South Africa has witnessed a phenomenon of state capture where business people and those who are closer to powerful politicians form a corrupt relationship that benefit them and their families. This phenomenon sought to repurpose the state institutions to pursue corrupt intent, which are diametrically opposed to its original mission of serving and advancing the interests of the country and its inhabitants. Indubitably, this phenomenon challenged the integrity of the country as a whole and its institutions.

SARS is one of the state institutions said to have been “captured” in this fashion. A special commission established to investigate internal governance at the agency found massive failures of governance. “SARS was systemically and deliberately weakened, chiefly through the restructuring of its institutional capacity, strategic appointments and dismissals of key individuals, and a pervasive culture of fear and bullying

SARS experienced regression during this period because those that were in charge had repurposed the organisation to achieve the corrupt intent of those in power and their connected allies.

In 2019, the rebuilding of SARS commenced in earnest, with SARS’ Strategic Plan setting the ambition to build “a smart modern SARS, with unquestionable integrity, trusted and admired”. While steadfast in its zero-tolerance stance to corruption, SARS also realised the need to adopt a holistic and comprehensive approach to build integrity, in line with the WCO Revised Arusha Declaration on Customs Integrity and Good Governance and the WTO Trade Facilitation Agreement (TFA).

Besides developing integrity and anti-corruption policies that are pragmatic, realistic, rapidly effective, and capable of being evaluated, a concrete link between integrity promotion policies and reforms was established. The fight against corruption was anchored in the policy of reform.

Now, in 2025, SARS Customs and Excise (C&E) stands as a testament to integrity-driven systemic reforms and transformation. This journey was supported under the partnership that SARS forged with the WCO Accelerate Trade Facilitation Programme, funded by the United Kingdom’s His Majesty’s Revenue & Customs (HMRC). SARS has strengthened its capacity to implement transparent and inclusive Customs operations and has demonstrated measurable progress in managing integrity-driven Customs and trade facilitation reforms aligned with international standards and fostering more predictability and accountability for cross-border trade.

The different steps of this journey are described below, as well as the results obtained.

The multi-year strategic partnership between the WCO and SARS started with an Integrity Diagnostic Assessment which was conducted during the COVID-19 pandemic. Led by SARS Commissioner and Director of Customs Operations, and with participation of the WCO Deputy Secretary General, a high-level launch of the assessment took place in May 2021 to inform stakeholders of the initiative and secure accountability for the success of the initiative.

Despite restrictions due to COVID-19, a multidisciplinary national Integrity Working Group, engaging both internal stakeholders and the private sector, was established to discuss the assessment results.

A Customs Integrity Perception Survey (CIPS) was also conducted in 2021 to understand how SARS Customs and Excise Department (SARS C&E) efforts to promote integrity and combating corruption were perceived by its own staff and by individuals who engage with it.

Values inform and guide the culture of the organisation, infusing policy as much as individual performance-management. For this reason, SARS reviewed its values to align the employees and stakeholders with the organisational vision.

To rebuild itself, the organisation needed to ensure senior SARS C&E executives had the capacity to lead and drive the SARS reforms and modernisation agenda. WCO Leadership and Management Development (LMD) workshops were therefore organized, enabling participants to explore modern management approaches and assess personal leadership skills, attitudes, and behaviour through interactive exercises and individual reflections. The SARS Commissioner shared the SARS’ experience on strengthening leadership and management skills within the organization in an article published in June 2023 in WCO News.

With the executives and senior management capacitated and aligned to the SARS values, it was time to attend to the workforce. Within C&E specifically, challenges were formidable, due to a stubbornly high attrition rate driven primarily by an aging workforce and corruption.

The diminishing workforce and corrosion of the already scarce skills required the adoption of a holistic approach to HRM and the transition to a competency-based human resource approach which ties recruitment, selection, performance management, training, development, career management, remuneration and benefits together in support of the efficient execution of the Customs and Excise mandate.

A People Capability and Career Management (PCCM) Framework was developed leveraging WCO extensive set of tools and guidance for implementing a competency-based approach to HRM in the Customs environment.

The curriculum of the Customs Cadet Programme was reviewed to ensure that new recruits not only understood the role that Customs plays but were also instilled with SARS’ culture of service delivery, behavioural values, work ethic and results-orientated approach.

Due to the pressing operational need for a rapid deployment of new officers, SARS decided to institute a blended training approach that consisted of intense classroom training for cadets and practical working experience under the watchful eyes of experienced C&E officers. The training has already been delivered to five cohorts of Cadets, comprising young university graduates educated in accounting, audit, data analytics, law and risk.

Moreover, employees were requested to follow the SARS ethics e-learning course. A total of 1,078 have completed at least one module of the course, while 369 finished it entirely.

Based on the results of the WCO Diagnostic Assessment and the CIPS, a total of 38 recommendations were made, of which now 32 are completed. A dedicated Integrity Business Area Lead, empowered to lead the delivery of reform initiatives, was appointed within SARS Customs & Excise (C&E).

A formal Customs Integrity Strategy and Action Plan, enabling clear monitoring and follow-up, was also adopted Informed by the WCO recommendations. The strategy advocates for a balance between punitive and positive initiatives and is biased towards proactive and preventative approach as opposed to reactive anti-corruption measures. Additionally, it advocates for increased focus on external stakeholders who are often the corruptors. Some of the actions taken to implement the strategy are described below.

The Integrity helpline and mailbox (SpeakOut@sars.gov.za) were established in 2022, for employees to report ethical breaches, dilemmas, and any deviations from standard operating procedures. To date, a total of 55 cases were received and processed through this reporting channel. Various issues were reported including but not limited to unfair labour practices, non-compliance with private interest declaration procedures, misuse of sick leave, bullying, abuse of authority, and victimization.

SARS has also established a high-level case closure committee which ensures that due process is followed in the finalisation and closure of investigation cases. This committee reviews and considers recommendations to close cases based on the findings of the investigation to ensure they are well-founded. It also determines if the cases were thoroughly investigated. This review process helps to maintain the integrity of the investigation work and ensure that cases are handled fairly without bias.

The SARS Code of Ethical Conduct differed in several respects with the WCO Model Code of Conduct. For example, there was no provisions on private financial transactions between Customs employees or on the use of government property. The code has therefore been revised to address all missing aspects.

The Protected Disclosure Policy has also been amended to ensure confidentiality and prohibit occupational detriment for whistleblower reporters, offering legal recourse and protection from threats. Whistleblowers also receive an acknowledgement letter with a reference number and may be notified of the investigation progress.

To ensure that employees are aware of the C&E Integrity Strategy and expected behavioural standards (as per the Code of Conduct), awareness sessions were conducted. Over 400 customs officers and 60 Customs operational managers, managers and senior managers were in attendance.

A dynamic partnership between SARS and stakeholders is essential to enhance integrity, and the administration has established Integrated Stakeholder Engagement Plan to lay down the various actions to be taken in this domain.

Two forums ensure consistent engagement with the private sector:

the Customs and Excise National Strategic Stakeholder Forum (CENSSF) which meets twice a year and deals with collaborative focus areas, regulatory and strategic issues,

the Customs and Excise National Operations Stakeholder Forum (CENOSF) which meets on a quarterly basis and deals with any operational, policy, and process matters that impact more than one port of entry and thus cannot be addressed at regional or branch office level.

Additionally, a Private Sector Integrity Pledge was developed to ensure the commitment of stakeholders to integrity. This pledge represents a promise by the private sector to uphold high ethical standards and collaborate with customs in combating corruption. The CENOSF adopted this pledge and agreed to integrate it into the licensing and accreditation contracts signed by clients registered with SARS Customs and Excise. In cases of transgressions, the economic operator will face deregistration and de-accreditation. Among the topics discussed with external stakeholders are the results of two surveys: the Trade Facilitation Index (TFI) survey which seeks to gain feedback from private sector on how they experience the service delivered by Customs and the WCO CIPS. These surveys provide valuable information to guide discussions and strengthening private sector engagement in improving the service provided and combating corruption. A working group with the private sector has been established to identify issues to be addressed from these surveys.

Documentary compliance checks and inspections have historically represented the most sensitive and corruption-prone areas of Customs operations. Traditionally reliant on face-to-face interactions, these operations were especially vulnerable to corruption.

These processes are today digitalized and automated, reducing physical interactions with economic operators. Even refund claims are today dealt with via an automated system.

Moreover, documentary checks are now conducted on a remote risk-based targeting basis by officers working at Customs Compliance Centres, which has greatly helped to reduce corruption risks. The Centres are at strategic hubs such as the Durban Port, Cape Town Port, Doringkloof, and Alberton, and process all trade flows moving via sea, air, and land.

Other measures which also enabled to reduce direct interactions include the use of technology for truck arrival and exit management and the use of non-intrusive inspection technology (scanners) at major ports of entry.

Moreover, SARS has been working with other regulatory agencies to increase automation and coordination of controls and reduce manual intervention by field officers. Via the Single Window Portal, an inspection workflow solution has been implemented in collaboration with the Department of Agriculture, Land Reform and Rural Development (DALRRD). SARS and the Border Management Authority (BMA) have also recently agreed to use the Portal to coordinate their actions and digitalize border management procedures.

The digitalization of procedures has also enhanced the monitoring capacities of the administrations with Customs officers being made accountable for their acts, and answerable for them. It also provided economic operators with increased transparency in operations and easier access to information. The Single Window Portal which allows users to register, to request and manage documents through the SARS Registration, Licensing and Accreditation (RLA) system, to access trade and Customs policies, to monitor the status of Customs declarations, including all messages received from SARS and regulatory bodies.

Two iterations of the Customs Integrity Perception Survey (CIPS) conducted in 2021 and 2024[1] provided a robust basis for measuring progress and an incredibly helpful quantifiable reference on improved perception, especially on the private sector side. The CIPS provided quantifiable data to assess changes in both internal and external perceptions of integrity, and to guide reforms. The statistical target sample size for both internal and external stakeholders were exceeded, albeit challenges to reach the target set per day during the survey conduct due to, sensitivities and fear of lack of anonymity.

It is noteworthy that the leadership of Customs and Excise (C&E) played a pivotal role in ensuring the survey targets were met. C&E leadership actively engaged with the private sector daily, assessing participation levels and providing updates, which encouraged private sector representatives to partake in the survey. This proactive approach was instrumental in convincing private sector stakeholders to respond. The analysis of the survey points to Customs Officers responses in the 2024 CIPS iteration shows that the efforts taken by the administration are positively perceived. The average perceived integrity score rose from 6.75 in 2021 to 7.16 2024 on a scale of 0-10.

Key findings indicate that:

• 70% of Customs officials feel safe to report integrity violations as compared to 34% in 2021 (36% increase).
• a strong majority of Customs officers (87% in 2024 compared to 85% in 2021) still feel encouraged by their supervisors to report integrity violations.
• 79% of Customs officials believe that the current regulatory framework effectively minimizes the risk of corruption in Customs, reflecting a 6% increase in positive perception since 2021. This growing confidence reinforces SARS’ commitment to further advance its regulatory environment.
• 74% of Customs officials feel that the introduction of automated Customs systems has reduced opportunities for integrity violations, constituting an increase of 8% compared to 2021 results.

As for the perception of private sector representatives of Customs integrity, it overall rose from 6.56 in 2021 to 6.91 in 2024 on a scale of 0-10. It is important to note that the 2024 survey captured a broader segment of the private sector, with 611 respondents compared to 528 in 2021, an increase of 15.7%. This expanded sample size strengthens the reliability and representativeness of the observed improvement in perception.

Analysis of the answers provided by private sector stakeholders also indicated that:

• perception of transparency in handling private sector requests and cases has increased by 7%.
• the perception of level of competency of Customs officers has increased by 11%. 85% private sector respondents are now satisfied with the level of competency of Customs officials, of which 34% think that the level of competency is actually “high” as compared to 23% in 2021.

The broader impact of SARS’ integrity-focused transformation is evident also across several key performance indicators:

• Increased Customs revenue collection since 2021.
• 173% increase in the number of declarations (from 5.6 million to 15.2 million declarations) from FY 2021 to FY 2025.
• 49% increase (from R2.6 trillion to R3.9 trillion) of trade transactions in terms of value from FY2021 to FY2025 since 2021.
• Increased performance and service delivery: 78% of employee performance benchmarks met in 2024, compared with 74% in 2021.
• Restored public confidence: according to the CIPS, there is an enhancement in the perception of Customs integrity among Private sector stakeholders (with an average score 6.91 out of 10 in 2024) and, according to the third Trade Facilitation Index survey conducted in 2025, 72 % of private sector stakeholders are satisfied with the administration compared to 53% in 2023.
• Increased number of Authorized Economic Operators: A total of 525 operators have been accredited, with 337 at compliance level and 188 at safety and security level.

While notable progress has been registered to date, SARS recognizes that restoration of integrity is a continuous journey, and more still needs to be done. For example, only 70% of Customs Officers feel safe enough to report integrity violations, this means that 30% do not feel safe to report. Similarly, 22% of private sector respondents still “…do not feel safe enough to report instances of corruption” as per 2024 CIPS.

To maintain the momentum, a Customs and Excise Integrity Steering Committee, consisting of heads of modalities (Air, Sea and Land) and leads of clusters (C&E Compliance, Continuous improvement, Strategy, Stakeholder Engagement) and chaired by Director of Customs, meets quarterly. The Committee has already supervised the conduct of an Internal Integrity and Corruption Risk Analysis and Mapping exercise. The C&E Integrity Unit needed to develop internal capacity in this domain and with the support of the WCO Accelerate Trade Facilitation Programme developed standard operation procedures aligned with the WCO Guide to Corruption Risk Mapping (2015), the Integrity Development Guide (2021) and UNODC Guide on Conducting Corruption Risk Assessments in Public Organizations (2020).

A total of 47 risks (comprising 20 risks related to regulatory and legal acts, and 27 risks related to core operational processes) were identified and 40 recommendations were added to the Integrity Action Plan. In addition, the activity resulted in the development of a Corruption Risk Heat Map to visualize the assessed risks and positions vulnerable to corruption.

Results of the analysis will inform the review of policies, including those related to recruitment promotion, deployment, rotation, and learning and development initiatives. Following the developed procedures, all strategic, operational and administrative units will now be requested to conduct a corruption risk analysis regularly.

Looking ahead dictates that Customs continues to work unceasingly to confront and eviscerate corruption. This is an ongoing challenge that face many Customs Administrations. The outcome of the survey serves as a lodestar and a beacon that we must follow. The work that has been done will help to ensure that integrity is engendered into operations, sustained and continually strengthened. SARS’ progress to date marks a true cultural shift from reactive efforts to a sustainable model of continuous integrity promotion and assurance improvement. Hopefully our transformative journey can be inspiring to other Customs administrations.

[1] The Customs Integrity Perception Surveys conducted in South Africa in 2021 and 2024 were structured around the ten key factors of the WCO Revised Arusha Declaration and were based on the WCO CIPS Methodological Guidelines. However, the used CIPS’ survey questionnaires for Customs officials and Private Sector Stakeholders respectively included slight modifications to align with national operational specifics and to provide greater clarity in certain areas. While WCO Members are encouraged to adopt and adapt the survey to meet their national specific needs, it is important to clarify when a modified version is used, particularly for transparency and potential comparability across different countries, should statistical comparisons be made in the future. It is recalled that CIPS results are confidential.