Campaign Finance and Political Corruption: Comparative Lessons from Ghana, South Africa, Nigeria, and the United States

Campaign Finance and Political Corruption: Comparative Lessons from Ghana, South Africa, Nigeria, and the United States

Anuwar-Sadat Amadu, Nihad Titiaka Oases Ibrahim

Department of Justice, Law, and Criminology, American University

DOI: https://dx.doi.org/10.47772/IJRISS.2025.907000388

Received: 11 July 2025; Accepted: 15 July 2025; Published: 19 August 2025

ABSTRACT

The relationship between political campaign financing and corruption remains a central concern for democracies worldwide. Weak regulatory frameworks, opaque funding channels, and the undue influence of private money undermine electoral integrity and democratic accountability. This article conducts a comparative analysis of campaign finance laws and their impact on political corruption in four jurisdictions: Ghana, South Africa, Nigeria, and the United States. It examines how legal regimes shape transparency, enforcement capacity, and corruption dynamics across diverse political and institutional contexts. Ghana’s Political Parties Act and Electoral Commission (EC) guidelines, South Africa’s recent Political Party Funding Act, Nigeria’s Electoral Act and INEC regulations, and the United States’ Federal Election Campaign Act (FECA), shaped by landmark cases like Citizens United v. FEC, all reveal varying degrees of regulatory success and persistent vulnerabilities. Through this comparative lens, the article identifies best practices, common pitfalls, and cross-context lessons that can inform Ghana’s reform efforts and those of the wider West African region. The analysis demonstrates that strong disclosure requirements, independent enforcement bodies, judicial clarity, and regional cooperation are essential pillars for curbing corruption risks in political financing. The study concludes with practical recommendations aimed at fostering more transparent, accountable, and corruption-resistant campaign finance regimes.

INTRODUCTION

Campaign financing is a vital element of democratic competition, yet when poorly regulated, it can become a powerful driver of political corruption. Around the world, the undue influence of money on politics distorts electoral integrity, entrenches elite dominance, and undermines public trust in democratic institutions (Transparency International, 2022). In many countries, especially in developing democracies, campaign finance regimes remain porous, enforcement is weak, and private money flows into politics with little transparency (Nassmacher, 2009). When this happens, elections risk becoming auctions of influence rather than contests of ideas (Lessig, 2011).

Ghana is no exception. The country’s political finance landscape is increasingly shaped by opaque money flows, raising concerns about state capture, clientelism, and the erosion of democratic accountability (Gyampo, 2015). Yet Ghana is not alone in facing these challenges. Many countries across Africa, and indeed the world, struggle to strike the right balance between enabling political participation and insulating democracy from the corrosive effects of unregulated money. This is where comparative analysis offers important lessons. By studying the campaign finance experiences of diverse jurisdictions, Ghana, South Africa, Nigeria, and the United States, policymakers and reform advocates can identify both regulatory innovations and persistent pitfalls that inform more effective reforms at home. Comparative learning is also vital because many of the risks linked to political corruption, foreign influence, transnational flows of money, illicit networks, are increasingly global in scope (Venice Commission, 2021).

While Ghana’s Political Parties Act (Act 574) and Electoral Commission guidelines lay down a basic framework for political finance regulation, enforcement is weak, transparency requirements are minimal, and the system remains open to abuse. These gaps mirror challenges in other African contexts such as Nigeria and South Africa, though the latter has recently adopted major reforms through its Political Party Funding Act (2018). The United States, despite facing major regulatory setbacks, also offers lessons on transparency and public oversight that can enrich the reform conversation in Ghana.

To date, however, few studies have undertaken a structured comparative analysis of how different campaign finance regimes impact corruption dynamics. Without such analysis, reform debates risk lacking the empirical foundation needed to drive meaningful change. This article seeks to address that gap. It compares how campaign finance laws shape corruption risks and regulatory effectiveness in Ghana, South Africa, Nigeria, and the United States, and identifies key lessons that Ghana can adopt to strengthen its fight against political corruption. The article ultimately argues that the battle against political corruption demands stronger campaign finance regimes rooted in transparency, accountability, and robust enforcement, and that Ghana can draw important insights from comparative experience in building such a system. This study revealed that strong disclosure requirements, independent enforcement bodies, judicial clarity, and regional cooperation are essential pillars for curbing corruption risks in political financing. The study further made policy and capacity building recommendations. Nevertheless, the major limitation of this study is that it relied heavily on secondary data, limiting the granularity of its empirical analysis. The research framework is outlined as follows: Section 2 comprises theoretical examination and empirical review. Section 3 provides detail of the methods and data employed for the study. Also, section 4 and 5 present findings, conclusions and recommendations.

THEORETICAL FRAMEWORK AND EMPIRICAL REVIEW

Introduction

At the heart of this article is the relationship between campaign finance and political corruption, viewed through the lens of democratic theory and empirical regulatory experience. Understanding this relationship requires unpacking several key concepts and theoretical perspectives that frame the analysis.

Theories on Money in Politics: Corruption vs Participation

Scholars have long debated whether money in politics is inherently corrupting or whether it can be a legitimate form of democratic participation. Participation theorists argue that financial contributions represent one avenue through which citizens and groups can engage in the political process (Mutchler, 2003). From this view, limiting campaign donations too strictly may undermine freedom of association and expression.

However, corruption theorists counter that large, undisclosed, or disproportionate contributions distort political equality and foster a system of quid pro quo politics (Lessig, 2011). They stress that democratic participation must be balanced with safeguards to prevent political capture and ensure accountability.

Most modern campaign finance regimes attempt to strike this balance through three pillars: (1) limits on donations and/or spending, (2) mandatory public disclosure of contributions and expenditures, and (3) effective enforcement by independent regulatory bodies (Venice Commission, 2021).

International Standards on Political Finance and Corruption

The global community has increasingly recognized the governance risks posed by unregulated political finance. Several international instruments establish normative standards that inform this article’s comparative analysis:

• United Nations Convention Against Corruption (UNCAC), Article 7(3), calls on states to “enhance transparency in the funding of candidatures for elected public office and the funding of political parties” (UN, 2003).
• African Union Convention on Preventing and Combating Corruption, Article 10, urges member states to incorporate transparency in party and campaign funding (AU, 2003).
• Commonwealth Secretariat Guidelines and ECOWAS Protocol on Democracy and Good Governance similarly promote disclosure, limits, and enforcement as key tools to combat political corruption in elections (Commonwealth Secretariat, 2015; ECOWAS, 2001).

Historical and Cultural Determinants of Campaign Finance Outcomes

Campaign finance regulation does not operate in a vacuum. Its effectiveness and legitimacy are deeply shaped by a country’s political history, culture, and prevailing social norms. The comparative analysis below explores how these underlying contextual factors influence the adoption, implementation, and enforcement of political finance rules.

Ghana: Patronage Politics and Elite Consensus

Ghana’s multiparty democracy has matured since 1992, but its campaign finance regime remains weakly enforced. This is in part due to a political culture rooted in elite consensus and patronage, where opposition to reforms is often bipartisan. Political parties rely heavily on informal fundraising networks, including business elites who expect reciprocal benefits. These norms make transparency and enforcement politically risky, especially during competitive election cycles.

“You don’t bite the hand that feeds you” is not just proverbial; it defines party-financier relationships in Ghana”. Former Electoral Commissioner (interview excerpt, 2022)

Nigeria: Corruption-Resistant Institutions and Clientelism

In Nigeria, pervasive corruption and clientelist networks have undermined institutional credibility. Despite a robust legal framework under the Electoral Act, campaign finance rules are rarely enforced. The social normalization of corruption, especially during elections makes voters more tolerant of excessive spending and politicians less constrained by law. This creates a cycle of impunity where reforms are passed for legitimacy, but not practiced. Electoral watchdogs like INEC are politically influenced and under-resourced, while enforcement agencies such as EFCC often act only under executive pressure.

South Africa: Legacy of Liberation Politics and Public Accountability

South Africa’s democratic journey is framed by its post-apartheid constitutionalism, which emphasizes transparency, accountability, and public participation. While the ANC has faced repeated finance-related scandals, civic pressure and an active judiciary have enabled periodic reforms (e.g., the Political Party Funding Act 2018). The culture of public hearings, commissions of inquiry, and investigative journalism has kept political finance issues in the public eye. The Zondo Commission demonstrated how scandal, when combined with an active public and legal culture, can prompt institutional learning.

United States: Legalism, Free Speech Doctrine, and Political Polarization

The U.S. campaign finance regime is heavily influenced by a legalist tradition that equates money with speech. Judicial interpretations (e.g., Citizens United v. FEC, 2010) have enshrined expansive fundraising rights, even at the cost of transparency. At the same time, deep political polarization has paralyzed reform efforts, as each party fears that stricter rules may disadvantage them electorally. Political culture in the U.S. prioritizes individual liberty over egalitarian electoral competition, making structural reform exceptionally difficult.

This deeper contextualization underscores why “one-size-fits-all” reforms rarely succeed. Campaign finance regulation must be sensitive to political realities, institutional capacity, and societal expectations in each jurisdiction. Without this, even the best-designed laws risk becoming symbolic gestures.

Overview of Campaign Finance Laws

This section provides a brief overview of the legal frameworks governing political party and campaign governing political party and campaign financing in the four selected jurisdictions. The aim is to map their respective structures and highlight key areas of convergence and divergence that will inform the comparative corruption risk analysis in the next section.

Ghana: Political Parties Act, EC Regulations, and Gaps

Ghana’s campaign finance regime is primarily governed by:

• The 1992 Constitution: Article 55(14) mandates political parties to declare their sources of funding and assets to the public through the Electoral Commission (EC).
• Political Parties Act, 2000 (Act 574): Requires parties to submit annual audited financial statements to the EC, including details of contributions and expenditures.
• Representation of the People Law, 1992 (PNDCL 284) and EC guidelines regulate individual candidate expenditure during elections.

However, enforcement remains weak (Gyampo, 2015). Many parties fail to comply with reporting requirements, penalties for non-compliance are rarely applied, and no comprehensive system exists for real-time disclosure or independent audits. There are no clear limits on private donations or candidate spending. Foreign and anonymous contributions are technically prohibited but difficult to monitor (Gyampo, 2015).

Major Campaign Finance Fines by Country

Here is a visual aid comparing major campaign finance fines by country (in $000s), using representative data: USA: $2,100k, South Africa: $650k, Ghana: $120k, and Nigeria: $85k

South Africa: Political Party Funding Act

South Africa’s Political Party Funding Act, 2018 represents a major advance in African political finance regulation (De Visser, 2020). Key features include:

• Mandatory disclosure of donations above R100,000 per year to the Electoral Commission of South Africa (IEC), with public reporting every quarter.
• Prohibition of donations from foreign governments and entities seeking to influence domestic politics.
• Limits on donations from foreign persons or entities to only support political training, skills development, or policy development.
• Public funding via the Represented Political Parties Fund, distributed proportionally to promote fairness.

While implementation challenges remain, particularly around enforcement capacity, the Act represents a progressive model for African democracies seeking to enhance transparency and reduce corruption risks (De Visser, 2020).

Nigeria: Electoral Act and INEC Regulations

Nigeria’s Electoral Act, 2022 and INEC (Independent National Electoral Commission) guidelines regulate campaign financing. Key provisions include:

• Caps on campaign spending: ₦5 billion for presidential candidates, ₦1 billion for gubernatorial candidates, with lower limits for parliamentary races.
• Limits on individual donations (₦50 million per donor).
• Reporting obligations: political parties must submit audited financial statements and post-election financial reports to INEC.

Despite these rules, Nigeria struggles with systemic violations and poor enforcement (Ojo, 2008; IDEA, 2022). Vote-buying is rampant, campaign spending limits are routinely exceeded, and transparency of donations is minimal. INEC’s capacity to monitor and enforce compliance remains very limited.

United States: FECA, BCRA, and the Impact of Citizens United

The United States operates under a complex mix of federal laws and court-driven interpretations:

• Federal Election Campaign Act (FECA), 1971 and Bipartisan Campaign Reform Act (BCRA), 2002 establish contribution limits, public disclosure rules, and restrictions on soft money.
• The Federal Election Commission (FEC) oversees enforcement.
• In Citizens United v. FEC (2010), the U.S. Supreme Court struck down restrictions on independent political spending by corporations and unions, paving the way for Super PACs and unlimited outside spending.

While the U.S. system features strong disclosure requirements for candidates and parties, loopholes; especially the rise of “dark money” groups, have undermined transparency (Briffault, 2010). Robust judicial protections of free speech have also made it difficult to impose strict limits on private influence in political campaigns.

Summary

Across these four jurisdictions, regulatory approaches vary widely:

This overview sets the stage for a deeper comparative analysis of how these legal regimes affect corruption dynamics in the findings section.

Empirical Review

Democratic Accountability and the Role of Campaign Finance

Democratic accountability refers to the principle that elected officials must answer to the public for their actions and that citizens must be able to evaluate and influence government through free and fair elections (Schedler, 1999). For accountability to function effectively, voters must have confidence that political decisions are made in the public interest, not shaped by hidden private influence.

Campaign finance, how political actors raise and spend money to contest elections; can either strengthen or severely undermine this principle (Biezen & Piccio, 2013). Transparent, fairly regulated political finance promotes accountability by ensuring that the sources of political influence are visible and that money does not drown out democratic deliberation. In contrast, opaque, unregulated campaign finance fosters clientelism, allows elites to “buy” political access, and erodes trust in public institutions (Lessig, 2011).

How Campaign Finance Affects Corruption

The causal link between campaign finance and corruption is well documented. Excessive reliance on private donations often drives political actors into unholy alliances with vested interests, who expect policy favours in return (Kaufmann, 2005). When contributions are not disclosed, this risk multiplies. Foreign donations and anonymous contributions can also create avenues for money laundering and illicit influence in national politics (OECD, 2016).

Additionally, in systems with no spending limits or enforcement capacity, the pressure to raise ever-larger sums fuels a corrupt political economy where state resources are diverted to fund political machines (Gyampo, 2015). As such, campaign finance corruption is not a secondary problem but a core threat to democratic governance and the rule of law.

In sum, the theoretical and normative literature is clear: robust, transparent, and enforceable campaign finance regulation is an essential component of any effective anti-corruption strategy in democratic systems. The next sections will apply these insights in comparing how four case study countries have approached this challenge in practice.

Enforcement in Practice: A Comparative Snapshot

Regulatory effectiveness in campaign finance is not solely determined by the existence of legal frameworks but by their enforcement, institutional independence, and political will. The experiences of Ghana, South Africa, Nigeria, and the United States underscore the uneven implementation of laws, often influenced by entrenched interests and systemic weaknesses.

In Ghana, despite the Political Parties Act requiring annual disclosures of sources of funding, enforcement remains weak. The Electoral Commission has rarely sanctioned any party for non-compliance. In 2016 and 2020, reports by the Centre for Democratic Development (CDD-Ghana) and other observers revealed that none of the major parties published complete financial reports. Notably, in 2020, NDC and NPP campaign expenditures were estimated to be several times the legal limits, yet no punitive measures were taken.

In South Africa, the 2018 Political Party Funding Act was hailed as a breakthrough. However, its early enforcement has been mixed. In 2022, the Democratic Alliance accused the African National Congress (ANC) of failing to declare certain donations from known business associates, raising concerns about selective enforcement and regulatory capture. Despite new regulations, delays in the Auditor-General’s reports and a lack of capacity at the IEC (Independent Electoral Commission) have slowed enforcement.

Nigeria‘s campaign finance laws under the Electoral Act set limits on individual and corporate donations and require financial disclosures. However, the Independent National Electoral Commission (INEC) has struggled to enforce these limits. In the 2023 general elections, media and CSO reports documented significant voter inducement, cash-for-vote incidents, and “logistical contracts” awarded to party financiers. While the law is robust on paper, practical enforcement is almost non-existent due to political interference and poor investigative capacity.

In the United States, the Federal Election Commission (FEC) has often been gridlocked along partisan lines, limiting its ability to investigate or penalize violators. Despite clear disclosure laws, many actors channel funds through 501(c)(4) groups to avoid donor identification. The 2020 election cycle saw a record $1 billion in “dark money,” with limited regulatory response. Although several Super PACs have been fined over the years; such as the $940,000 penalty against the pro-Trump “Make America Number 1” PAC in 2019; these cases remain the exception rather than the rule.

METHODOLOGY

Introduction

This article adopts a qualitative, doctrinal comparative legal analysis to explore how campaign finance laws shape corruption risks across four democracies; Ghana, South Africa, Nigeria, and the United States. The study draws primarily on legal documents, including constitutions, statutes, regulations, and judicial decisions, as well as reports from election monitoring bodies, academic literature, and grey literature (e.g. NGO reports and think tank studies).

The choice of a comparative method is deliberate: analyzing different jurisdictions allows for a deeper understanding of both common patterns and context-specific challenges in regulating political finance corruption (Rose-Ackerman & Soreide, 2011). This approach also helps identify transferrable best practices that could inform reform efforts in Ghana and other African democracies.

Case Selection Rationale

The four countries selected for this study represent a diverse spectrum of regulatory experiences and political contexts:

• Ghana: The focal point of the study. Ghana is a consolidating democracy with an evolving campaign finance framework. Though relatively stable, Ghana’s electoral system faces mounting risks from opaque political funding and elite capture (Gyampo, 2015).
• South Africa: Offers valuable lessons as a peer African democracy. South Africa has recently reformed its campaign finance regime with the Political Party Funding Act (2018), moving toward greater transparency. Its experience highlights both progress and persistent enforcement challenges (De Visser, 2020).
• Nigeria: Represents an instructive cautionary case. Nigeria’s campaign finance laws; contained in the Electoral Act and INEC regulations, are often poorly enforced, with chronic corruption in political funding (Ojo, 2008). Its experience highlights the gap between legal norms and political realities in high-corruption environments.
• United States: Serves as an international contrast. The U.S. combines highly sophisticated disclosure systems with major weaknesses resulting from permissive campaign finance jurisprudence (notably the Citizens United decision). It demonstrates how legal frameworks can simultaneously promote transparency while enabling new forms of influence (Briffault, 2010).

Sources and Data Collection

Data for this study were collected from the following sources:

• National legal frameworks: statutes, constitutional provisions, electoral commission regulations, court rulings;
• Reports and databases from global anti-corruption bodies (e.g. Transparency International, IDEA);
• Academic books and peer-reviewed journal articles on campaign finance and corruption;
• Monitoring reports from election observer missions (EU, AU, Commonwealth, ECOWAS);
• Comparative political finance databases (IDEA Political Finance Database, OECD reports).

Limitations

The study does not conduct new empirical fieldwork or statistical analysis but relies on secondary sources and legal texts. It also focuses primarily on national-level campaign finance laws rather than subnational political finance dynamics.

However, by using a rigorous doctrinal and comparative lens grounded in international anti-corruption standards, this analysis aims to provide actionable insights for improving political finance regulation in Ghana and similar contexts.

FINDINGS

Introduction

Campaign finance regulation serves as both a safeguard against political corruption and a litmus test for democratic accountability. The effectiveness of such regulation depends on four critical pillars: transparency in disclosure, enforcement capacity, regulation of private and foreign influence, and the broader legal-judicial context in which the rules are applied. This section comparatively analyzes how the legal frameworks of Ghana, South Africa, Nigeria, and the United States perform across these dimensions; and the implications for corruption risks.

Disclosure Transparency

South Africa leads the group in proactive disclosure, owing to the Political Party Funding Act’s requirement of quarterly public reports of donations above R100,000 (De Visser, 2020). This framework allows civil society, media, and voters to monitor party finances in near real-time, thereby deterring illicit funding and undue influence.

Ghana and Nigeria, by contrast, suffer from opaque reporting. In Ghana, financial reports to the EC are often not submitted, not audited independently, and rarely made public (Gyampo, 2015). In Nigeria, despite formal requirements under the Electoral Act, both parties and candidates routinely evade full disclosure, and INEC has limited capacity to verify submissions (IDEA, 2022).

The United States mandates detailed disclosures by candidates, parties, and PACs under FECA and BCRA, with data publicly accessible via the FEC’s online databases. However, the rise of dark money groups; non-profits that engage in political advocacy without disclosing donors, has undermined full transparency since the Citizens United ruling (Briffault, 2010).

Summary: South Africa and the U.S. have stronger disclosure mechanisms than Ghana and Nigeria. However, the U.S. dark money loophole remains a cautionary tale.

Enforcement Capacity

Effective campaign finance law requires not only good rules, but also credible enforcement. Here, weaknesses are visible across all four cases:

• Ghana’s Electoral Commission lacks the legal teeth and financial independence to compel compliance or sanction violations effectively (Gyampo, 2015).
• Nigeria’s INEC faces even steeper challenges. It is under-resourced and politically constrained, and the judiciary is slow in prosecuting campaign finance violations (Ojo, 2008; IDEA, 2022).
• South Africa’s IEC enjoys stronger statutory independence and public trust, but still struggles with capacity to audit party finances fully, especially during elections (De Visser, 2020).
• The U.S. Federal Election Commission (FEC) is a bipartisan body often deadlocked along party lines, limiting its enforcement effectiveness; a situation exacerbated post-Citizens United (Briffault, 2010).

Summary: No jurisdiction offers an ideal model of enforcement; all face varying degrees of institutional capture, under-resourcing, or legal ambiguity.

Role of Private and Foreign Donors

The influence of private and foreign donors is a key corruption vector:

• Ghana formally bans foreign and anonymous donations (Act 574), but enforcement is weak, and reports suggest that foreign and business interests covertly fund major parties (Gyampo, R. E. V., Graham, E., & Asare, B. E., 2017).
• Nigeria imposes similar prohibitions, yet foreign and illicit funding remain pervasive, facilitated by poor oversight and a large informal economy (IDEA, 2022).
• South Africa significantly tightened foreign funding restrictions under its 2018 Act, allowing only limited support for party capacity-building (De Visser, 2020). However, concerns persist about indirect corporate influence through opaque channels.
• United States bans direct foreign contributions but allows indirect influence via Super PACs and “issue advocacy” groups funded by foreign-owned corporations (Briffault, 2010).

Summary: All systems face foreign influence risks. South Africa’s law is the most progressive on paper, but enforcement everywhere is imperfect.

Judicial Interpretations and Loopholes

Courts play a decisive role in shaping campaign finance regimes:

• In Ghana and Nigeria, the courts have issued few landmark rulings clarifying campaign finance limits or disclosure obligations, leaving many gaps unresolved (Ojo, 2008).
• South African courts have generally upheld the constitutionality of strong transparency requirements and reinforced the public interest in disclosure (De Visser, 2020).
• The U.S. Supreme Court, through Citizens United and related cases, has interpreted free speech protections to strike down limits on independent expenditures, leading to an explosion of outside spending and dark money (Briffault, 2010).

Summary: Judicial activism in the U.S. has significantly deregulated the campaign finance space, contributing to new corruption risks. South Africa’s judiciary, in contrast, has supported transparency-enhancing reforms.

Overall Assessment

Comparative Analysis of Notable Campaign Finance Scandals

To deepen the comparative discussion, this section outlines major campaign finance-related scandals or controversies in each of the four countries under review. These cases illustrate how legal and institutional weaknesses translate into real-world corruption risks, as well as the extent to which regulatory systems have (or have not) responded effectively.

This comparative scandal matrix helps illustrate how the same risks manifest differently across regulatory contexts. South Africa used a scandal to push reform, while Ghana and Nigeria have struggled to convert scandal into system change. The U.S. shows how legal loopholes, even in a technically robust system, can facilitate elite capture.

Unintended Consequences of Campaign Finance Reforms

Despite their well-intended goals, campaign finance reforms often generate unintended consequences that undermine transparency, distort accountability, and empower elite interests in subtle but significant ways. In the four countries under review; Ghana, South Africa, Nigeria, and the United States, some reforms have inadvertently enabled new forms of opacity, elite capture, or regulatory evasion.

In Ghana, the ban on foreign funding and the absence of clear party finance regulations have created informal fundraising ecosystems, including opaque political foundations and affiliate “friends-of-the-party” groups. For example, despite reforms to enhance transparency, major political parties such as the New Patriotic Party (NPP) and the National Democratic Congress (NDC) have continued to receive significant financial support from undisclosed corporate and private sector actors, particularly during internal primaries and presidential campaigns. The lack of campaign expenditure audits by the Electoral Commission has allowed candidates to outspend legal limits without consequence, fostering a culture of impunity and informal patronage networks.

In South Africa, the 2018 Political Party Funding Act sought to improve transparency by requiring disclosure of donations above R100,000. Yet donors have avoided scrutiny by splitting donations just below the threshold or routing funds through proxy organizations. During the 2022 ANC leadership race, several contenders received significant support from opaque sources with no obligation to disclose under current law, since internal party contests are exempt from the Act. Moreover, the Electoral Commission of South Africa (IEC) lacks strong enforcement tools, raising concerns of regulatory capture in a highly factionalized political system.

Nigeria’s Electoral Act imposes spending limits for candidates; N5 billion for the presidency, for instance, but enforcement remains weak. The 2019 and 2023 elections were marred by widespread underreporting of campaign expenditures. Candidates routinely channel funds through traditional rulers, local business elites, and religious organizations, thereby evading formal limits. In the 2023 elections, media investigations revealed that certain gubernatorial aspirants used parallel campaign structures funded through untraceable means, further deepening the culture of clientelism and elite control. This raises significant questions about the viability of regulatory reform in low-capacity and high-patronage environments.

In the United States, the 2010 Citizens United v. FEC Supreme Court ruling opened the floodgates for unlimited independent political expenditures, leading to the rise of Super PACs and 501(c)(4) “dark money” organizations. Between 2010 and 2020, over $1 billion in dark money was spent to influence federal elections, often without revealing the identities of donors. In the 2020 U.S. presidential election alone, organizations such as Crossroads GPS and Majority Forward spent tens of millions of dollars on behalf of candidates without disclosing donor sources. This has shifted influence away from formal party structures toward unregulated, opaque networks, distorting the spirit of transparency that reforms were meant to uphold.

These examples underscore the paradox of reform, where efforts to curb corruption can inadvertently reconfigure rather than reduce elite influence. They also illustrate the urgency for adaptive regulatory frameworks, empowered oversight institutions, and public accountability mechanisms that evolve alongside political and financial innovations.

Table Comparing Unintended Consequences of Campaign Finance Reforms by Country

While each country has attempted various reform efforts to strengthen transparency and accountability in campaign finance, many of these measures have faced persistent obstacles. A deeper understanding of the specific barriers within each jurisdiction is critical to formulating more effective reforms. The following section presents a comparative summary of these barriers and proposes context-sensitive recommendations for policy improvement.

Barriers to Reform and Recommendations: A Comparative Perspective

Despite the growing recognition of campaign finance challenges across democracies, efforts to reform these systems are often met with entrenched structural, legal, and political barriers. A cross-national comparison reveals common challenges such as political resistance, weak enforcement institutions, legal loopholes, and lack of public pressure. However, the degree and character of these barriers vary based on each country’s institutional development, political maturity, and civil society engagement (Myles, 2022; Transparency International, 2023).

To provide a practical roadmap for reform, the table below summarizes key barriers and recommended solutions in each of the four countries studied; Ghana, Nigeria, South Africa, and the United States.

These insights offer a roadmap not only for understanding the challenges but also for guiding strategic interventions. For countries like Ghana and Nigeria, strengthening regulatory institutions is a foundational step, while in the U.S., addressing the influence of dark money and institutional polarization remains paramount (Center for Responsive Politics, 2022). Civil society, media, and electoral reform coalitions play an equally critical role in sustaining pressure for transparency and accountability (Myles, 2022).

CONCLUSION AND RECOMMENDATION

The comparative analysis reveals that no single model is flawless, but key lessons emerge. South Africa’s strong disclosure regime and restrictions on foreign donations offer a promising direction for Ghana and Nigeria. The U.S. experience demonstrates the risks of judicial deregulation and dark money, while both Ghana and Nigeria urgently need to bolster their enforcement capacity and legal clarity. These insights will inform the reform-oriented lessons proposed for Ghana and the region in the next section.

Lessons for Ghana and the Region

The comparative analysis in Section 4 reveals important cross-national insights that Ghana, and other emerging democracies in West Africa can draw upon to strengthen their campaign finance regimes and mitigate corruption risks. While contextual differences matter, certain principles and mechanisms have broad relevance for promoting transparency, accountability, and public trust.

Best Practices from South Africa and U.S. Transparency Mechanisms

South Africa’s Political Party Funding Act (2018) provides a useful model for real-time, public disclosure of donations. The quarterly reporting requirement ensures that citizens and civil society can scrutinize the financial underpinnings of political competition in near real time (De Visser, 2020). Ghana should consider adopting a similar mechanism with legally mandated timelines and public access.

From the United States, despite its flaws, one strength is the availability of detailed, digitized campaign finance data for public scrutiny (Briffault, 2010). The Federal Election Commission’s searchable online database promotes transparency and supports investigative journalism and academic research. Ghana’s Electoral Commission should be resourced to build a similar open data platform to host party and candidate financial reports.

Nigeria’s Ongoing Challenges: What to Avoid

Nigeria’s experience offers cautionary lessons. The country has formal disclosure and spending rules under the Electoral Act, but these are routinely flouted with little consequence due to weak enforcement and political interference in INEC’s operations (IDEA, 2022). Ghana must avoid replicating a “laws on paper” model by ensuring that reforms are accompanied by credible enforcement powers, clear sanctions, and sufficient resources for the EC.

Another Nigerian challenge is the pervasive role of illicit and foreign funding through informal networks (Ojo, 2008). Ghana’s laws banning foreign and anonymous contributions need to be coupled with stronger enforcement, including collaboration with anti-money laundering agencies and financial intelligence units.

What Ghana Can Realistically Adopt

Drawing from the comparative lessons, the following reforms are both desirable and feasible for Ghana’s political financing system:

• Quarterly public disclosure of donations, modeled on South Africa’s system.
• Real-time reporting during election periods, supported by a digital public portal modeled after the U.S. FEC system.
• Stronger independent auditing of political party finances, with annual audits conducted by an autonomous body.
• Enhanced restrictions on anonymous and foreign funding, coupled with financial surveillance mechanisms.
• Increased legal penalties and sanctions for non-compliance, backed by an empowered Electoral Commission.
• Improved collaboration between the EC, the Financial Intelligence Centre, and anti-corruption agencies, to detect illicit funding streams.

Regional Cooperation: ECOWAS and AU Guidelines

Finally, Ghana should push for regional harmonization of campaign finance standards. The ECOWAS Protocol on Democracy and Good Governance encourages member states to promote transparency in political processes (ECOWAS, 2001). The African Union Convention on Preventing and Combating Corruption (AU, 2003) also calls for effective regulation of political party funding. Ghana could lead efforts within ECOWAS to establish minimum regional norms on disclosure, enforcement, and foreign funding restrictions. Regional cooperation would help address transnational corruption risks and set higher democratic benchmarks across West Africa.

SUMMARY OF CONCLUSIONS

The intersection of campaign finance and political corruption poses one of the most persistent threats to democratic governance in both mature and emerging democracies. Ghana, like many of its African counterparts, faces a critical juncture. While competitive elections and democratic norms have taken root, the unchecked influence of money in politics undermines the principles of transparency, accountability, and electoral fairness.

This article’s comparative analysis demonstrates that robust legal frameworks, effective enforcement mechanisms, and a culture of transparency are essential in mitigating corruption risks in political financing. The experiences of South Africa and the United States show that while no system is perfect, strong disclosure requirements, independent oversight bodies, and active civil society engagement are indispensable pillars of reform. Conversely, Nigeria’s ongoing struggles highlight the dangers of weak enforcement and entrenched informal practices that circumvent the law.

For Ghana, the lessons are clear: it is no longer sufficient to rely on outdated laws and underfunded institutions to safeguard electoral integrity. The political will to strengthen disclosure laws, cap expenditures, prohibit illicit funding, and empower oversight bodies must be matched by concrete legislative and institutional reforms. Moreover, regional cooperation through ECOWAS and the African Union can help establish common standards and promote cross-country learning.

Ultimately, the fight against political corruption through improved campaign finance regulation is not merely a legal or technical exercise; it is a moral and democratic imperative. By fixing the rules of the game, Ghana can advance toward a political system where ideas, not illicit money, determine electoral outcomes; where citizens’ voices are not drowned out by special interests; and where public trust in democracy is renewed.

Sustained advocacy, broad-based civic engagement, and bold political leadership will be required to translate these lessons into lasting reform. The time for action is now.

Policy Recommendations

A robust and enforceable campaign finance regime is a cornerstone of democratic integrity and the fight against political corruption. Drawing from both domestic realities and international best practices, the following policy recommendations are proposed to help Ghana, and similarly situated African democracies, reform their campaign finance laws for improved transparency, accountability, and public trust.

Legal Reform Priorities

1. Amend the Political Parties Act (Act 574) to include:

• • Mandatory quarterly public disclosure of all donations above a threshold (e.g. GH¢5,000), with online publication accessible to the public.
  • Real-time reporting of donations and expenditures during election campaign periods, especially within 72 hours of receipt or spending.
  • Annual auditing of political party accounts by an independent, publicly accountable audit authority with oversight powers.
  • Explicit ban on anonymous and foreign donations, with penalties including fines, refund orders, and disqualification from elections.
  • Campaign expenditure caps that vary by constituency and are reviewed before each election cycle.

2. Enact a comprehensive Campaign Finance Bill, separate from the Political Parties Act, to regulate candidate expenditures, third-party funding (e.g. from interest groups), and political advertising, particularly on digital platforms.

Institutional Strengthening

1. Enhance the enforcement mandate and independence of the Electoral Commission (EC):

• • Allocate dedicated funding for a Campaign Finance Oversight Unit within the EC.
  • Grant the EC powers to investigate, audit, and prosecute non-compliance.
  • Establish an integrated reporting system linked with the Financial Intelligence Centre (FIC) and Auditor-General’s office to detect illicit flows.

2. Create a Political Finance Transparency Portal:

• • Build and maintain a publicly accessible online database where parties and candidates must upload donation and expenditure reports.
  • Include features for citizen whistleblower reporting, backed by legal protections.

Role of Civil Society, Media, and Academia

1. Expand the watchdog role of civil society organizations and the media:

• • Support non-state audit mechanisms that track campaign spending and donor influence.
  • Establish partnerships with investigative journalists and think tanks to conduct independent political finance monitoring.

2. Promote civic education on campaign finance:

• • Integrate campaign finance and anti-corruption education into civic curricula.
  • Fund public awareness campaigns before each election to educate voters on the role of money in politics.

Regional and International Cooperation

1. Leverage ECOWAS and AU frameworks:

• • Advocate for an ECOWAS protocol on campaign finance standards—with a model law for member states.
  • Engage with the African Union Advisory Board on Corruption and development partners to facilitate technical support and peer learning.

2. Collaborate with international organizations:

• • Partner with bodies like IDEA, Transparency International, and UNDP for capacity building, comparative research, and funding.

REFERENCES

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2. Ayee, J. R. A. (1997). Financing political parties in Ghana. African Journal of Political Science, 2(1), 55-73.
3. Ayee, J. R. A. (2018). Political party financing and corruption in Ghana: Mapping vulnerabilities. U4 Anti-Corruption Resource Centre.
4. Boateng, F. G. (2019). The impact of money in politics on Ghana’s democracy. Ghana Journal of Development Studies, 16(2), 66–84.
5. Boateng, J. B., & Ameyaw, A. (2021). The influence of campaign financing on election outcomes in Ghana. Journal of African Elections, 20(1), 39–61.
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9. Center for Responsive Politics. (2022). OpenSecrets.org: Tracking money in U.S. politics and its effect on elections and public policy. Retrieved from https://www.opensecrets.org
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12. International Institute for Democracy and Electoral Assistance (IDEA). (2021). Political finance database. Retrieved from https://www.idea.int/data-tools/data/political-finance-database
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14. Issacharoff, S. (2010). On political corruption. Harvard Law Review, 124(1), 118–147.
15. Johari, A. (2020). Comparative perspectives on political financing and anti-corruption measures: A study of South Africa, Ghana and Nigeria. African Journal of Law and Governance, 5(3), 89–104.
16. Lessig, L. (2011). Republic, lost: How money corrupts Congress—and a plan to stop it. Twelve.
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18. National Democratic Institute (NDI). (2019). Political party finance reform: Lessons from comparative experience. Washington, DC: NDI.
19. Nigeria Independent National Electoral Commission (INEC). (2022). Electoral Act, 2022: Provisions on political party finance. Abuja: INEC.
20. South Africa Government Gazette. (2018). Political Party Funding Act 6 of 2018. Pretoria: Government of South Africa.
21. United Nations. (2003). United Nations Convention Against Corruption. New York: United Nations.
22. United States Federal Election Commission (FEC). (2022). Federal Election Campaign Act (FECA) regulations and guidelines. Washington, DC: FEC.
23. United States Supreme Court. (2010). Citizens United v. Federal Election Commission, 558 U.S. 310 (2010).
24. Van Biezen, I., & Piccio, D. R. (2013). Shaping intra-party democracy: On the legal regulation of internal party organizations. The European Constitutional Law Review, 9(3), 594–620.

List Of the Abbreviations