I’ve reviewed The Carter Center’s pre-election observation report. Much of the media coverage to date has emphasized the negatives and under-reported the positives that were documented. For the sake of balance, here are the key positives alongside the observably glaring omissions.
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• Modernized legal framework (2022 reforms). Clear steps to improve transparency: sub-district tabulation in Regions 3, 4, and 6; immediate online publication of Statements of Poll and tabulation forms; and stronger rights for party agents to observe every stage.
• Continuous registration & public scrutiny. Registration now runs in two cycles each year, followed by claims-and-objections; the Official List of Electors (OLE) is published online and searchable, and was publicly displayed in all regions.
• Voter list facts, not rumors. The OLE stands at 757,690 (men 376,703; women 380,987). Importantly, ??? ??????? ??? ??? ??????? ???????? ?? ???? ?????????.
• Openness at close and count. Presiding officers now have explicit obligations for openness; stiffer penalties apply for failures to publish or obstruction.
• Accessibility and administration. New provisions encourage accessible polling places; election staff recruitment and materials preparation are well underway; the CEO must issue a report within 12 hours of results calculation.
• Campaign environment so far. Campaigning has been generally peaceful, and most parties signed the ERC Code of Conduct (the mission urges all parties to sign).
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• OFAC’s role vs. bank autonomy.
The report notes “over-compliance,” but omits that OFAC does not direct banks to override their own risk controls. U.S. guidance consistently stresses a risk-based approach, not blanket account closures—and decision-making ultimately rests with each financial institution’s internal policies.
• Material-support exposure (incl. non-U.S. persons).
OFAC also warns that persons—including non-U.S. persons—who materially assist, sponsor, or provide support to sanctioned persons/entities can themselves be exposed to sanctions. Any assessment of banking actions should weigh this counter-risk alongside concerns about “de-risking.”
• AML/CFT obligations & de-risking discretion.
International AML/CFT standards recognize that banks may decline or exit relationships where the money-laundering/terrorist-financing risk or reputational exposure is unacceptable. “De-risking” in this context means closing accounts of clients assessed as high-risk—a decision grounded in regulatory expectations, not political preference.
• No political direction over compliance.
Attempts by any political actors to instruct banks on account-opening/closure contradict the risk-based regime. The correct standard is independent compliance judgment by the bank’s board and compliance team, informed by sanctions and AML/CFT rules, not political pressure.
• Nomination-day assault (WIN operative).
Video purportedly shows a WIN operative assaulting a female supporter over alleged payment disputes tied to nomination-day activities.
• Alleged inducement payments (hinterland meetings).
Videos reportedly show individuals being paid to attend/support WIN events in hinterland regions—despite GECOM reminders that such acts are unlawful under electoral law.
• Vandalism of campaign materials.
Additional video materials depict destruction of the incumbent’s campaign materials by persons WIN members/associates.
• Forced entry and abuse in an Amerindian village.
Reports on record indicate WIN members entered a village event without Toshao approval and verbally abused the Toshao.
• Coordinated online harassment.
Accounts linked to WIN saturated social media with abusive content targeting opponents.
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