How declarations are verified
Collecting declarations is only the first step. Agencies check that forms are filed and complete, then select some declarations for closer review, comparing them with earlier filings and outside records and looking for unexplained changes in wealth or conflicts of interest.
- StAR describes four general verification approaches, checking declarations for internal consistency, comparing declarations over time, cross-checking them against external sources and databases, and lifestyle checks, plus analysis of declarations for potential incompatibilities or conflicts of interest.1
- Because full verification is costly, StAR suggests limiting it to a fraction of declarations, selected at random or according to risk factors, after a basic completeness review at submission.1
- StAR found that verification of the content of declarations was specified by law in only 55 to 65 percent of the countries it reviewed.1
- Ukraine's National Agency on Corruption Prevention runs automated logical and arithmetical control on every e-declaration, assigns each a risk rating, and selects the highest-risk declarations for full verification.2
- Argentina's Oficina Anticorrupción cross-checks declarations of executive branch officials against prior declarations and other public databases, assesses whether asset growth is reasonable given declared income, and can send requests for asset clarification.3
- StAR favours administrative sanctions, such as fines, suspension or barring from office, where criminal sanctions are unlikely to be enforced, and says sanctions should be proportionate and enforceable.1
Sources
- Stolen Asset Recovery Initiative (World Bank and UNODC), Public Office, Private Interests: Accountability through Income and Asset Disclosure (28 March 2012)
- National Agency on Corruption Prevention, Four years of NACP 2.0: restoration and simplification of the declaration filing process and increase of efficiency of inspections
- Oficina Anticorrupción, Cómo se controlan las Declaraciones Juradas