MADLANGA COMMISSION: SAPS needs once-off ‘deep clean’ targeting corrupt officers — World Bank expert

On Wednesday, 16 September, Laura Pop, a senior financial sector specialist at the World Bank, told the Madlanga Commission of Inquiry that SAPS might need to undergo a once-off “deep cleaning” exercise, which she described as an extraordinary evaluation, to address integrity failures in the compromised institution, restore its integrity and rebuild public trust.

Her testimony came a day after a damning portrait of alleged police corruption emerged at the Madlanga Commission when Johannesburg Metropolitan Police Department (JMPD) Internal Affairs chief Superintendent Elmarie de Beer took the stand.

De Beer outlined a pattern of alleged collusion between some officers and criminal syndicates, identifying the Tactical Response Unit, Special Projects Unit and, to a lesser extent, the K9 Unit as the divisions most frequently implicated in cases investigated by Internal Affairs.

But the warning signs of criminal infiltration predate the commission itself. They came into sharp public focus on 6 July 2025, when KwaZulu-Natal police commissioner Lieutenant General Nhlanhla Mkhwanazi made explosive allegations about criminal syndicates operating within law enforcement.

More than a year later, the evidence before the Madlanga Commission has brought those allegations into a broader institutional focus, with testimony pointing to alleged systemic corruption, political interference and links between senior law-enforcement figures and organised crime.

Pop testified how criminal syndicates could exploit weaknesses in state institutions, and how illicit money could move through systems designed to prevent it. She told the Commission that South Africa’s problem was not unique. Globally, the capture or infiltration of criminal justice institutions by corrupt individuals and organised crime was “unfortunately not an isolated phenomenon”.

“To clean up a compromised institution quickly and at scale through ordinary processes is simply unrealistic for many countries,” Pop told the commission.

Who is Laura Pop?

Laura Pop is a senior financial sector specialist at the World Bank and a member of the World Bank-UNODC Stolen Asset Recovery Initiative (StAR).

She has 17 years’ experience in anti-corruption work across more than 20 countries, including South Africa, focusing on illicit asset recovery, financial disclosure, money laundering and strengthening institutions that investigate economic crime.

Don’t wait for criminal convictions

Pop’s proposal for an extraordinary evaluation addresses a critical question: must the state wait for a criminal prosecution or civil recovery process to conclude before deciding whether an official should remain in a position of trust?

The purpose of the deep cleaning exercise would be to avoid that lengthy wait, while evidence gathered in criminal investigations could be considered where it pointed to misconduct or an integrity breach.

She also proposes that previous vetting should not provide a safe harbour. An earlier financial disclosure review or security clearance would not prevent fresh scrutiny. In the context of the Madlanga Commission, this addresses a broader question raised by the inquiry: whether existing safeguards are sufficient to detect or prevent the alleged infiltration now being investigated.

Pop said the once-off exercise would not be a permanent substitute for ordinary accountability systems. The longer-term challenge, she said, would be preventing re-infiltration through stronger financial verification, appointment processes and independent oversight. 

Not every officer would face the ‘deep clean’

Pop’s proposed extraordinary evaluation would be selective, focusing on officials whose positions create the greatest risk of corruption or interference.

This would include senior management, officials controlling financial resources and those in high-risk roles with the power to start, stop, suspend or transfer criminal cases, a particularly significant category given the commission’s evidence of alleged political interference and compromised investigations.

The evaluation would also cover officials appointed, promoted or transferred into these positions during the process, preventing vacancies from being filled without integrity checks. Other officials would remain subject to existing disciplinary mechanisms.

Pop proposes three areas of scrutiny: financial integrity, associations and conflicts of interest, and past conduct. Financial checks would examine whether assets and spending match lawful income, including indirectly held assets. Associations with organised crime and conduct such as interference in investigations, protecting syndicates or misuse of intelligence would also be assessed.

The credibility of such a system, Pop argues, would ultimately depend on who runs it. She proposes an independent evaluation body with secure tenure, supported by its own professional secretariat of analysts and investigators with access to the financial and other records needed to conduct the assessments.

Extraordinary powers still face legal scrutiny

As evidence leader advocate Matthew Chaskalson, SC, emphasised, Pop’s proposal would still have to meet established South African administrative justice standards.

Pop’s proposed extraordinary evaluation would not give the state a free hand to remove officials. The process would have to be structured around procedural safeguards designed to withstand legal challenge, principles familiar to South African administrative law.

Officials would have to know the case against them, access the evidence, have a meaningful opportunity to respond and receive reasons for the decision. The criteria would need to be clear, predetermined and applied proportionately. 

The criteria could not be vague or changed along the way. Pop’s international review found that processes which survived legal challenges generally relied on published methodologies, clear assessment criteria, individual hearings, reasoned decisions and an assessment of whether the proposed consequence was proportionate to the finding.

The same principle would apply to financial scrutiny. The burden would not simply shift to an official to explain their wealth. The evaluation body would first have to identify a specific discrepancy or unexplained variation. Only then would the official be required to explain it.

That distinction matters. Pop said the purpose was not to punish officials for minor mistakes or innocent discrepancies in their financial profiles. The process was intended to address a systemic integrity crisis, and its credibility would depend on distinguishing material concerns from errors that could reasonably be explained.

Asked by Commissioner Sandile Khumalo SC whether this amounted to a materiality threshold, Pop agreed that minor discrepancies could be overlooked, while significant unexplained variations should trigger further inquiry. South Africa could leave that threshold to the evaluation body, provided clear criteria governed its discretion.

The question of amnesty

Khumalo asked Pop whether she had encountered systems where officials were encouraged to confess to wrongdoing in exchange for immunity or amnesty, rather than simply being removed after failing an integrity assessment.

The logic was that an extraordinary evaluation would never identify everyone. Insiders may know far more about how a compromised system operates than an external assessment can uncover, but may be reluctant to come forward if doing so exposes them to criminal prosecution.

Pop said she was aware of such approaches, including the use of plea bargaining, but had not encountered the use of an amnesty mechanism as part of the extraordinary integrity assessment models she had studied.

Justice Madlanga told Pop that the commission would ultimately have to decide for itself what constituted “systemic” failure if South Africa were to pursue extraordinary measures.

But, he raised a difficulty. The commission has a relatively short lifespan and can examine only a small window into the criminal justice system.

“Regarding what we shall have looked at in the end, we shall have looked through a very small window, and therefore we shall have seen very little through that very small window,” Madlanga said.

Compared with the tens of thousands of people working across the criminal justice system, he suggested, the number of officials the commission could examine would represent only a tiny fraction.

Pop acknowledged the limits of the commission’s perspective, but said South Africa had something other countries facing similar problems did not: a process specifically established to examine the allegations in real time.

Ultimately, she said, the task was to document what could be established from the available information and use that evidence, even if it was not perfect, to identify where change was needed. DM