Getting The Full Picture On Public Officials
Getting the Full Picture onPublic OfficialsA How-To Guide forEffective Financial DisclosureIvana M. RossiLaura PopTammar Berger
Getting the Full Pictureon Public Officials
Stolen Asset Recovery (StAR) SeriesStAR—the Stolen Asset Recovery Initiative—is a partnership between the World BankGroup and the United Nations Office on Drugs and Crime (UNODC) that supportsinternational efforts to end safe havens for corrupt funds. StAR works with developingcountries and financial centers to prevent the laundering of the proceeds of corruptionand to facilitate more systematic and timely return of stolen assets.The Stolen Asset Recovery (StAR) Series supports the efforts of StAR and UNODC byproviding practitioners with knowledge and policy tools that consolidate internationalgood practice and wide-ranging practical experience on cutting edge issues related to anticorruption and asset recovery efforts. For more information, visit www.worldbank.org/star.Titles in the Stolen Asset Recovery (StAR) SeriesStolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture(2009) by Theodore S. Greenberg, Linda M. Samuel, Wingate Grant, and Larissa GrayPolitically Exposed Persons: Preventive Measures for the Banking Sector (2010) by Theodore S. Greenberg, Larissa Gray, Delphine Schantz, Carolin Gardner, and Michael LathamAsset Recovery Handbook: A Guide for Practitioners (2011) by Jean-Pierre Brun, LarissaGray, Clive Scott, and Kevin StephensonBarriers to Asset Recovery: An Analysis of the Key Barriers and Recommendations forAction (2011) by Kevin Stephenson, Larissa Gray, and Ric PowerThe Puppet Masters: How the Corrupt Use Legal Structures to Hide Stolen Assets andWhat to Do About It (2011) by Emile van der Does de Willebois, J. C. Sharman, RobertHarrison, Ji Won Park, and Emily HalterPublic Office, Private Interests: Accountability through Income and Asset Disclosure (2012)On the Take: Criminalizing Illicit Enrichment to Fight Corruption (2012) by Lindy Muzila,Michelle Morales, Marianne Mathias, and Tammar BergerLeft Out of the Bargain: Settlements in Foreign Bribery Cases and Implications for AssetRecovery (2014) by Jacinta Anyango Oduor, Francisca M. U. Fernando, Agustin Flah,Dorothee Gottwald, Jeanne M. Hauch, Marianne Mathias, Ji Won Park, and Oliver StolpePublic Wrongs, Private Actions: Civil Lawsuits to Recover Stolen Assets (2015) by JeanPierre Brun, Pascale Helene Dubois, Emile van der Does de Willebois, Jeanne Hauch,Sarah Jaïs, Yannis Mekki, Anastasia Sotiropoulou, Katherine Rose Sylvester, andMahesh UttamchandaniGetting the Full Picture on Public Officials: A How-to Guide for Effective Financial Disclosure (2017) by Ivana M. Rossi, Laura Pop, and Tammar BergerAll books in the StAR Series are available for free at https://openknowledge.worldbank .org/handle/10986/2172.
Getting the Full Pictureon Public OfficialsA How-to Guide for EffectiveFinancial DisclosureIvana M. RossiLaura PopTammar Berger
2017 International Bank for Reconstruction and Development / The World Bank1818 H Street NW, Washington, DC 20433Telephone: 202-473-1000; Internet: www.worldbank.orgSome rights reserved1 2 3 4 19 18 17 16This work is a product of the staff of The World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, itsBoard of Executive Directors, or the governments they represent. The World Bank does not guarantee theaccuracy of the data included in this work. The boundaries, colors, denominations, and other informationshown on any map in this work do not imply any judgment on the part of The World Bank concerning thelegal status of any territory or the endorsement or acceptance of such boundaries.Nothing herein shall constitute or be considered to be a limitation upon or waiver of the privileges andimmunities of The World Bank, all of which are specifically reserved.Rights and PermissionsThis work is available under the Creative Commons Attribution 3.0 IGO license (CC BY 3.0 IGO) http://creativecommons.org/licenses/by/3.0/igo. Under the Creative Commons Attribution license, you are free tocopy, distribute, transmit, and adapt this work, including for commercial purposes, under the followingconditions:Attribution—Please cite the work as follows: Rossi, Ivana M., Laura Pop, and Tammar Berger. 2017. Gettingthe Full Picture on Public Officials: A How-To Guide for Effective Financial Disclosure. Stolen Asset Recovery(StAR) Series. Washington, DC: World Bank. doi:10.1596/978-1-4648-0953-8. License: Creative CommonsAttribution CC BY 3.0 IGOTranslations—If you create a translation of this work, please add the following disclaimer along with theattribution: This translation was not created by The World Bank and should not be considered an official WorldBank translation. The World Bank shall not be liable for any content or error in this translation.Adaptations—If you create an adaptation of this work, please add the following disclaimer along with theattribution: This is an adaptation of an original work by The World Bank. Views and opinions expressed in theadaptation are the sole responsibility of the author or authors of the adaptation and are not endorsed by TheWorld Bank.Third-party content—The World Bank does not necessarily own each component of the content containedwithin the work. The World Bank therefore does not warrant that the use of any third-party-owned individual component or part contained in the work will not infringe on the rights of those third parties. Therisk of claims resulting from such infringement rests solely with you. If you wish to re-use a component ofthe work, it is your responsibility to determine whether permission is needed for that re-use and to obtainpermission from the copyright owner. Examples of components can include, but are not limited to, tables,figures, or images.All queries on rights and licenses should be addressed to World Bank Publications, The World Bank Group,1818 H Street NW, Washington, DC 20433, USA; e-mail: pubrights@worldbank.org.ISBN (paper): 978-1-4648-0953-8ISBN (electronic): 978-1-4648-0957-6DOI: 10.1596/978-1-4648-0953-8Cover photo: Car and plane: istockphoto/Mark Evans; house: istockphoto/Peter Zelei; money puzzle: istockphoto/Aslan Alphan. Further permission required for reuse.Cover design: Debra Naylor, Naylor Design, Washington, DCLibrary of Congress Cataloging-in-Publication Data has been requested.
ContentsForeword xiAcknowledgments xiiiAbout the Authors xvAbbreviations xviiGlossary xixIntroductionNotesReferences1561. Why Do Countries Embark on Financial Disclosure?Global and Regional Trends Observed in the Adoption of Disclosure SystemsWhat Are the Objectives of a Disclosure System?Illicit Wealth FocusConflict of Interest FocusLegal Foundations of Disclosure SystemsDomestic Legal FoundationsInternational Conventions and Other InstrumentsExpectations: The Nonlegal Key to Successful ObjectivesNotesReferences78910101212121415172. Who Should File a Disclosure? How Often?Who Should File a Disclosure?Targeted Categories of OfficialsPut a Name to It: Creating and Updating a List of FilersSize MattersFamily MembersHow Often Should Filers Declare?NotesReferences1919202223242628283. What to Declare?What Makes a Disclosure Form Strong or Weak?What Categories of Information Are Included in Financial Disclosure Forms?Personal Identification Information29303335v
Declaring Immovable and Movable AssetsDeclaring IncomeDeclaring SecuritiesDeclaring Business Relationships with Financial Institutions(Bank Accounts)Declaring LiabilitiesDeclaring CashDeclaring InterestsDeclaring GiftsBeneficial OwnershipNotesReferences3740414. The Submission ProcessKey Elements of the Submission ProcessThe Register of FilersCommunication with the FilerCompleting and Submitting the FormEnsuring Compliance and Quality ControlData Collection and ManagementAnalysis and ReportingElectronic versus Paper-Based SubmissionChallenges in Transitioning to Electronic-Based SubmissionNotesReference4950515255585960616365665. Verification of InformationObjectives of VerificationVerification MethodologyDetermining Which Disclosures to VerifyThe Verification ProcessWhat Happens When Irregularities Are Found?Public Access and VerificationInteragency Cooperation for Effective VerificationMapping Sources of Information for Verification (Domesticallyand Abroad)Prioritizing Sources of InformationEnsuring Effective Interagency CooperationUsing Electronic Tools in the Verification ProcessNotesReferences67687070757778806. Why and How to Provide Access to Information in DisclosuresPublic Availability of InformationApproaches to Public AvailabilityWhat Information Is Made 3858787
7.Information Contained in Public Officials’ DeclarationsSharing Information about the Disclosure SystemSharing Information with Other Agencies and InstitutionsSharing Information with Other Government AgenciesSharing Information with Foreign and Private Sector InstitutionsNotesReferences9394979799103103How Are Disclosures Used for Enforcement?Section 1: Enforcement of the Disclosure SystemConnecting the DotsWho Is Sanctioned?Cooperation and CoordinationChallenges in Imposing SanctionsSection 2: Disclosures as Part of a Bigger Puzzle: How Can DisclosureSupport the Broader Fight against Corruption and Asset Recovery?Illicit EnrichmentAsset RecoveryNotes105106106113113114Appendix A. Sample 1 and Sample 2 DataSample 1: LegislationSample 2: Practices of Disclosure oxesI.1Who Are We?I.2A Little Bit More on Our Data3.1Keeping the Truth (and Luxury New York Apartments) Hidden,while Not Lying5.1Verifying Abroad: International Cooperation and Open Sources334584Figures1.1Adoption of Financial Disclosure Laws Spiked in the Last Three Decades1.2Financial Disclosure Laws Are More Widespread in Some Regions1.3Systems Combine Elements of Both Illicit Wealth and Conflictsof Interest Objectives1.4International Anticorruption Instruments and Adoption of FinancialDisclosure Laws2.1Share of Public Officials Required to Disclose, by Category2.2Filing Population Size2.3Size of Disclosure Population2.4Share of Jurisdictions Requiring Disclosure of Family Members2.5Frequency of Disclosure Requirements3.1Disclosure Form Example, IncomeContents891114202324252730Ivii
7.17.27.3viiiIDisclosure Form Example, Unclear Request of Value of AssetsFinding the Right Balance in the Disclosure FormDepth and Breadth of Requirements on Declaring Securities(OECD High-Income Jurisdictions)Share of Jurisdictions Requiring Each Type of Information in Filer’sDisclosure FormValue of the AssetAsset AcquisitionAsset OwnershipThe Submission ProcessCountry Example: Creating and Maintaining a List of FilersPreferred Methods for Checking ComplianceCountry Example: Communication with FilersHow Officials Access the Disclosure FormMethods for Submitting Disclosure FormsMethods for Filling Out Disclosure FormsThe Path to ComplianceAchieving an Optimal Submission ProcessManual Management and Transfer of Data Still Widespread, butAutomatic Transfer Gaining GroundVerification of the Content of Financial Disclosures (by Law) IsParticularly Widespread in Latin American and the Caribbean and inEurope and Central AsiaSelecting All Disclosures for Verification Is the Least Common ApproachGlobally, Routine Checks Are More Common by Law than IrregularChecksPractitioners Use a Variety of Methods to Carry Out VerificationIn Many Systems, Verification is Complemented by Public AccessStill Room for Growth in Implementing Verification and Public AccessSources of Information for VerificationPrioritization VariablesWeighing the Arguments of Public AvailabilityDeclared Information Is Publicly Available by Law, by RegionDeclared Information Is Publicly Available by Law, by IncomeCategory of CountryApproaches for Public AccessMethods for Public Access to Disclosure InformationConditions for Sharing Declared Information with Other GovernmentInstitutionsMethods for Sharing Disclosure Information with BankingInstitutions in Relation to PEPs’ Due Diligence ProceduresSharing Disclosure Information with Foreign Public InstitutionsSample of Sanctions Applied to Public OfficialsSample Sanctions for NoncomplianceComponents of Effective 06871727678798182909292949699101102106108110
Tables3.1A.1A.2A.3A.4Categories of Information Typically Found in Disclosure FormsSample 1 Countries, by RegionSample 1 Countries, by Income CategorySample 2 Countries, by RegionSample 2 Countries, by Income Category34121122124124ContentsIix
ForewordIn a series of articles titled “Towers of Secrecy,” the New York Times in 2015 revealed theopaque way in which much high-value U.S. real estate is owned by famous and politically connected persons from around the world. The anticorruption organizationTransparency International conducted a similar exercise in the United Kingdom, showing how (among others) apartments in the exclusive London boroughs of Kensingtonand Chelsea were owned by shell companies. More recently, information leaked fromthe Bahamas and Panama law firm Mossack Fonseca revealed that many of the world’sfamous and politically powerful individuals own assets in such convoluted ways thattheir control over those assets is all but invisible to the outside world. Time then, to takea good look at some of the tools that could help shed light on the assets of the powerful.Time for a book on financial disclosure—the rules on what those in power shoulddeclare, to whom and how, about the assets they own and interests they hold.By now, 161 countries around the world have introduced financial disclosure systems.Since their initial introduction in the United States following the Watergate affair, theyhave become commonplace around the world. But, although the rules are on the books,many practitioners are still struggling with the intricacies of the rules and how to implement them in the socioeconomic, historical, and legal contexts of their own countries.Little guidance is available to assist them. This book aims to fill that void and providepractitioners with practical scenarios to consider before deciding on a particular courseof action.This book contains short chapters that elaborate each topic and provide clear guidanceon the issues that policy makers and those involved in the implementation of financialdisclosure obligations will need to take into account before making a decision. How doyou decide who should file? Everyone in the civil service? Only ministers? And whatabout their spouses, children, or extended family? And how often? Online or in hardcopy? And what exactly? Everything they own directly—or also those apartments theyown indirectly? This is the sort of practical guidance that this book aims to provide.At the World Bank, we consider information on the interests and assets of those whowield public power to be a vital element of good governance and anticorruption.Financial disclosure systems are a vital component of transparency. The only societiesthat provide the necessary checks to power that are needed to underpin growth anddevelopment are those that ask their leaders to provide complete information on whatxi
they have and where their interests lie, and that are able to hold leaders to account inthe event of deficiencies or omissions. Moreover, financial information is very usefulfor those conducting corruption and money-laundering investigations. We hope thatthe practitioners who use this book will find it to be a useful tool in guiding their decision making, and, ultimately, to help their countries build more effective systems.Gloria GrandoliniSenior Director, Finance and Markets Global PracticeWorld Bank GroupxiiIForeword
AcknowledgmentsThis Guide was written by a Stolen Asset Recovery Initiative (StAR) and World BankGroup (WBG) team comprising Ivana M. Rossi, Laura Pop, and Tammar Berger, underthe guidance of Jean Pesme (former StAR Coordinator and Practice Manager, FinancialMarket Integrity, WBG). This Guide also draws on financial disclosure systems datagathered throughout the years by a WBG team, most recently comprising CatherineGreene, Tanya Blackburn, and Gaukhar Larson, and with earlier contributions fromSimeon Djankov, Elena Gasol-Ramos, Francesco Clementucci, Larisa Smirnova, LinaSawaqed, Teymour Abdel-Aziz, Hania Dawood, and Doina Cebotari.The team gratefully acknowledges the expert guidance and advice of peer reviewersOliver Stolpe (Chief, Conference Support Section, Corruption and Economic CrimeBranch Division for Treaty Affairs, United Nations Office on Drugs and Crime[UNODC]), Silviu Popa (Deputy Director, National Integrity Agency of Romania),Marko Klasnja (Assistant Professor, School of Foreign Service and GovernmentDepartment, Georgetown University), Jana Kunikova (Senior Public Sector Specialist,Governance Global Practice, WBG), and Alexandra Habershon (Program Coordinator,Integrity Vice Presidency, WBG).Emile Van der Does de Willebois (StAR/WBG), Lisa Bostwick (StAR/WBG), NigelBartlett (StAR/WBG), Stuart Yikona (WBG), Elsa Gopala Krishnan (StAR/UNODC),and Emily Adeleke (WBG) have also generously contributed their advice and experience to this Guide. Ladan Cherenegar and Liudmila Uvarova provided support at different stages of the project.The team wishes to thank Gloria Grandolini (Senior Director, Finance and MarketsGlobal Practice, WBG), Alfonso Garcia Mora (Director, Finance and Markets GlobalPractice), and our current Practice Manager, Yira Mascaró (Financial Market Integrity/StAR, WBG) for their support in the completion of this project.Finally, the team would like to acknowledge all the hard-working practitioners in thefinancial disclosure field who have interacted and worked with the team throughout theyears and who have invaluably contributed to this Guide.xiii
About the AuthorsIvana M. Rossi is a Senior Financial Sector Specialist with the World Bank’s FinancialMarket Integrity/StAR Initiative team. She has led the work on financial disclosure bypublic officials since 2009, providing tailored technical assistance to countries, enhancing knowledge-sharing at the regional and global levels, developing research, and contributing to international policy debates on disclosure, such as the G-20 Anti-CorruptionWorking Group and Open Government Partnership. Her work promotes innovationand synergies with the anti-money-laundering and asset recovery fields. She hasauthored “Using Asset Disclosure for Identifying Politically Exposed Persons” (WorldBank) and other analytical work, such as the Financial Disclosure Law Library, articles,and blogs. Before joining the World Bank in 2006, she worked in different transparencyand public sector reform initiatives in international organizations, as well as in the civilsociety sector in Argentina.Laura Pop is a Senior Financial Sector Specialist with the World Bank’s FinancialMarket Integrity/StAR Initiative team. Since joining the World Bank in 2009, she hasdelivered advisory services on multiple areas of asset declaration (enhancing the legalframework; transitioning from paper to electronic filing; increasing the effectivenessof verification; operationalizing the concept of beneficial ownership in declarations;and establishing interagency cooperation, in particular with anti-money-laundering institutions) to more than 20 countries across all regions. She coauthored “Using AssetDisclosure for Identifying Politically Exposed Persons” (World Bank). She designedand worked on the content of the Financial Disclosure Law Library, the first collectionof laws and regulations on disclosure from 176 jurisdictions. She also works on assetrecovery, anti-money-laundering, and fina
2.1 Share of Public Officials Required to Disclose, by Category 20 2.2 Filing Population Size 23 2.3 Size of Disclosure Population 24 2.4 Share of Jurisdictions Requiring Disclosure of Family Members 25 2.5 Frequency of Disclosure Requirements 27 3.1 Disclosure Form Example, Income 30
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