International Comparisons

Mauritius was placed on the Financial Action Task Force grey list in February 2020 and removed in October 2021 — some twenty months — for a jurisdiction whose financial-centre business depends on correspondent banking and cross-border fund administration. It treated the listing as a commercial emergency rather than a compliance exercise. The action plan was driven centrally rather than left to each supervisor: supervision of the global business sector and the non-financial professions was rebuilt on a risk basis, beneficial-ownership data was made accessible in time to be useful, and law enforcement was equipped to run money laundering investigations alongside the predicate offence. The European Union removed Mauritius from its own high-risk list three months later, in January 2022.

Italy's answer to mafia extortion of construction was to attack the contract and the money rather than only the intimidation. A national anti-mafia investigative directorate created in 1991 pooled the intelligence held separately by the police, the carabinieri and the finance police into one inter-force capability. Anti-mafia documentation can bar an infiltrated firm from public contracts and subcontracts without waiting for a criminal conviction. From 2012, prefectural vetting lists covering ten infiltration-prone supply activities — among them earth and inert materials, concrete and bitumen, haulage and site guarding — became the route by which contracting authorities must obtain that clearance. And a state solidarity fund, reorganised in 1999, compensates businesses that report extortion.

Estonia built a national digital identity infrastructure (X-Road data exchange layer, e-ID card) from 2000. The X-Road interoperability layer — allowing government databases to communicate securely — is open-source and co-developed with Finland through the Nordic Institute for Interoperability Solutions. SA's GovTech and SITA have proposed equivalent systems but lack the political mandate and interoperability standards that drove Estonian success.

Brazil expanded one of the world's largest transmission networks by auctioning individual line concessions to whoever would build and operate them for the lowest annual revenue. The regulator specifies the route, the voltage and the in-service deadline; the winner finances and builds the line and is then paid a fixed annual permitted revenue for keeping it available, independent of how much energy flows over it. System operation stayed with an independent operator, so no builder controls dispatch. The design pulled private and state capital into transmission for two decades, and it is the closest available answer to how a ring-fenced transmission company finances a grid build-out it cannot fund from its own balance sheet.

Chile restructured its electricity sector in 1982, separating generation, transmission and distribution and introducing competitive private generation. The model became the global template for power-sector liberalisation and is directly relevant to Eskom unbundling proposals. Key success factors: a load dispatch centre (CDEC) run collectively by the generators (an independent coordinator came only with Law 20,936 of 2016), long-term power purchase agreements to de-risk private investment, and regulated access to transmission infrastructure.

India scaled utility-scale solar through competitive reverse auctions, viability gap funding, and the National Solar Mission. The IPP procurement model with government offtake guarantees removed private-sector financing risk. SA's REIPPP programme closely mirrors this model.

Turkey broke up a vertically integrated state electricity monopoly by statute rather than by shareholder decision. The 2001 electricity market law created an independent market regulator holding licensing, market-rule and tariff powers, and under it the incumbent was split into separate state-owned companies for generation, transmission and wholesale trading. Transmission stayed in state hands as the neutral platform, which took the question of who owns the network out of the argument. Generation was opened to licensed independent producers, and the state distribution regions were restructured and only then transferred to private operators, region by region, over the following decade. Distribution, not the transmission split, was the contested stage.

Australia created a federal Small Business and Family Enterprise Ombudsman, operating from March 2016, with two distinct powers: assisting individual small businesses in disputes, and conducting own-motion inquiries into market-wide practices. The second power is what moved late payment. The Ombudsman's 2017 inquiry into payment times and practices documented large firms and public agencies extending terms unilaterally, and the response was not more adjudication but disclosure and a hard rule for government itself: a commitment binding Commonwealth agencies to pay suppliers within twenty calendar days, and later legislation compelling large businesses to report publicly the payment terms they impose.

Georgia cut petty corruption dramatically after 2004: the entire traffic police was dismissed and replaced with a smaller, better-paid force. Public service salaries were raised to market rates, funded by tax administration reform. Transparency International CPI improved from 1.8 (2003) to 52/100 (2014). The approach required political will to absorb short-term disruption but demonstrated that rapid institutional change is possible. SA's NPA and SAPS face analogous institutional capture challenges.

The Philippines rebuilt its public-private partnership programme around the diagnosis that the binding constraint was project preparation, not project ideas. An executive order of 2010 reconstituted the old build-operate-transfer centre as a PPP Centre attached to the planning authority, with a mandate to prepare, appraise and monitor projects owned by line agencies, and renamed and funded its project preparation arm as a revolving Project Development and Monitoring Facility. The facility hires feasibility consultants and legal and financial transaction advisers on the agency's behalf and recovers what it spends from the project once that project is awarded, so the money returns to be spent on the next one. Contracts and bid documents were standardised alongside it.

Sweden cut employer social security contributions for young workers in 2007, deepened the cut in 2009 and repealed it from 2015 — a full policy cycle read off administrative payroll data. The evaluations are why the case matters, and they do not agree. The earlier evaluation found only a small employment response and put the cost per job created at several times the cost of simply hiring workers at the average wage. The later one, on the same reform, found youth employment two to three percentage points higher. What both establish is where the money went: not into young workers' take-home pay, which did not move, but to firms that already employed many young people — who expanded, and who raised the wages of their whole workforce, old and young alike.

Brazil legislated against municipal permitting as the bottleneck on mobile and fibre rollout, and then took seven more years to make the law work. The 2015 general antenna law set one national framework for siting approvals — a standard application, infrastructure sharing, and a hard rule that no licence may take longer than sixty days. What it did not carry was any consequence for a municipality that let the sixty days pass: the deemed-approval clause was vetoed out of the enacted text. Only a further statute in 2022 provided that silence authorises the operator to install. The deadline existed from 2015; the remedy for missing it did not.

India launched an electronic travel authorisation for tourists in November 2014 — renamed the e-Tourist Visa soon after — for a short list of nationalities and a handful of airports, then widened eligibility in tranches and subdivided the product into purpose-specific categories for business, medical, student and conference travel. The application is filed and paid for online and the authorisation is issued electronically before departure, with biometrics captured on arrival at designated ports rather than at a mission beforehand. The constraint that governed the rollout was never the platform: it was the country-by-country judgement about who could be admitted on a document check.

In 2008, registering a company in Rwanda took nine procedures and 16 days. After the 2010 digitisation, a complete online application is processed within a single working day, and the new company leaves the process with its tax registration done. Rwanda is regularly ranked among the fastest places in Africa to start a business.

Canada replaced first-come-first-served processing of skilled-worker applications with Express Entry in January 2015. Applicants who meet the minimum criteria enter a standing pool and are scored on a published points formula; the department invites the highest-ranked to apply in rounds held roughly fortnightly, and only those invited file a full application, against a published processing service standard. The scarce-skills judgement is therefore made continuously by a formula the government can retune, rather than by a schedule of occupations that ages between gazettes, and provinces and employers draw from the same pool through their own nomination streams. Backlogs moved from the queue to the invitation policy, where they can be managed.

South Korea built a network of polytechnic colleges from 1974, funded by a mandatory training levy with employer governance over curriculum. Engineers from these colleges staffed semiconductor, shipbuilding, and automotive industries that drove Korea's growth miracle. SA's SETA system collects a similar levy but training does not match employer demand — Korea's success rested on industry governance of curriculum, not just funding.

Brazil concessioned its federal railway to private operators in 1997. Key success factors: 30-year concession terms, capital expenditure obligations written into contracts, and an independent regulator (ANTT) with tariff-setting authority. SA's Transnet rail concession debate mirrors Brazil's pre-1997 institutional state almost exactly.

Germany's 1994 Bahnreform merged the two state railways into Deutsche Bahn AG, opened the network to competing train operators against payment of track charges, moved the inherited debt to a federal agency, and handed regional passenger services to the Länder to tender. The dates that follow are the lesson. Infrastructure became a separate company inside the DB holding only in 1999; rail regulation passed to the Federal Network Agency in 2006; and a general requirement that track access charges be approved before they take effect arrived with the Rail Regulation Act of 2016. Access was granted in year one and the power to police its price took twenty-two years.

Vietnam opened container terminal development to private and foreign investment after severe congestion at Ho Chi Minh City's inner-city ports in 2006–08, and joint ventures between state port enterprises and global terminal operators built the country's first deep-water container berths at Cai Mep-Thi Vai, the first opening in May 2009. The World Bank's assessment calls the new terminals a watershed in Vietnam's connectivity: ocean carriers could for the first time run services direct to North America and Europe rather than feedering through Singapore or Hong Kong, an estimated saving of USD 150–300 per container. The same assessment records what concessioning without capacity discipline cost: licences ran ahead of demand, and by September 2012 the Cai Mep-Thi Vai terminals were operating at 18 percent of their 5.2 million TEU capacity, with three of the five receiving no regular container calls.

France funds water infrastructure from charges on the people who abstract and pollute water, collected and spent inside the river basin that generates them. The 1964 water law created, in each basin, a committee on which local authorities and users hold at least two-thirds of the seats, and an agency that levies charges on public and private users — six of each, once the basins were delimited. The load-bearing clause is the one that runs the arithmetic backwards: the total charge take is set by what the agency's multi-year investment programme costs. Payers vote the programme and are billed for it, which is why cost-reflective abstraction charges have survived six decades.