and the judiciary.

In practice, AAAs are unique hybrids and do not fit easily in the traditional model of separation of powers. Each AAA combines elements of three different ideal types described above. Key variations between agencies include the timing of control (whether ex-ante or ex-post control), its nature (whether emphasizing compliance or performance auditing), its effects (the intensity of follow-up of audit recommendations), as well as its status (the legal standing of audit rulings). Comparative analysis of legal frameworks and institutional arrangements in Tables 3 and 4, respectively, reveals the great variety of functions these perform, as well as the difference in institutional arrangements.

Typology of audit techniques

AAAs’ approaches to fiscal control also vary across countries and have evolved over time. The nature of external auditing of government finances is shaped by four main factors: (i) the type, (ii) timing, (iii) scope and (iii) enforceability of audits.

Types of audits Fiscal control can be preventive, corrective or punitive (Barra 2002). AAAs’ main function is to guarantee the accuracy and reliability of government financial reporting through financial audits and ensure compliance with legal and financial regulations through compliance audits. Compliance control is concerned with the formal adherence with the legal rules and financial regulations framing the budgetary process. These functions include checking government’s compliance with the mandate given by the legislature through the budget law. In recent years, AAAs have broadened their audit methods to assess the efficiency, effectiveness and economy of public spending through performance audits. Performance control is concerned with the substantive compliance with the objectives of the budget law and the manner in which public resources have been deployed.

The general trend is towards a greater emphasis on preventive and corrective functions through increased reliance on ex-post performance auditing. Undoubtedly, increased emphasis on performance and results is necessary to overcome the inefficiencies of procedure-driven bureaucracies, especially in civil law countries. However, it should not replace the need to uphold standards of integrity and probity necessary to combat corruption, especially in countries where the rule of law is weak. These two forms of accountability should complement, rather than substitute one other. Nevertheless, performance auditing is hindered by the legalistic culture of


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