JUNE 2023 Asset and Interest Disclosure A Technical Guide to an Effective Form Laura Pop Dmytro Kotlyar Ivana Rossi Asset and Interest Disclosure A Technical Guide to an Effective Form Laura Pop Dmytro Kotlyar Ivana Rossi Acknowledgments © 2023 International Bank for Reconstruction and Development / The World Bank The authors would like to thank Emile van der Does de Willebois (Stolen Asset Recovery Initiative Coordinator), 1818 H Street NW, Washington, DC 20433 who supported this technical guide from the conceptual stage through research and drafting. Telephone: 202-473-1000 Internet: star.worldbank.org The authors benefited from the expert advice and guidance provided during the peer review process chaired Email: starinitiative@worldbank.org by Cedric Mousset (Acting Practice Manager and Lead Financial Sector Specialist, EFNFS). The peer reviewers Twitter: @returningassets were Edouard Al-Dahdah (Lead Country Economist and EFI Program Leader, EAWDR); David Bernstein (Lead Some rights reserved. Public Sector Specialist, EMNGU); Marlon Rolston Rawlins (Financial Sector Specialist, EAEF1); Silviu Popa (Secretary General, National Integrity Agency, Romania) and Guillaume Valette Valla (Deputy Secretary StAR — the Stolen Asset Recovery Initiative — is a partnership between the World Bank Group and the United General, Court of Accounts, France). Nations Office on Drugs and Crime (UNODC) that supports international efforts to end safe havens for corrupt funds. StAR works with developing countries and financial centers to prevent the laundering of the proceeds We would like to thank Catherine Greene (Consultant, StAR) for her contributions to the early draft of the guide of corruption and to facilitate more systematic and timely return of stolen assets. and Jane Ley (Consultant, StAR) for valuable comments on the draft guide before finalization. This work is a product of the staff of the World Bank with external contributions. The findings, interpretation and conclusions expressed in this work are those of the authors and do not necessarily reflect the views of the World Bank, its Board of Executive Directors, or the governments, they represent, the United Nations, or its Member States, the IMF, its Executive Board, or IMF management. The World Bank and the United Nations do not guarantee the accuracy of the data included in this work. 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Cover illustration by Lindsay Jordan Kretchun. Design by Obnova. iv Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form v About the Authors Contents Laura Pop is a Senior Financial Sector Specialist with the World Bank Group Financial Stability and Integrity and a 1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 member of the Stolen Asset Recovery Initiative (StAR) team. She has led advisory programs on asset and interest 2. Key recommendations for designing the disclosure form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 declaration systems, asset recovery, anti-money laundering and integrity solutions at the sectoral level across multiple regions. She also regularly contributes to the World Bank’s development policy operations. Laura co- 3. Focus of the disclosure form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 authored several StAR and World Bank publications on asset declarations: “Automated Risk-Analysis of Asset and 4. Organization of the form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Interest Declarations of Public Officials”, “Getting the Full Picture on Public Officials: A How to Guide for Effective Financial Disclosure”, “E-filing asset declarations: Benefits and Challenges”, “Using Asset Disclosure for Identifying 5. The menu for the form: detailed discussion of sections and their fields . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Politically Exposed Persons” and the chapter on asset and interest declarations in “Enhancing Government Effectiveness and Transparency: The Fight Against Corruption”. She holds a BA from Princeton University Standard blocks of fields . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 and MA from Harvard University. Sections of the form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Dmytro Kotlyar is a consultant with the World Bank/StAR since 2015. He focuses on asset declarations, conflict Section 1. Types of declarations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 of interest, beneficial ownership, criminalization of corruption, e-governance and other related issues. He has more Section 2. Personal Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 than 14 years of experience working on anti-corruption and rule of law issues. He helped design and implement the electronic asset disclosure system in Ukraine and has advised other governments on anti-corruption reforms. Section 3. Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Dmytro co-authored several StAR and World Bank publications on asset declarations. Dmytro has consulted on Section 4. Income, gifts, and other incoming financial flows . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 anti-corruption and good governance issues for other organizations and technical assistance projects, including OECD, Council of Europe, UNODC, EU, USAID. Working for the OECD Anticorruption Network for Eastern Europe and Section 5. Financial liabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 Central Asia, Dmytro led peer reviews of several countries in the region. Before that, he worked as a Deputy Minister Section 6. Expenditures and other transactions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 of Justice and in the civil society sector of Ukraine. He holds a BA and MA in Law from the National University of Kyiv Mohyla Academy in Ukraine. Section 7. Activities outside of public service and other interests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 Ivana M. Rossi worked at the World Bank Group and the Stolen Asset Recovery Initiative (StAR) for over a decade, Appendix. Previous publications on asset and interest disclosure systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 leading engagements in anti-corruption, illicit financial flows, asset recovery, and anti-money laundering. She led the World Bank’s research and technical assistance program on financial disclosure by public officials, providing tailored technical support and training to over 30 countries, and frequently contributed to international conferences and policy dialogue in this area. Ivana authored the World Bank publications “Getting the full picture on public officials: a how-to Guide for effective financial disclosure” (2017) and “Using Asset Disclosure for Identifying Politically Exposed Persons” (2011), as well as several articles on the topic. She also worked with civil society and other international organizations on transparency and public sector reform initiatives. Ivana joined the International Monetary Fund (IMF) Legal Department in late 2018 and continues to focus her work on governance and anti-corruption. vi Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 1 Figure Table 24. Types of money owed to the declarant or family member, legal claims . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 Figure 1. Elements of the asset and interest disclosure system . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Table 24. Loans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 Figure 2. Sections of the form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Table 26. Rights to claim debt or assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 Figure 3. Types of declarations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Table 27. Insurance contracts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 Figure 4. Key issues in disclosing assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Table 28. Types of income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 Figure 5. Types of unfinished construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Table 29. Income recipient, amount, and source . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 Table 30. Type of gift and recipient . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 Boxes Table 31. Cash gifts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 Box 1. Requirements from the Technical Guide to the United Nations Convention against Corruption . . . . . . . . . . . 9 Table 32. Noncash gifts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57 Box 2. Benefits of an electronic disclosure form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Table 33. Financial liabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 Table 34. Life insurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 Tables Table 35. Financial obligations in which the declarant or family member is a guarantor . . . . . . . . . . . . . . . . . . . . . . 60 Table 1. Reporting periods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Table 36. Expenses and other transactions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 Table 2. Block of fields “ID of Individual” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Table 37. Concurrent employment or activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 Table 3. Block of fields “ID of Legal Entity” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Table 38. Previous employment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 Table 4. Block of fields “Type of Ownership” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Table 39. Rights of representation (agency) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 Table 5. Block of fields “Address” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Table 40. Government contracts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 Table 6. Types of declarations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Table 7. Personal and contact information of the declarant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Table 8. Current position of the declarant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Table 9. Information on family members . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Table 10. Land . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Table 11. Buildings, apartments, and other real estate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Table 12. Unfinished construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Table 13. Vehicles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Table 14. Other movable assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Table 15. Stocks and other securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Table 16. Ownership interests (other than stocks) in commercial entities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 Table 17. Beneficial ownership or control in legal entities, trusts, and similar legal arrangements . . . . . . . . . . . . . . 42 Table 18. Intangible assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Table 19. Accounts in banks and other financial institutions, safe-deposit boxes . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 Table 20. Types of monetary assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 Table 21. Monetary assets except precious metals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 Table 22. Precious metals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 Table 23. Virtual assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 2 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 3 1. Introduction organizations and civil society organizations can use example, when the proposed form mentions drop-down this guide as a benchmark to assess the relevance and lists, the options in a paper form can be presented effectiveness of national asset and interest declaration in a note as a list relevant to the specific field. forms and to promote their reform. This guide is intended to provide specific and practical The disclosure of assets and interests by public officials sents the main and the most important input for the Figure 1. Elements of the asset and interest guidance on achieving the right balance between the is a well-established tool for preventing corruption and disclosure system. The form also defines the role that    disclosure system type and amount of information required in the form to helping to strengthen integrity in public administration. declarations can play in the anti-corruption value chain, achieve the objectives of the disclosure system, and the Countries use this tool to identify unexplained wealth, which incorporates all the legal provisions, processes, effort expended by a public official to provide this infor- to prevent conflicts of interest, and to promote accoun­ and policies that are in place to prevent, detect, investi- mation. The guide reflects over 10 years of research and tability in public officials. According to World Bank gate, prosecute, and sanction corruption-related offenses. Disclosure technical assistance. The suggested fields of informa- research, over 160 countries around the world have form tion are based on the analysis of the legal framework introduced financial disclosure systems.1 The declara- The blank asset and interest disclosure form filled in Sanctions of more than 150 jurisdictions, combined with the tions of assets and interests are also a part of the global by public officials is a simple way of getting a quick experience gained from working directly with countries normative framework for anti-corruption.2 and accurate picture of the financial disclosure regime throughout the different stages of reforming their disclo- of a given country. A simple look at the design of the Declarant sure systems. Additionally, the recommendations reflect Institutions Asset and interest declarations play an important role in form, how the fields are structured, and the type and population the changing nature of corruption typologies and the di- detecting and investigating illicit enrichment or unjustified scope of information requested provides a sense of verse uses that financial disclosure can have. Therefore, assets of public officials, investigating corruption crimes, the objectives of the system, the ease with which the the guide also discusses fields that most forms current- and asset recovery. Investigators and asset recovery information in the disclosure form can be analyzed, and ly lack but that are becoming increasingly necessary. practitioners can use information from asset and interest the comprehensiveness of the system’s requirements. Submission Publication declarations to identify and track proceeds from corrup- method This guide builds on the previous work of the World tion offenses or prove unjustified wealth variations. Is having a good form enough? Certainly not, but it is Bank and StAR on the asset and interest disclosure a necessary precondition for an effective, useful asset of public officials that can be found in sources listed The blank asset and interest disclosure form  and interest disclosure system. As such, this guide Access, Verification sharing in the appendix. is a simple way of getting a quick and accurate focuses on key considerations for structuring the form picture of a country’s financial disclosure regime. and for making its content comprehensive. Finally, it is important to note that this guide does not cov- Asset and interest disclosure is a mechanism according er all possible property relationships and situations that This guide is intended for several stakeholders. Policy to which public officials must submit information about The guide assumes that the country has a functioning may exist in a country’s specific context. The guide is not makers and asset declaration practitioners can use it their and their family members’ income, assets, liabili­ties, asset and interest declaration system, is contemplating intended to cover all possibilities or to explain all possible while creating a new disclosure form or redesigning an expenditures, and other interests.3 From a technical point establishing one, or is in the process of reforming it. The scenarios for a country and its declarants. The form and existing one to make it more robust. The guide can also of view, the system has many elements, including the guide can be used at any stage of the disclosure form the supporting explanatory materials (official guidelines, be useful for drafters of legislation to ensure that the dis­closure form, the scope of declarants (the filing po­ development — for example, when policy makers are recommendations, clarifications, and so on) should, how- law covers all important categories of information that pu­lation), methods of submission (paper or electro­ nic), considering introducing an asset and interest disclosure ever, make clear to the declarant how to reflect the most should be disclosed and provides sufficient flexibility procedures for submitting the form, validation and system and want to understand what information the typical situations and relationships when filling out the for preparing and adjusting the form’s template if verification of the forms, publication of the information disclosure form should reasonably include, when form. The form must also be broad enough to allow the necessary. In addition, the guide can be used by anti- from the form, establishing an institutional mechanism the system is upgraded (for example, when the country declarant to address all possible property scenarios with corruption agencies and other institutions in charge to deal with the disclosure system, and other compo­ transitions from a paper form to a digital one), or when the help of the official guidelines or professional advice if of the asset and interest disclosure system. It includes nents (figure 1). This technical guide focuses only on the form is being improved incrementally (for example, needed. Depending on the country’s context, certain sec- many technical recommendations that can be imple­ the disclosure, or declaration, form itself, not on the by updating its content to add new types of assets tions of the form may require additional details to cover men­ ted by such institutions when developing or up- other elements of a fully operating system. or interests and to close loopholes). specific property relationships (for example, when trusts grading an electronic form and, to a certain extent, the What data are requested on the disclosure form repre­ are widely used in the country to structure a declarant’s content requirements of a paper form. International The proposed sections of the form that are described assets), or the sections may omit some details if the in this guide are built on the assumption that the dis- relevant situations are rare and can be reflected in the 1 For an overview and analysis of national systems and global trends, see Ivana M. Rossi, Laura Pop, and Tammar Berger, Getting the Full Picture closure system uses electronic filing, meaning that the comment fields or clarified during the follow-up verifica- on Public Officials: A How-To Guide for Effective Financial Disclosure, Stolen Asset Recovery (StAR) Series (Washington, DC: World Bank, 2017), https://star.worldbank.org/sites/star/files/getting-the-full-picture-on-public-officials-how-to-guide.pdf. The analysis presented in chapter 3: declarant must fill in and submit the form online. An tion of the declaration. In addition, certain assets may be “What to Declare?” in that publication (see page 31) is updated by much of the information in this guide. electronic form provides many benefits and opportuni- qualified differently depending on the country’s law and 2 Article 8.5 of the United Nations Convention against Corruption calls on its State Parties to establish measures and systems requiring public officials to ties for a more effective disclosure system.4 However, practice (for example, stocks in companies may or may make declarations to appropriate authorities regarding, inter alia, their outside activities, employment, investments, assets, and substantial gifts or bene­ most of the guide’s content can also be used for devel- not be treated as securities, and deposit certificates may fits from which a conflict of interest may result with respect to their functions as public officials. The Convention (art. 52.5) also requires State Parties to consider establishing effective financial disclosure systems for appropriate public officials and to provide for appropriate sanctions for noncompliance, oping or upgrading paper-based declaration forms. For be treated as securities or bank accounts). and to consider taking such measures as may be necessary to permit its competent authorities to share that information with the competent authori- ties in other State Parties when necessary to investigate, claim, and recover proceeds of offenses established in accordance with this Convention. 4 Thebenefits of e-filing are outlined in Dmytro Kotlyar and Laura Pop, E-filing Asset Declarations: Benefits and Challenges, Stolen Asset Recovery 3 Also referred to as financial disclosure, asset disclosure, asset and income declarations, or wealth reporting. (StAR) Series (Washington, DC: World Bank, 2019), https://star.worldbank.org/publications/e-filing-asset-declarations-benefits-and-challenges 4 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 5 2. Key recommendations for to provide it; that the process is not cumbersome and that it facilitates accurate submission, minimizing standards. Information that neither promotes the accountability of public officials nor facilitates the designing the disclosure form inadvertent mistakes; and that the verification agency enforcement of anti-corruption requirements should receives a form that is accurate and complete with be treated as excessive and excluded from the form. verifiable data. If a form is not user-friendly, the quality For example, the form may ask for information about of the data collected is compromised and its usability a counterparty to the transaction, but it does not need is reduced. As a result, the asset and interest to require extensive details about such a person. disclosure agency would waste additional resources It can ask for only what is necessary to identify the A weak form asks for either too much expenditures and incoming financial flows to help to follow up and clarify filing errors, thus taking away person through other government data sources or too little information and misses determine whether assets are commensurate with time from pursuing an in-depth verification of the and keep certain information for future clarification the objectives of the system in its design. income. declaration. during the verification process if it is started. The level of detail required should also consider whether The declaration form is the initial point of contact Relevance applies not only to the general focus of the Comprehensive but balanced. A disclosure form the declarant has relevant information at hand or for public officials who are required to complete it form but also to the specific data requested about will be strong as long as it provides enough will need to take steps to obtain it, and if so, how (called “declarants” or “filers” in this guide). It is a critical a type of asset or interests. If specific details or an pertinent data for the effective functioning of the cumbersome these steps are. point in setting the tone for their interaction with and information field do not promote transparency or system without asking for excessive or confusing their overall perception of the system. The information future verification, the data should not be requested. information. For instance, the form should not be This guide does not suggest that all information in submitted by the officials through the form is the overly burdensome for filers by requiring information the proposed form should be made public. This is a cornerstone for all subsequent processes in the One of the approaches to designing the form with limited or no benefit to the objectives of the separate topic, which is outside this guide’s scope. system because these processes (verifi­ cation, sharing is to reverse engineer any known breaches of the disclosure system. Finding the right balance, The choice to make the information public should be information with other agencies, detection of anoma­ law to see how the form could be made more however, is not easy. The form developers may governed by the principle of finding the right balance lies, and so on) rely on data being submitted in the first useful for detecting, proving, and preventing future want to extend the form’s reach to capture as much between privacy and personal security, and public place. A weak form can therefore compromise the similar violations. The goal of prevention can inform information as possible, hoping that it will be useful interest in scrutinizing information about the assets asset and interest disclosure system overall. the form’s design because the requirement to for future verification. This natural inclination should and interests of public officials. See the reference disclose certain information may help guard against be balanced by the proportionality requirement, materials in the appendix for additional discussion To develop a strong disclosure form, we recom­ mend offenses, especially if the information is then made which is described in the next paragraph. on the topic. following these principles (see also box 1): public. For example, requiring information about all contracts that an official, his or her family members, First, an asset and interest disclosure form collects Why the disclosure form is important Key takeaways or affiliated legal entities have concluded with personal data and should follow the principles government agencies may prevent abuse of office in that protect data, including minimization, or y Serves as entry point to the asset and interest The asset and interest disclosure form should be public procurement or in licensing regulated entities. “proportionality.” That is, personal data should be disclosure system y Relevant adequate, relevant, and limited to what is necessary y Facilitates or complicates the submission y Focused on the user experience By tweaking the scope of information required, the in relation to the purposes for which they are process y Comprehensive but balanced and proportionate form’s designers may achieve both purposes of processed.5 Second, requiring information that is y Weakens or strengthens the disclosure system in collecting personal data a disclosure system. For example, if the form asks excessive and unnecessary can be counterproductive, y Affects credibility of the system y Tailored to the country context and risk-based for information about assets acquired, it may help to encouraging declarants to withhold information or y A living document and easily adjustable establish signs of unjustified enrichment. If the same misrepresent it. Third, requiring excessive information Tailored to country context. For the form to be y Supported by guidelines form also asks for information about parties to the can result in backlash from policy makers, who may effective, it needs to be tailored to a country’s risks transaction that led to acquiring the said assets, it be inclined to use the disproportionate collection of and context. The comprehensive form proposed in Relevant information. When designing the form, may also help detect a potential or an existing data as an excuse to roll back the disclosure system this guide is not intended to suggest a one-size-fits-all it is important to keep in mind the objectives of the conflict of interest. or to resist strengthening it further. solution but instead offers guidance on the different country’s asset and interest disclosure system. types of data that a comprehensive and balanced The form should ask for information that will User-friendly. The disclosure form can be seen as a To achieve the balance, the form designers should form should consider. The form’s design is one aspect contribute to achieving these objectives. It should be technical tool for collecting data to verify compliance ensure that each data point in the form is consistent of the asset and interest disclosure system for which sufficiently broad to capture information that may be with anti-corruption requirements. Anti-corruption with the principles mentioned above and that it is a risk-based approach should be used. The form used later to enforce anti-corruption requirements practitioners and policy makers who design the form either important for transparency and accountability should not only reflect the disclosure system’s and restrictions. For example, if a country’s laws tend to pursue the objectives of the asset and interest (if relevant information is made public) or useful objective to be relevant (as mentioned previously) restrict outside positions of public officials when in disclosure system first and may overlook considerations for the verification and subsequent detection of but should also be based on national legal practices office, the disclosure form should capture information such as convenience for the filer and ease of working possible violations of anti-corruption and integrity (for example, how ownership structures are about outside activities and positions held. If the with the form. However, a clear and user-friendly form system’s aim is to detect unjustified assets of is beneficial for all sides. It ensures that the declarant 5 See, for example, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, article 5, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC officials, the form should capture information about understands what information is necessary and how (General Data Protection Regulation),  https://eur-lex.europa.eu/eli/reg/2016/679/oj 6 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 7 regulated), on family relationships and traditions to uncover a certain type of asset or interest). Box 1. Requirements from the Technical Guide to the United Nations Convention against Corruption (for example, how to regulate the scope of disclosure Third, it is useful to involve stakeholders from regarding family members and others close to the outside the public sector, such as nongovernment declarant), and on an analysis of corruption and asset organizations, investigative journalists and others The requirements on the disclosure and registration of assets and interests should ensure that conceal­ ment patterns. At the same time, developers in the media, anti-money-laundering compliance of the form should remember that globalization has officers, and other practitioners. Their feedback and y Disclosure covers all substantial types of incomes and assets of officials (all or from a certain level expanded corruption, beyond national borders, advice can be valuable input into how to make a of appointment or sector and/or their relatives). including with regards to the acquisition and robust form that achieves the system’s objectives y Disclosure forms allow for year-on-year comparisons of officials’ financial position. placement of illegal proceeds, so the form should in a balanced way. Practices and techniques used y Disclosure procedures preclude possibilities to conceal officials’ assets through other means or, be broad enough to capture such situations. in the private sector (for example, risk-based to the extent possible, held by those against whom a State Party may have no access compliance systems and information technology (such as overseas or held by a nonresident). Living document. The form should be considered solutions for data collection and processing) y A reliable system for income and asset control exists for all physical and legal persons — such as a work in progress, open to regular re-assessment can also be an important source for the form’s within tax administration — to access in relation to persons or legal entities associated with public and fine-tuning. This need for flexibility is why the continuous improvement. officials. authors of this guide do not consider the fields y Officials have a strong duty to substantiate/prove the sources of their income. and the types of information in the proposed form Easily adjustable. The form should not be rigid. y To the extent possible, officials are precluded from declaring nonexistent assets, to be set in stone. The form is a living document For this reason, we do not recommend attaching which can later be used as justification for otherwise unexplained wealth. that should be amended and strengthened based the form’s template to the primary law. The law can on a country’s needs and lessons learned from outline categories of information to be included in Source: United Nations, Technical Guide to the United Nations Convention against Corruption (New York: experience. The agency or personnel responsible the form and define key concepts and requirements, United Nations, 2009), р. 25–26, https://www.unodc.org/unodc/en/treaties/CAC/technical-guide.html for the asset and interest disclosure system should but the actual template for the form with its sections, use various sources to improve the form. One of fields, and requirements for data entries is better them is the previous verification results showing regulated through bylaws. They are easier to either typical mistakes that can be addressed by amend, thereby making the form more flexible and tweaking the form or the patterns of hiding assets effective. However, the form must be standardized or misrepresenting data made possible by the gaps in some way. Otherwise, it could be subject to legal in the form. challenges, and legal uncertainty could lead to abuse. Formalizing the form would also ensure that It is important to include feedback loops in developing declarants would (a) be aware of what information and updating the form, particularly by engaging must be provided to complete the form and (b) stakeholders with different perspectives. First, the be notified of any changes in the form before they form developers (for example, the anti-corruption become effective. agency in charge of the asset and interest disclosure system) may survey the declarants or gain insight Supported by guidelines. Even the best form cannot into the form via their queries and clarification explain or capture all real-life situations. It must requests. Declarants can pinpoint the form’s therefore be supported by extensive guidelines in weaknesses or show where it can be improved various formats (hints built into the form, tutorials, in terms of content or the ease of submitting data. FAQs, and so on) and training activities (online Second, the form developers may also collect courses through open platforms or platforms for opinions and recommendations from the law public officials, in-person trainings, or both). The enforcement practitioners and other officials who agency or personnel in charge of the asset and use the disclosure form for verification or other interest disclosure system should provide such enforcement purposes. These practitioners can guidelines and update them regularly, including reveal remaining loopholes in the form or help to test ensuring that feedback and queries from declarants hypotheses proposed by anti-corruption specialists are taken into consideration. (for example, what information should be collected 8 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 9 3. Focus of the disclosure form The categories of information in the form should align such as positions held outside the public sector or with the disclosure system’s objectives. As explained post-tenure activities. The categories of information previously, these objectives can be the detection represent the skeleton of the declaration. To gather of illicit enrichment, the prevention of conflicts of the necessary information about these categories, interest, or both. Detecting illicit enrichment means the form should consist of specific questions uncovering unjustified wealth based on the analysis requiring public officials to disclose precise details. of incoming and outgoing cash and asset flows. Such details should be sufficient for subsequent Preventing conflicts of interest is a broad category identification purposes, such as the source of income that includes not only potential, actual, or apparent (company or individual), and for verification purposes. conflicts concerning specific decision-making but also banning/restricting certain situations that may result Not all the elements of the form will present the same in a conflict of interest, such as restrictions on holding implementation challenges, and these challenges will concurrent offices or engaging in certain activities also vary according to the jurisdiction. If the country while in office, on receiving gifts, on holding financial has a national ID system, then the public official’s and corporate interests, or on post-employment ID number will likely be enough to certify his or her activities. identity. However, if the jurisdiction does not have a national ID system, then the matter can be trickier, and The proposed form targets both objectives the form will need to require the disclosure of several (the detection of illicit enrichment and the identifiers (for example, ID number, tax, and/or Social prevention and detection of conflict of interest), Security number). as countries need to respond to both challenges. A comprehensive asset and interest disclosure Applying our experience with systems that have form that is intended to detect unjustified wealth different objectives, we have drafted this form to and conflicts of interests should contain personal reflect the main trends identified across jurisdictions identification information; data on sources and and have proposed solutions to the salient gaps or amounts of income, including gifts; data on assets, deficiencies found in many disclosure systems. The expenditures, and liabilities; positions held in, form we propose here targets both objectives (to and activities performed for, entities outside the detect illicit enrichment and to prevent conflicts of government; and other activities that generate interest), as many countries need to respond to the interests. Most of the information should ideally be challenges arising from unjustified variations in wealth required for the official and close family members, and conflicts of interest. such as the spouse, children, and other dependents or cohabitants. Information should reflect interests Most disclosure systems require filers to provide and activities domestically and abroad. Additionally, information on movable and nonmovable assets, the form should require disclosure of assets that income, stocks and securities, and/or relationships the declarant and close family members directly with financial institutions. Some systems focus on or indirectly own or co-own, use, or of which collecting data about other interests of the officials, they are the beneficial owners. 10 Asset and Interest Disclosure: A Technical Guide to an Effective Form 4. Organization of the form submitted until the declarant provides such an acknowledgment. For systems in which the declarant has to provide data about an asset held by a family member, the form can include an option for the declarant to The form consists of sections and fields (sometimes indicate the reason for not providing the required further divided into subfields). The form can combine information. This would mean that the field applies An electronic disclosure form can be organized in or are available from other sources. First, the form the fields into blocks — for example, information about to the item, but it concerns an asset owned or a way that is more efficient and user-friendly than could pre-populate fields from the previous ownership of the asset declared. (See the proposed controlled by a family member who refused to a paper form (box 2). For example, the form could declaration submitted by the declarant. It would allow blocks of fields in chapter 5, “The menu for the form”). provide the relevant information and that it is prompt answers in a specific field only if declarants the declarant to check the data and confirm it or make unknown to the declarant. At the same time, the indicate that the situation applies to them (for example, changes, removing items that are no longer relevant, The form should indicate which sections and fields are form or its supporting regulations should clearly if declarants checked the box indicating that they for example, because they were sold; adding new mandatory for submission; that is, the form may not require the declarant to provide all information he changed their name in the previous year, then the form items, and changing data values if needed. In this be submitted unless both are filled in. Sections about or she knows about such an item. will prompt them to provide their previous name). An way, only the very first disclosure form filed by the the personal details of declarants and their family electronic form should also have drop-down menus declarant will, in most cases, require a substantial members are usually the only ones that are mandatory. Using these options does not absolve the declarant (lists of options from which declarants may choose) investment of effort, and all subsequent declarations Some minimum information should be required for of liability for providing false information. For in as many fields as possible to provide declarants with will build on it. other sections if the declarant has something to declare. example, marking the field indicating an asset’s value the most typical replies, thereby minimizing errors and Whether the field is mandatory or not should depend as “unknown” when the declarant has documents the need to manually input information. For example, Second, an electronic system can retrieve and upload on the minimum amount of information required for certifying this value would mean that the declarant the form could have drop-down menus for entering to the form data from external sources, such as other verification. For example, if the information provided provided false information, which should be a information about types of assets (such as types government registries and databases. The declarant is not enough to identify an asset, then another field punishable offense. For example, the declarant of real estate) or standard data values (such as lists could then check the form and confirm the accuracy or fields should be mandatory. would be liable for reporting false information about of countries, cities, streets, the makes and models of the data without having to enter it manually. These assets belonging to a family member if the declarant of cars, currencies, and so on). data could be from the tax administration, the land For electronic forms, it is helpful to establish the rules fails to report a vacation home owned by the family registry or cadastre, the registry of vehicles, a company about what information can be included in a given member in which the declarant has stayed. An electronic form can also allow for the use of registry, the government payroll system, and other field (for example, what letters, digits, or symbols are previous data, which were submitted by the declarant government systems. allowed) so that the information can be automatically Each section of the form should cover the specific validated. reporting period — that is, the period for which the Box 2. Benefits of an electronic disclosure form declarant must report all relevant items (for example, The best way to structure the sections in which a income received during the previous calendar year). declarant may not have anything to report is to ask The form should specify this period for each type of An electronic disclosure form has the following benefits: explicitly at the beginning of each section whether declaration to avoid confusion and mistakes. Reporting y Allows covering a broader scope of declarants the person has anything to declare, the options periods can differ with the type of declaration. For y Simplifies the submission process by making the form more user-friendly through tutorials, hints, being to answer “yes” or “no.” In this way, declarants example, they can be annual or biannual, or they can drop-down menus, pre-populated data, and so forth cannot claim later that they forgot to fill in a particular cover the period either before a public official leaves y Reduces the number of mistakes in the form section. If the declarant answered “yes,” the form office or post-employment. Reporting periods can also y Facilitates further checks of submission and verification of declarations should prompt the declarant to enter information differ by country context (for example, the reporting y Allows electronic communication with the declarant about at least one item in the section (for example, year may not coincide with the calendar year). No y Removes the need of paper forms that must be distributed, collected, stored, preserved, and processed an item of real estate held under any right). matter how the reporting period is defined, it is essential y Can integrate with external data sources that there are no gaps between different declarations y Provides different access regimes and better data management The form should also provide options when the submitted. For example, the declarant who leaves y Allows an automatic publication declarant cannot fill in fields for various reasons. public office and has to submit an exit declaration may y Provides machine-readable (re-usable) data For most systems, the usual options would be not yet have submitted a declaration for the previous year; in this case, the exit declaration should cover the Note: For more details, see Dmytro Kotlyar and Laura Pop, “E-filing Asset Declarations:  “Not applicable”: Used when the field does not whole period, starting with the end date of the reporting Benefits and Challenges,” (StAR series, World Bank, Washington, DC, 2019), apply to the item being declared. period of the last declaration filed in the system. https://star.worldbank.org/publications/e-filing-asset-declarations-benefits-and-challenges  “Unknown”: Used when the field applies to the item, but the declarant does not have the necessary Table 1 shows a possible approach to defining information and cannot reasonably establish it. reporting periods. An important formal element of the form is the explicitly acknowledge that he or she is aware of the  “Family member did not provide information”: disclaimer that the declarant must sign when liability for providing false or incomplete information starting to fill out the form, after filling it out but and confirm the accuracy of the submitted data before submitting it, or both. The declarant should as a sworn statement. The form may not be 12 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 13 Table 1. Reporting periods Section of the form Reporting period Section 3. Assets Declare assets as of the last day of the reporting period (for example, for an annual declaration, as of December 31 of the year before submission of the declaration). Alternative option: “as of the date of declaration submission.” Section 4. Income, gifts, and other incoming Declare income and other incoming financial flows received financial flows during the previous calendar year (that is, from January 1 to December 31) or during another reporting period covered by the declaration. If the reporting is linked to a financial year that does not coincide with the calendar year, the period covered in this section could be the respective financial year. Section 5. Financial liabilities Declare the financial liabilities situation as of the last day of the reporting period (for example, for an annual declaration, as of December 31 of the year before submission of the declaration). Alternative option: “as of the date of declaration submission.” Section 6. Expenditures and other transactions Declare expenditures and other transactions made during the previous calendar year or during another reporting period covered by the declaration. Alternative option: “during the previous financial year.” Section 7. Activities outside of public service and Declare positions held or activities conducted as of the last other interests day of the reporting period (for example, for an annual declaration, as of December 31 of the year before submission of the declaration). Alternative option: “as of the date of declaration submission.” * If the individual is a foreign national, the name should be entered both in the national language of the country in which the declaration form is submitted and, in a separate field, in English (if English is not the main language of the form). ** In different national contexts, people may have numerous names, such as family and tribal names, so the form should ask for all the names that will be relevant and useful for identifying a person in the national context. 14 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 15 5. The menu for the form: Table 2. (continued) Fields Subfields Characteristics/Notes to the field detailed discussion of sections Primary residence (i.e., where the person actually resides) *** Number Street Empty field to enter data Empty field to enter data and their fields Apartment Empty field to enter data City A drop-down list of cities (if in the same country in which the declarant is an official) State/province A drop-down list of states/provinces (if in the same country in which the declarant is an official) Standard blocks of fields ZIP code Empty field to enter data Country A drop-down list of countries Recurring blocks of fields are used throughout the On an electronic form, the declarant should be Address where the person Number Empty field to enter data declaration form. For example, the declarant has to required to enter data on a specific individual or legal is registered name an individual or legal entity that is the source entity only once. Family members would be entered Street Empty field to enter data (if different from the primary of income, the owner of assets, or the company in once at the start of the form, and all other individuals residence address) *** Apartment Empty field to enter data which the declarant or a family member owns shares. or legal entities would be entered once — wherever City A drop-down list of cities The way in which the form asks for descriptive they are first mentioned. The system should be (if in the same country in which the declarant is information required for these natural persons or programmed to remember each new entry, an official) legal entities should be consistent throughout. These and if the declarant needs to mention a person State/province A drop-down list of states/provinces blocks of fields are important in identifying relevant or an entity again, the system should offer the (if in the same country in which the declarant is persons/entities and in making the information option to the declarant to choose the person/entity an official) useful for verification. To simplify the presentation from a drop-down list. In the same way, after ZIP code Empty field to enter data of the sections and to avoid duplication, tables 2, 3, the declarant enters the identification details Country A drop-down list of countries 4, and 5 show the standard blocks of fields referred about all persons who qualify as family members, to in this guide when applicable. The blocks include the form should include these family members ***  If the address is in a country in which the main language is not English, it should still be provided in English. the minimum information necessary for all sections; in a drop-down list from which the declarant can some sections may require additional details relevant choose whenever there is a need to mention any to the disclosure of the specific asset or interest. family member again. Table 3. Block of fields “ID of Legal Entity” Table 2. Block of fields “ID of Individual” Fields Subfields Characteristics / Notes to the field Name of entity  * Empty field to enter data Fields Subfields Characteristics/Notes to the field Country of entity’s head office A drop-down list of countries First name* Empty field to enter data Entity’s registration number Empty field to enter data Middle name(s) or patronymic Empty field to enter data if applicable * Official (registration) address Number Empty field to enter data of the entity ** Last (family) name ** Empty field to enter data Street Empty field to enter data Nationality A drop-down list of countries Apartment Empty field to enter data City A drop-down list of cities (if in the same country Date of birth A pre-set date format in which the declarant is an official) National ID number If more than one ID is applicable, the form should State/province A drop-down list of states/provinces include a field for each ID (if in the same country in which the declarant Tax ID is an official) (if different from the national ID) ZIP code Empty field to enter data Country A drop-down list of countries * If the entity is registered abroad, the name should be entered both in the national language and in English (if English is not the main language of the form). ** If the address is in a country in which the main language is not English, it should still be provided in English. 16 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 17 Table 3. (continued) Table 4. (continued) Fields Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Entity’s head office address ** Number Empty field to enter data Other type of right to use the asset ID of the used asset’s The asset’s owner may mean a management Street Empty field to enter data owner company with which the declarant/family - Block “ID of Individual” member has a contract to use the property Apartment Empty field to enter data - Block “ID of Legal Entity” if the owner is unknown to the declarant. This should be explained in the form or its City A drop-down list of cities (if in the same country guidelines. in which the declarant is an official) State/province A drop-down list of states/provinces Beneficial ownership/control ID of the formal/nominal (if in the same country in which the declarant owner of the asset is an official) - Block “ID of Individual” - Block “ID of Legal Entity” ZIP code Empty field to enter data Asset held in trust Country of the trust A drop-down list of countries Country A drop-down list of countries establishment ** If the address is in a country in which the main language is not English, it should still be provided in English. Date of the trust A pre-set date format establishment Another standard block of fields concerns the more in-depth explanation and/or examples to help ID of the trust settlor ownership or another relationship that the declarant a declarant understand how to respond to questions - Block “ID of Individual” or family member has to an asset that is declared regarding different types of assets. - Block “ID of Legal Entity” (table 4). This block applies to all assets and reflects ID of the trustee/director whether the declarant or a family member owns or For all assets reported in the form, the declarant will - Block “ID of Individual” co-owns, rents, leases, or has the asset under other need to explain how the asset is owned or available - Block “ID of Legal Entity” rights of use, whether the declarant or the family for use by him or her, or by a family member. For each member is a beneficial owner of the asset owned type of ownership or use, the form will ask standard ID of the trust’s beneficiaries by a nominal owner, or whether the asset is in trust questions, which are set out in the block of fields - Block “ID of Individual” management. This block will normally require a for assets. - Block “ID of Legal Entity” Table 4. Block of fields “Type of Ownership” ID of the protector or If applicable another natural person Field / Options in a drop-down list Subfields Characteristics / Notes to the field exercising effective control over the trust Type of ownership or other relationship - Block “ID of Individual” to the asset - Block “ID of Legal Entity” Ownership Co-ownership ID of each co-owner - Block “ID of Individual” The block of fields concerning address (table 5) - Block “ID of Legal Entity” should be used each time the form requires Joint ownership has the declarant to provide details on the address, no shares distributed which is not a part of the other blocks (undivided joint ownership) (for example, “ID of Individual,” Yes “ID of Legal Entity”). No Share of each co-owner in If ownership shares are distributed joint ownership Lease ID of the leased asset’s The asset’s owner may mean a management owner company with which the declarant/family - Block “ID of Individual” member has a contract to use the property - Block “ID of Legal Entity” if the owner is unknown to the declarant. This should be explained in the form or in its guidelines. 18 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 19 Table 5. Block of fields “Address” that includes corrected data if the law either allows there are signs of unjustified wealth or if the review corrected declarations to be submitted during a grace of the declaration showed that another person was Field Subfields Characteristics / Notes to the field period after the submission deadline or requires a the source of income, so his or her assets must be Address Number Empty field to enter data correction to be submitted when the agency in charge verified as well). An ad hoc declaration may also be of verification detects missing or false data. Some required to report on significant changes in assets Street Empty field to enter data systems also provide for an ad hoc declaration that between regular declarations. The different types of Apartment Empty field to enter data must be submitted upon request (for example, if declarations usually cover different periods. City A drop-down list of cities (if in the same Figure 3. Types of declarations country State/province A drop-down list of states/provinces (if in the same country) ZIP code Empty field to enter data Ad hoc Candidate’s Country A drop-down list of countries Upon Corrected entering Sections of the form form public office The proposed order of the sections and fields in the form is one option for structuring it. It can also be organized differently. Post- Regular employment while in office Figure 2. Sections of the form Before or upon terminating office Income, gifts, Type Personal and other Assets of declaration information incoming The declaration form should start with the fields and financial flows subfields shown in table 6. Table 6. Types of declarations Activities outside Expenditures Field / Options in a drop-down list Subfields Characteristics / Notes to the field Financial of public service and other liabilities and other Type of declaration transactions interests Candidate’s (applicant’s) Name of the organization/agency A drop-down list of public agencies declaration or declaration upon to which the declarant is applying to choose from, or enter the name entering public office or is newly employed if it is missing from the list Organizational/structural unit Empty field to enter data Section 1. Types of declarations within the organization/agency National law may require different types office), an annual or biannual declaration while in Position for which the declarant is Empty field to enter data of declarations to be submitted, such as a declaration office, a declaration before or upon terminating applying or in which the declarant by a candidate or an applicant for an elected or public office, and a declaration submitted one or is newly employed appointed/contracted public office (submitted before two years after terminating the public office (post- Regular declaration while entering public office), a declaration upon entering employment declaration). Figure 3 shows the types of in office public office (submitted shortly after entering declarations. There may also be a type of declaration 20 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 21 Table 6. (continued) 2.1. Identification of and contact information same name and to cross-check information with other for the declarant data sources (registries, databases, information held Field / Options in a drop-down list Subfields Characteristics / Notes to the field by legal entities, and so on). Therefore, it is useful Before or upon terminating Name of the organization/agency A drop-down list of public agencies to Identification information should help to distinguish for the form to require the details shown in table 7 public office in which the declarant last worked choose from, or enter the name if it is the declarant from other persons who share the to identify the declarant. missing from the list Table 7. Personal and contact information of the declarant Organizational/structural unit Empty field to enter data within the organization/agency in Field / Options in a drop-down list Subfields Characteristics / Notes to the field which the declarant last worked First name Empty field to enter data The last position of the declarant Empty field to enter data before leaving public office Middle name(s) or patronymic if applicable Empty field to enter data Last (family) name  * Empty field to enter data Post-employment Name of the public organization/ A drop-down list of public agencies Did you change your name during agency in which the declarant to choose from, or enter the name the reporting period? last worked if it is missing on the list Yes Previous first name Empty field to enter data Organizational/structural unit Empty field to enter data within the public organization/ Previous middle name Empty field to enter data or patronymic agency in which the declarant last worked Previous last name Empty field to enter data The last position of the declarant Empty field to enter data No before leaving public office Date of birth A pre-set date format Corrected declaration form The form should prompt the declarant Country of birth A drop-down list of countries to choose the previous declaration that will be corrected City of birth Empty field to enter data Nationality/ Add subfields in case of multiple A drop-down list of countries Ad hoc declaration Declaration of significant changes Options: Yes/No Citizenship nationalities or citizenships Country in which the declarant A drop-down list of countries Declaration submitted when Options: Yes/No has a residence permit required by the verification agency (if different from nationality) National ID number ** If more than one ID is applicable, the Reporting period form should offer a field for each one Year Choose from the drop-down list of years. Tax ID (if different from the national ID) If declaration is submitted every two years, choose the respective period Primary residence Block of fields “Address” Address where the declarant is registered Block of fields “Address” Period since the previous Start date A pre-set date format (if different from the primary residence declaration End date A pre-set date format address) Other reporting period Start date A pre-set date format Phone *** Home number Empty field to enter data Mobile number Empty field to enter data End date A pre-set date format Work number Empty field to enter data Email  *** Work email Empty field to enter data Section 2. Personal Information Personal email Empty field to enter data It is generally necessary to go beyond the declarant’s identification details are also essential for future * In different national contexts, people may have numerous names, so the form should ask for all the names that will be relevant and useful for simple contact details and dig deeper into the verification when information about the declarant or identifying the person. position the declarant holds and into the declarant’s family members is cross-checked against other data ** The form should ask for the most common identifier used in the country’s context; if several IDs are used in the country, the form should ask for them if they are necessary to identify the person effectively. other activities. These data points can be used sources. To better present the fields and make them *** If the declaration is submitted through an online system, the declarant could be asked to provide these details when registering in the system for identifying possible conflicts of interests and more user-friendly, they could be organized into the and to update them when the information changes. As a result, the electronic form does not need to ask for the information again and can hence contribute to more effective analysis. The following subsections. prefill these fields. 22 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 23 2.2. Current position held by the declarant action against the official. Information on the position, Table 8. (continued) job title, grade, and professional responsibilities This subsection identifies the agency for which the can also help determine the risk profile of the Field / Options in a drop-down list Subfields Characteristics / Notes to the field declarant is working and the declarant’s position. declarant. Activities performed by the declarant The designation of specific functions This information helps prevent confusion between in the current position should be linked to the national disclosures from declarants with the same This subsection should include the fields shown nomenclature — that is, a formal name and is relevant when analyzing possible in table 8 to properly identify the position currently standard to which the designation conflicts of interest or for possible enforcement held by the declarant. is linked (for example, the official duties of the position). The options here are general guidance; functions in the Table 8. Current position of the declarant country's form could be more specific. Field / Options in a drop-down list Subfields Characteristics / Notes to the field Senior management Organization/agency name A list of public agencies to choose from (if possible), or enter the name if it is Involvement in financial missing from the list or if the drop-down management (collecting revenues, list is not available disbursing funds, budgeting, accounting) Organizational/structural unit within Empty field to enter data the organization/agency Involvement in procurement Organization/agency official address Block of fields “Address” (selection of suppliers, contract management, involved in the Type of position drafting of terms of reference, member of tender committees) Permanent staff Temporary staff Involvement in granting benefits; concessions; licenses; rights to use Tenured official land, natural resources, or property Contract-based employment Involvement in adjudication Other type Specify which one Empty field to enter data (judicial activity) Category of public service (if applicable) Involvement in law enforcement Civil servant Grade A drop-down menu of grades Involvement in regulatory Local self-government official Grade A drop-down menu of grades enforcement (inspections, supervision, control) Elected official Judge Involvement in policy development and in drafting legislation Prosecutor Advisor or assistant to a public official 2.3. Family members is to get information regarding those closely connected Official of a public company Including family members on the form is essential to the public official. A conflict of interest or accrual of Other category Specify which one Empty field to enter data to achieving the objectives of the disclosure system. wealth may not manifest itself in the information about Information on family members affects the data public officials themselves but may be detected when Do you belong to the category Include a note in the subsection to explain of politically exposed persons according the definition of politically exposed person required in the remaining sections of the form because examining the occupation or position of the officials’ to anti-money laundering legislation? under the national law in many cases, the declarant will have to provide family members or a spouse’s bank account and information related to income, assets, liabilities, and income. Identification information for family members, Yes Choose category of A drop-down list of categories of officials interests for those identified as family members or such as ID numbers, date and place of birth, or officials designated as politically exposed persons as members of the same household (hereinafter addresses, can be used for cross-checking under the national law collectively referred to as family members). information with outside registries and databases. No The purpose of including close family members, The definition of family members should be Appointment date in the current position A pre-set date format cohabitants, or economic dependents in the declaration sufficiently broad to account for the ways in which 24 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 25 assets can be hidden in the country. For example, the spouse is no longer a family member in order to Table 9. (continued) in some countries, the practice of divorcing or not avoid disclosing assets. If the national tradition or law officially registering a marriage to avoid disclosure allows polygamy, the form should ask for information Field / Options in a drop-down list Subfields Characteristics / Notes to the field of assets is widespread. Therefore, the definition on all spouses to prevent the transfer of assets in the Main place of work of family members should cover those who live name of the second or third spouse while disclosing Organization/institution Block of fields “ID of Legal in the same household as the declarant, have only the first one. Entity” a family-type relationship, and are financially dependent on the declarant or vice versa. The definition of family members should also be Self-employed To answer the question of how long a person tailored to the country context for another reason. Unemployed needs to cohabitate with the declarant to become In a particular country, it may be common for adult a “family member” for the purposes of financial children to live in the same house as their parents, Position (if employed in an organization/ Empty field to enter data institution) disclosure, some countries have introduced a but they have a separate household and are financially threshold of days (for example, at least 183 days independent. To account for this arrangement, the Start date of employment/self- Indicate month and year A pre-set date format during the previous year). In some situations, the definition should include the element of financial employment status person may still be a dependent of the declarant dependence. Otherwise, the definition would be Management and supervisory positions Block of fields “ID of Legal Add subfields in case of multiple and qualify as a family member while not actually too broad. Similarly, a definition of family members in commercial and non-commercial Entity” management or supervisory cohabitating with the declarant (for example, that covers close relatives (such as adult children entities positions a child studying abroad or an elderly relative who or parents) who live apart from the declarant in a is financially dependent on the declarant but may separate household and are not financially dependent Commercial entity be living in a care facility or in his or her own home on the declarant may be too broad. It would be better Yes with a caregiver). The national law or guidelines to capture assets acquired in the name of such need to clarify these conditions. relatives through the requirement to disclose the No declarant’s beneficial ownership in assets together Position Empty field to enter data Some systems also consider the declarant’s with their nominal owners. During the reporting period, has the family Representation includes serving spouse to be their family member for purposes of member represented the interests of any as an attorney or with a power the disclosure even if they are de facto separated. The fields shown in table 9 are to be completed for natural or legal person before any public of attorney, an agent, a business The intent is to discourage a declarant’s claims that each person qualifying as a family member. agency except representation before representative, or a lobbyist (if judicial bodies? lobbying is regulated in the country) Table 9. Information on family members Yes Before which public entity has Empty field to enter data Field / Options in a drop-down list Subfields Characteristics / Notes to the field the family member served as an agent? Relationship with the public official In what capacity? Spouse Attorney Partner Business representative Child Lobbyist Parent Other (specify which one) Empty field to enter data Person living in the same household No Financial dependent not living in the same household Comments/explanation An empty field for the declarant to provide an explanation regarding Block of fields “ID of Individual” Identification details of the family the information submitted in this member subsection (optional) Country of birth A drop-down list of countries City of birth A drop-down list of cities Section 3. Assets (if in the same country in which the declarant is an official To get an accurate description of the wealth of the nonmovable property tends to be easier to verify Contact phone Empty field to enter data declarant, the form should require officials to declare because such assets are usually registrable and all movable and nonmovable assets as well as all can be cross-checked with the relevant records. Contact email Empty field to enter data tangible and intangible assets. The disclosure of Regarding movable assets, the ease of disclosure 26 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 27 will vary according to the type of asset. While, for As shown in figure 4, the key issues regarding minimum or average market price of a similar check for possible signs of disguising undue example, cars usually tend to be registered in most disclosure of assets are (a) how to identify asset and use a certain threshold for discrepancy benefits through legitimate sources. The mode jurisdictions, other types of movable assets, such the asset; (b) how to express its value; (c) how to to check whether the price was reduced or inflated of acquisition also significantly facilitates the as antiques or collectible art, might not be registered represent its acquisition — that is, when and how by the declarant. The form may also ask for the verification of the asset and interest disclosure. even though they sometimes have a higher value it was acquired; and (d) what the nature of the appraisal value of the asset if the appraisal was than cars. declarant’s relationship to the asset is. conducted and if the value is known or should be y Nature of the ownership or control. The known to the declarant (for example, if the asset declaration form should capture assets that belong Figure 4. Key issues in disclosing assets was recently appraised for use as collateral in a to the official or to family members in any of the loan). However, there should be no requirement to following ways: conduct a special appraisal just for the purpose of filing the declaration form. I. Formal ownership of the asset. What is the How to represent How to identify How to express nature of the the asset's For movable assets, another issue related to II. Co-ownership (with the requirement to provide the asset the asset's value relationship acquisition to the asset value is the setting of a threshold. It would not be identification details about all co-owners, and reasonable to require that the public official be whether and how the interest in the asset is   obliged to declare all movable assets. A possible distributed among co-owners — for example, approach to solving this problem is to indicate when there are two co-owners and each owns Independent of the specifics of each asset, the not to use it as the only way to represent the value a monetary value for the jewelry, art, antiques, 50 percent of the asset). following are some general guidelines to keep in required in the form. Market value is continuously and other moveable assets to be declared — mind when dealing with the four key issues involved in flux, hard to follow for a non-expert, and for example, any item or collection (set) of items III. Another person or legal entity owns the asset, in disclosing assets: dependent on many variables, making it easy with a value above US $ 3,000, depending on the but the official or family member uses it legally for the declarant to make mistakes inadvertently country context. This type of threshold may also or de facto (with the requirement to provide y Identifying the asset. To accurately identify the when trying to estimate a market value. In be relevant when it comes to livestock, though information about the legal basis for such asset, the form should request the full address addition, the current market price for an asset again it would also depend on the specifics of use, as in a lease/rent contract, and about the at which the asset is located (for real estate), the acquired a long time ago may create a false sense the case: it might not be relevant to declare the asset’s owner or manager if the declarant does country in which is located (for certain movable of wealth and damage the declarant’s reputation ownership of two sheep, but it would certainly not know the asset owner’s ID). property such as vehicles), the property registry if this information is made public. By showing be pertinent to disclose the ownership of a race number (if applicable), the asset’s type and size, sufficient detail about the asset (location, year of horse. Here, the country context and the common IV. Another person (nominal owner) formally and other important descriptive characteristics. acquisition, surface area, and acquisition value for sense should guide the process. As in other owns the asset, but the official or family It is also useful to request information that might real estate; make and model, and acquisition value sections, the ease of filling out the form should member holds beneficial ownership/control be in other registries, databases, or documents for a movable asset), the form provides enough be taken into account but should not be the main of the asset. The definition of beneficial in order to simplify cross-checking (for example, a transparency for the public to understand the factor. The form should capture all substantive ownership or control of assets may differ registration number, place and date of registration, declarant’s wealth and for the verification agency assets and changes in the declarant’s wealth. from one country to the next. and registration authority). to conduct meaningful checks. Current market value has no relevance for tracking unexplained y Acquisition of the asset. If the system is focused One option is to define beneficial ownership y Value of the asset. This is one of the most challen­ wealth because the verification agency has on tracing unjustified variations in wealth, the form as property: ging issues that need to be addressed, taking into to compare available income and savings should require filers to include the date on which consideration the country context, the objectives information with the amount that was spent a currently held asset was acquired (exact date a) Over which the public official or family of the disclosure system, and the ease with which to obtain the asset when it was acquired, or month and year or at least the year if the exact member exercises control being capable filers can retrieve the information. The value of the not when the declaration was submitted. date is hard to establish). For conflict-of-interest to take action (directly or through other asset can be expressed in different terms: market purposes, the date of acquisition may also be persons) that is identical in substance to the value (when the asset was acquired or when the The most relevant value for the purposes of the relevant: for example, if the official acquired stocks right of the asset’s disposal, or declaration was submitted), purchase value, cadas- asset and interest disclosure is the acquisition when in office, it may indicate the misuse of insider tral value, appraisal value, fiscal value, or insured price, which can also vary, for instance, between information. b) From which the official or family member value. There are certain trade-offs and complexities the price noted in the document certifying the derives a benefit by receiving income involved in picking one type of value over the other. purchase (if the document exists) and the price Information on how an asset was acquired or having the right to receive income, or No matter which type of value is used, the most that was actually paid to acquire the asset. Ideally, (whether it was purchased, inherited, or important factor is to communicate this properly the form should ask for the price actually paid, as it received as a gift) is also relevant to the internal c) That was acquired upon instruction by or at to the filer and to be consistent across the form. would show the declarant’s actual expense, which consistency of the declared information. It helps expense of the official or family member. can then be compared with his or her income. to match the variations in assets to variations in In general, we do not recommend using the When such an acquisition price is indicated, income, to reveal interests (such as a relationship This definition of ownership is an example of market value when describing an asset, at least the verification agency can compare it with the with the person who donated an asset), or to how the beneficial ownership/control over assets 28 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 29 can be interpreted and explained in the anti- Beyond the preceding general guidelines and Table 10. (continued) corruption legislation and in the form. It should to better capture the specifics of each type of be adjusted to the country context and legal asset that may belong to the declarant and family Field / Options in a drop-down list Subfields Characteristics / Notes to the field regulations but broad enough to capture property members, we suggest organizing this category Date when acquired A pre-set date format relationships to assets established abroad. into subsections 3.1 to 3.13. Acquisition price (if applicable) Empty field to enter data V. The asset is held in trust (or a similar legal All subsections on assets should cover information Cadastral value Empty field to enter data arrangement) of which the official or family on the declarant and all family members. The form Value of property according to the latest Empty field to enter data member is a beneficiary, settlor, or trustee. should explain that the fields in each subsection valuation (if available) concern one specific item (for example, a land plot); Comments/explanation An empty field for the declarant to An asset may generate income or may have been if the declarant needs to report several items provide an explanation regarding purchased with a loan. Filers should be made aware (for example, several land plots), a new entry must be the information submitted in this that these and other circumstances may require created for each item, and the data must be included subsection (optional) entries elsewhere on the form. in the relevant fields. 3.2. Buildings, a'partments, and other real estate 3.1. Land The subsection should include the fields shown The subsection should include the fields shown in table 11 for each other real estate. in table 10 for each piece of land. Table 11. Buildings, apartments, and other real estate Table 10. Land Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Type of real estate Type of land Apartment Farmland Building/house Residential land Forest Office Water surface Warehouse Other Specify which one Empty field to enter data Garage Surface area (sq. meters/sq. feet) Empty field to enter data Parking space Title registration number Empty field to enter data Vacation house Cadaster number Empty field to enter data Other Specify which one Empty field to enter data Address Block of fields “Address” Surface area (sq. meters/sq. feet) Empty field to enter data Whose asset is it? Indicate whom the asset concerns (who is its owner, user, or controller) – Title registration number (if applicable) Empty field to enter data the declarant or the family member (and which one). Cadaster number Empty field to enter data Declarant Address Block of fields “Address” Family member Choose the family A drop-down list of family members member entered in section 2.3 Whose asset is it? Indicate whom the asset concerns (who is its owner, user, or controller) – Type of ownership/control Block of fields the declarant or the family member “Type of Ownership” (and which one) Legal ground for acquisition Declarant Purchase Family member Choose the family A drop-down list of family members Inheritance member entered in section 2.3 Gift Type of ownership/control Block of fields Other Specify which one Empty field to enter data “Type of Ownership” 30 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 31 Table 11. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Legal ground for acquisition Property is located Property was fully Declarant or family on the land plot or mostly built from Purchase member owns that is in ownership, the materials or at the property or rights   right lease, or other the expense of the Inheritance to future property of the declarant declarant or family Gift or family member member Other Specify which one Empty field to enter data Date when acquired A pre-set date format Acquisition price (if applicable) Empty field to enter data Value of property according to the latest Empty field to enter data If the property construction involves financial The subsection should include the fields shown valuation (if available) obligations of the declarant or family member in table 12 for each real estate under construction. Expenses related to real estate development Investment in the renovation or other (for example, investment in construction carried out in the reporting period improvement of the property if the by a development company), these obligations also cumulative expenses to improve one need to be reported in section 5, “Financial liabilities.” real estate asset during the reporting period exceed a threshold set in the legislation (for example, US $ 5,000) Table 12. Unfinished construction Comments/explanation An empty field for the declarant to Field / Options in a drop-down list Subfields Characteristics / Notes to the field provide an explanation regarding the information submitted in this Type of real estate subsection (optional) Apartment Building/house 3.3. Unfinished construction not yet registered according to the procedure legally Office required (figure 5). The unfinished construction should Warehouse It is important that the form captures real estate be reported if it meets at least one of the following assets that are under development because they conditions: (a) the property or the rights to future Garage may represent a significant investment or can hide property is owned by the declarant or family member, Parking space real estate use or ownership if the declarant does not (b) the property is located on the land plot that is in Vacation house obtain the full title. Describing unfinished construction ownership, lease, or under another right of use of has its peculiarities, so it is better to organize it as the declarant or family member, or (c) the property Other Specify which one Empty field to enter data a separate subsection of the form. This subsection was fully or mostly built from the materials or at the Type of property It should be possible to choose any covers real estate under construction, real estate expense of the declarant or family member. National combination of these options that was constructed but not formally certified for legislation may indicate other characteristics of such (unless this contradicts national residence, or other types of use or rights that were real estate that should be included in the form. legislation) Property under construction Figure 5. Types of unfinished construction Property without formal certification Property without registration Whose asset is it? Indicate whom the asset concerns (who is its owner, user, or controller) – the declarant or the family member (and which one)   Declarant Family member Choose the family A drop-down list of family members Real estate that was constructed Other types of use or rights that were not member entered in section 2.3 Real estate but not formally certified yet registered according to the legally Type of ownership/control Block of fields under construction for residence required procedure “Type of Ownership” 32 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 33 Table 12. (continued) Table 13. Vehicles Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Relationship to the property At least one option/checkbox should Type of vehicle be chosen Motorcycle Property is owned by the declarant or family member Car Property is located on a land plot that Boat is in ownership, lease, or under another right of use of the declarant or family Aircraft member Truck Property was fully or largely built from the materials or at the expense of the Agricultural machine declarant or family member Bus Surface area (sq. meters/sq. feet) Empty field to enter data Registration number Empty field to enter data Construction machinery (if applicable and available) Other Specify which one Empty field to enter data Address Block of fields “Address” Manufacturer or brand The form may include a drop-down list of the main manufacturers/brands Start date of the construction Month, year A pre-set date format Year of production A pre-set date format Owner of the land plot on which property is located Model The form may include a drop-down list of the main car models linked Declarant to the vehicle brand Family member Choose the family A drop-down list of family members member entered in section 2.3 Country of location or registration A drop-down list of countries Another person Block of fields Information on the registered owner “ID of Individual” Declarant Legal entity Block of fields “ID of Legal Entity” Family member Choose the family A drop-down list of family members member entered in section 2.3 Expenses related to the real estate Investment in the renovation or other development in the reporting period improvement of property if the cumulative Another individual Block of fields expenses to improve one real estate “ID of Individual” asset during the reporting period exceed a threshold set in the legislation Legal entity Block of fields (for example, US $ 5,000) “ID of Legal Entity” Comments/explanation An empty field for the declarant to provide VIN or another registration number Empty field to enter data an explanation regarding the information submitted in this subsection (optional) Whose asset is it? Indicate whom the asset concerns (who is its owner, user, or controller) – the declarant or the family member 3.4. Vehicles, boats, aircraft, machinery, items. The form or the guidelines to it should (and which one) and so forth also define what counts as a vehicle by referring to other legislation or including an autonomous Declarant Because vehicles and other similar movable definition (for example, “a self-propelled machine Family member Choose the family A drop-down list of family members assets have unique characteristics, it is better to or mechanism”). member entered in section 2.3 cover them in a separate subsection. The form may set a minimum value threshold for disclosing The subsection should include the information Type of ownership/control Block of fields a vehicle to avoid the disclosure of low-value shown in table 13 for each vehicle. “Type of Ownership” 34 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 35 Table 13. (continued) Table 14. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Legal ground for acquisition Country of location or registration A drop-down list of countries Purchase Whose asset is it? Indicate whom the asset concerns (who is its owner, user, or controller) – Inheritance the declarant or the family member (and which one) Gift Other Specify which one Empty field to enter data Declarant Date of acquisition A pre-set date format Family member Choose the family A drop-down list of family members member entered in section 2.3 Acquisition price (if applicable) Empty field to enter data Type of ownership/control Block of fields Value of property according to the latest Empty field to enter data “Type of Ownership” valuation (if available) Legal ground for acquisition Comments/explanation An empty field for the declarant to provide an explanation regarding the information Purchase submitted in this subsection (optional) Inheritance Gift 3.5. Other movable assets items. To avoid the disclosure of numerous household items and personal belongings, the law should establish Other Specify which one Empty field to enter data The form should include information about valuable a value threshold for disclosing such movable assets Date of acquisition A pre-set date format movable property other than vehicles. Such assets (for instance, US $ 3,000 per item or per collection/set). can vary in type and include livestock; art; jewelry; and Acquisition price (if applicable) Empty field to enter data historical, cultural, or religious artifacts. This subsection The subsection should include the fields shown in Value of property according to the latest Empty field to enter data of the form also covers collections and sets of such table 14 for each moveable asset. valuation (if available) Table 14. Other movable assets Comments/explanation An empty field for the declarant to provide an explanation regarding Field / Options in a drop-down list Subfields Characteristics / Notes to the field the information submitted in this subsection (optional) Type of asset Art Jewelry 3.6. Securities and stocks (except ownership The challenge of reflecting the value of assets is also interest in commercial entities) relevant to securities because their market value is Precious stones continuously in flux. To manage this challenge, the The disclosure of information on securities is form should ask for the acquisition value and face Antiques important in most systems because it concerns both (nominal) value of securities, not a statement of the Cultural or religious artifact variations in the public official’s wealth and conflict of current market value of the securities. interest. The subsection on securities should cover all Livestock types of public and private securities and derivatives. The subsection should include the fields shown Pet Stocks (privately owned or publicly traded) should in table 15 for each class of securities of the same also be included in this subsection. Other interests in type (for example, stocks in the same company or a Electronic device businesses (for example, other types of shares in the batch of government bonds company capital) are covered in the next subsection. of the same issue):6 Other Specify which one Empty field to enter data Description of asset An open field in which the official describes the item 6 The form or supporting guidelines should explain how a declarant or family member should report securities of the same type acquired at Manufacturer or trademark (if applicable) Empty field to enter data different times. For example, when the declarant acquired an additional batch of company stock. The declarant may need to explain such situations in the comments field while indicating the date of the first acquisition in the field “Date of acquisition.” 36 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 37 Table 15. Stocks and other securities Table 15. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Type of securities Declarant Stocks in a private company (not Family member Choose the family A drop-down list of family members publicly traded) member entered in section 2.3 Stocks in a public company (publicly Type of ownership/control Block of fields traded) “Type of Ownership” Government bonds Legal ground for acquisition Municipal bonds Purchase Private bonds Inheritance Promissory note Gift Certificate of deposit Other Specify which one Empty field to enter data Investment certificate Date of acquisition A pre-set date format Mortgage-backed security Were securities transferred in management to another person? Privatization securities Yes - Block of fields Derivatives “ID of Individual” Options - Block of fields “ID of Legal Entity” Futures Date when securities A pre-set date format Forwards were transferred Swaps End date of A pre-set date format Mutual fund management agreement Money market security No Other Specify which one Empty field to enter data Comments/explanation An empty field for the declarant to Details of issuer provide an explanation regarding the information submitted in this Individual Block of fields subsection (optional) “ID of Individual” Legal entity Block of fields “ID of Legal Entity” 3.7. Ownership interest in commercial entities 3 and 5, respectively). For declaration purposes, Primary stock exchange (for publicly traded A drop-down list of main national other than stocks the assets of sole proprietorships are treated as stocks) and foreign stock exchanges personal assets of the declarant or the family This subsection focuses on the ownership interest member. Number of units held Empty field to enter data held by the declarant or family member in businesses Ownership interest (for stocks) % of the total capital if known to when they are owned by two or more natural persons When the declarant is required to disclose the amount the declarant or if above a certain or by legal persons. This subsection does not concern of ownership interest in commercial entities, he threshold — for example, 1% stocks in private or public companies, as they are or she needs to declare only the actual amount of Face value per unit (if applicable) Empty field to enter data covered in the previous subsection. funds contributed to the business by way of capital (contributions made by way of loans need to be Acquisition cost per unit Empty field to enter data This subsection also does not include self- included in section 5, “Financial liabilities”). Whose asset is it? Indicate whom the asset concerns employed businesses (sole proprietorships) (who is its owner, user, or controller) – because for these cases, the associated business The subsection should include the detailed the declarant or the family member assets and liabilities should be included with the information shown in table 16 about each ownership (and which one) declarant’s other assets and liabilities (sections interest in commercial entities. 38 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 39 Table 16. Ownership interests (other than stocks) in commercial entities Table 16. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Name of the company Empty field to enter data Main area of business activity of the legal Main area of business activity could entity mean the sector in which the legal entity Block of fields “ID of Legal Entity” obtains more than 50% of its revenue Type of legal form Construction Limited liability partnership Mining/extractive industry Joint venture Energy generation and supply Cooperative Transportation and logistics Other Specify which one Empty field to enter data Pharmaceutical Date of incorporation or setting up A pre-set date format of the legal entity Manufacturing Face value per unit Empty field to enter data Importing Acquisition cost per unit Empty field to enter data Agriculture Date of acquisition A pre-set date format Hotels, restaurants, catering Ownership interest % of the total capital if known to Information and communication the declarant or if above certain technology services threshold — for example, 1% Tourism Whose asset is it? Indicate whom the asset concerns (who is its owner, user, or controller) – Legal and accounting services the declarant or the family member (and which one) Investment and finance Declarant Other Specify which one Family member Choose the family A drop-down list of family members Major business partner of the legal entity - Block of fields A major business partner could mean member entered in section 2.3 if the declarant or family member owns/ “ID of Individual” an individual or legal entity from which controls more than a substantial percentage - Block of fields the company received more than 50% Type of ownership/control Block of fields (for example, above 25 or 50 percent) of the “ID of Legal Entity” of its last year’s total revenue “Type of Ownership” entity’s shares or is otherwise the ultimate Legal ground for acquisition beneficial owner (controller) of the entity Purchase Comments/explanation An empty field for the declarant to provide an explanation regarding Inheritance the information submitted in this Gift subsection (optional) Other Specify which one Empty field to enter data Were shares transferred in management 3.8. Beneficial ownership or control in legal disclosure law may introduce an autonomous to a legal person or an individual? entities, trusts, and similar legal arrangements definition used for disclosure purposes. Yes - Block of fields “ID of Individual” In addition to stocks and shares in companies, the Using entities in which the official does not have a - Block of fields form should capture beneficial ownership or control in formal stake in ownership is a widespread practice to “ID of Legal Entity” legal entities, trusts, and legal arrangements similar to hide unjustified assets or to divert public resources. trusts. The definition of beneficial ownership (control) It is therefore important to disclose information on Date when shares A pre-set date format used in the anti-money – laundering legislation can entities controlled by the public official or family were transferred be applied to the asset and interest disclosure of members in the declaration form because it may be End date of A pre-set date format public officials.7 Alternatively, the asset and interest hard for law enforcement authorities or anti-corruption management agreement 7 See, for example, the definition in Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 No on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, article 3 (6), * For trusts and similar legal arrangements. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32015L0849&from=EN 40 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 41 agencies to obtain it from publicly available sources. The subsection should include the details shown Table 17. (continued) This is especially the case when such entities are in table 17 for each of the entities required to be registered or set up in foreign jurisdictions. reported. Field / Options in a drop-down list Subfields Characteristics / Notes to the field Any other person exercising ultimate control over the trust by means of direct or indirect Table 17. Beneficial ownership or control in legal entities, trusts, and similar legal arrangements ownership or by other means * Declarant Field / Options in a drop-down list Subfields Characteristics / Notes to the field Type of entity Family member Choose the family A drop-down list of family members member entered in section 2.3. Corporate entity Another individual Block of fields Trust “ID of Individual” Legal arrangement similar to trust Amount of income received from legal Empty field to enter data Legal foundation entity, trust, or similar legal arrangement in the reporting period Other Specify which one Empty field to enter data Assets held by trust in which the declarant Type of asset A drop-down list of types of assets Block of fields “ID of Legal Entity” or family member is a settlor, trustee, protector or beneficiary (unless such assets Location of asset Settlor * have already been reported in the form’s - Block of fields Declarant other sections on assets) “Address” Family member Choose the family A drop-down list of family members Owner of asset member entered in section 2.3 Declarant Another individual Block of fields “ID of Individual” Family member Choose the family member Trustee(s) * Another individual - Block of fields Declarant “ID of Individual” Family member Choose the family A drop-down list of family members member entered in section 2.3 A legal entity - Block of fields Another individual Block of fields “ID of Legal Entity” “ID of Individual” Comments/explanation An empty field for the declarant to Protector (if applicable) * provide an explanation regarding Declarant the information submitted in this subsection (optional) Family member Choose the family A drop-down list of family members * For trusts and similar legal arrangements. member entered in section 2.3 Another individual Block of fields “ID of Individual” 3.9. Intangible assets them, making cross-checking the data easier than Beneficiary(ies) * for other assets. We recommend limiting intangible Declarant Intangible assets include intellectual property assets disclosed in the form to those that have rights, patents, trademarks, know-how, other a monetary value and are subject to registration Family member Choose the family A drop-down list of family members similar rights, licenses to extract or use natural (for intellectual property). member entered in section 2.3 resources, and so on. This subsection may present Another individual Block of fields difficulties in identifying the assets involved. The subsection should include the fields shown “ID of Individual” Nonetheless, for most intangible assets in this in table 18 to obtain sufficient information on each Class of beneficiaries Empty field to enter data category, there are usually agencies that register intangible asset. (if specific persons are not yet determined) 42 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 43 Table 18. Intangible assets Table 18. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Type of asset Did the declarant or family member transfer the rights to use the intangible asset Patent (e.g., a patent) to another person? Trademark Yes Indicate the person to Industrial design whom the rights were transferred Know-how Declarant Cannot be chosen if the asset belongs Copyright to the declarant Plant variety rights Family member Choose the family member, except the family member to whom the asset License to use subsoil resources belongs according to the filed Other Specify which one Empty field to enter data “Whose asset is it?” Description of the asset to which the right An open field in which the declarant Another individual applies describes the asset according to the - Block of fields official document that certifies the right “ID of Individual” to the asset or license A legal entity Whose asset is it? Indicate whom the asset concerns - Block of fields (who is its owner, user, or controller) – “ID of Legal Entity” the declarant or the family member (and which one) No Declarant Comments/explanation An empty field for the declarant to provide an explanation regarding Family member Choose the family A drop-down list of family members the information submitted in this member entered in section 2.3. subsection (optional) Type of ownership/control Block of fields “Type of Ownership” Legal ground for acquisition 3.10. Accounts in banks and other financial bank secrecy laws might present an obstacle. This institutions, safe-deposit boxes subsection should also include information on the Purchase safe-deposit boxes that belong to the official or The information regarding bank accounts and other family member or to which they have access (for Inheritance financial products from banking or other financial example, through authorization granted by another Gift institutions (such as credit unions and investment person). Certain bank accounts may be excluded funds) is a category that tends not to raise particular from the disclosure requirements (for example, Other Specify which one Empty field to enter data issues in terms of how the information is requested accounts that are set up specifically for receiving Date of acquisition A pre-set date format from the filer. Account information is readily Social Security or other state-guaranteed payments available and is easy to access for most filers. as required by the law). Value at the time of acquisition Empty field to enter data The challenges regarding this subsection tend to Date of registration or issuing of license A pre-set date format arise, nonetheless, when the information declared is The subsection should include the fields shown in as indicated in the certifying document being cross-checked because in many jurisdictions, table 19 for each account. Name of the right registration or license Empty field to enter data issuing agency Place of the right registration or issuing Empty field to enter data of license 44 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 45 Table 19. Accounts in banks and other financial institutions, safe-deposit boxes a certain threshold value should be subject to the amount of savings held by the declarant or disclosure. This threshold is something that needs family members from the previous reporting periods Field / Options in a drop-down list Subfields Characteristics / Notes to the field to be defined according to the country’s context. that, taken together with income received, can be Name of the bank or nonbanking financial compared with assets acquired and expenditures institution Some disclosure practitioners question the made during that period. The risk that the declarant usefulness of this subsection because, in most will disclose nonexistent cash holdings is also Details of the bank or nonbanking financial Block of fields cases, the tools available to the verification balanced by the fact that in systems that track institution “ID of Legal Entity” agency will not allow it to confirm whether the unjustified wealth, an excessive amount of monetary Type of account value of the monetary asset disclosed by the assets will trigger an investigation, and the declarant Savings account in bank filer is accurate. Nonetheless, asking for this will need to show the lawful sources for such assets. type of data can prove useful in the context of The lack of such lawful sources may be grounds Checking account in bank a broader corruption investigation. For example, for prosecuting illicit enrichment or for confiscating Credit card account in bank when cash is found in the residence of a suspect unjustified wealth through civil or administrative or monies are discovered in a bank account, and proceedings. Account in credit union if neither was disclosed in a previous asset and Account in investment fund interest declaration, such a nondisclosure may Other countries address this problem by establishing be prosecuted separately from the predicate a limit to how much money a public official may hold Other type of account Specify which one Empty field to enter data offense, which is typically harder to prove. outside of the financial system. Safe-deposit box Account number (if applicable) Empty field to enter data Information on monetary assets is also essential The subsection should include the details shown in for tracking unjustified variations in wealth. It shows table 20 for each monetary asset. Who opened the account or safe-deposit box in the interests of the declarant or family Table 20. Types of monetary assets member? Declarant Field / Options in a drop-down list Subfields Characteristics / Notes to the field Family member Choose the family A drop-down list of family members Type of asset member entered in section 2.3. Cash Another individual Block of fields “ID of Individual” Money held in bank account Who has the right to use the account or has Money deposited with a credit union or access to the safe-deposit box (if different other nonbanking financial institution from the person who opened account/box)? Money placed in investment/pension Declarant fund Family member Choose the family A drop-down list of family members Precious metal member entered in section 2.3. Another individual Block of fields “ID of Individual” Whose asset is it? Comments/explanation An empty field for the declarant to Declarant provide an explanation regarding the information submitted in this Family member Choose the family A drop-down list of family members subsection (optional) member entered in section 2.3. 3.11. Monetary assets usually no unequivocal trail). It is also necessary to For monetary assets except precious metals, the form (cash, precious metals, and so forth) strike a balance between the interests of reaching should ask for the information shown in table 21. the disclosure system’s objectives and minimizing The challenge with monetary assets is the lack of the burden on filers by establishing appropriate a standardized proof of their existence unless they thresholds for the disclosure of such assets. If we are held in financial institutions, making it difficult to do not want to make disclosure obligations too identify their sources and specific locations (there is burdensome, then only monetary assets above 46 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 47 Table 21. Monetary assets except precious metals 3.12. Virtual assets therefore important that the form does not leave a gap and covers this relatively new type of asset. The Field / Options in a drop-down list Subfields Characteristics / Notes to the field Virtual assets (for example, cryptocurrencies) have form should use a broad definition that is not limited Amount on the last day of the reporting Aggregated amount per type of been increasingly used as a tool to invest or to to cryptocurrencies to cover existing and emerging period asset and per banking or nonbanking accumulate wealth. These assets can, however, types of virtual assets (for example, nonfungible financial institution (for example, be used for money laundering or for hiding tokens [NFTs], which are becoming a popular digital amount of money held in all declarant’s illicit benefits of public officials. The Financial asset,9 or Metaverse digital assets). Because virtual checking accounts in bank X or total Action Task Force (FATF) defines virtual assets assets can be associated with different categories amount of cash held outside of banks as digital representations of value that can be of other assets covered in the form, we recommend in each currency) digitally traded or transferred and can be used for including them in a separate subsection. If virtual Currency of asset A drop-down list of currencies payment or investment purposes, including digital assets are covered in the subsection on intangible representations of value that function as a medium assets, the form should explicitly mention this to Banking or nonbanking financial institution in Block of fields of exchange, a unit of account, and/or a store of make it clear for declarants. which asset is held (if applicable) “ID of Legal Entity” value. The FATF emphasizes that virtual assets are Comments/explanation An empty field for the declarant to distinct from fiat currency, which is the money of a The subsection should include the details shown in provide an explanation regarding country that is designated as its legal tender.8 It is table 23 for each type of virtual asset. the information submitted in this subsection (optional) Table 23. Virtual assets For precious metals, the form should ask for the Field / Options in a drop-down list Subfields Characteristics / Notes to the field information shown in table 22. Name/Type The list of the most popular virtual assets should be regularly updated, Table 22. Precious metals as it changes often Field / Options in a drop-down list Subfields Characteristics / Notes to the field Bitcoin Type of asset Binance coin Gold Ethereum Silver Tether Platinum USD coin Palladium Other cryptocurrency Specify which one Empty field to enter data NFTs Type of unit Other type of virtual assets Specify which one Empty field to enter data Bar/nugget Whose asset is it? Coin Declarant Number of units Empty field to enter data Family member Choose the family A drop-down list of family members Weight Empty field to enter data member entered in section 2.3. Date of acquisition A pre-set date format Date of acquisition or period of acquisition A pre-set date format Acquisition price Empty field to enter data if several virtual asset units of one type were acquired during the reporting period Comments/explanation An empty field for the declarant to provide an explanation regarding the Number of tokens or other units of virtual Empty field to enter data information submitted in this subsection asset of one type as of the last day (optional) of the reporting period 8 FATF,“Virtual Currencies Key Definitions and Potential AML/CFT Risks,” June 2014, https://www.fatf-gafi.org/en/publications/methodsandtrends/documents/virtual-currency-definitions-aml-cft-risk.html 9 An NFT is a unit of data stored on a blockchain that certifies a digital asset to be unique and therefore not interchangeable. NFTs can be used to represent digital items such as photos, videos, and audio. 48 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 49 Table 23. (continued) Table 24. Loans Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Total acquisition value of virtual asset of one Empty field to enter data Lender type acquired during the reporting period Declarant Entity that provides services of safekeeping Block of fields Family member Choose the family A drop-down list of family members or administration of virtual asset “ID of Legal Entity” member entered in section 2.3. (for example, virtual asset wallet custodian) Borrower Public key for virtual asset acquisition Empty field to enter data transaction (or equivalent transaction Declarant identifier) Family member Choose the family A drop-down list of family members Comments/explanation An empty field for the declarant to member entered in section 2.3. provide an explanation regarding Another individual Block of fields the information submitted in this “ID of Individual” subsection (optional) Another entity Block of fields “ID of Legal Entity” Original loan amount Empty field to enter data 3.13. Money owed to the declarant or family contracts under which the declarant or family member, legal claims to future payments member are mentioned as a beneficiary. Date when loan was made A pre-set date format End date of loan A pre-set date format This subsection is a complement to much of the The data declared in this subsection is useful not Currency A drop-down list of currencies data described in the previous subsections. It only for checking wealth variations and detecting includes (a) money provided by the declarant or undue advantages but also for getting a better idea Annual interest rate Empty field to enter data family member as a private loan to another person of the interests and influences affecting the public No-interest loan A checkbox or a legal entity, (b) rights to claim monetary assets official. To exclude small-value loans and other Comments/explanation An empty field for the declarant to that the declarant or family member acquired but minor claims, we recommend establishing a value provide an explanation regarding has not yet realized (for example, the right to claim threshold for disclosing such assets (for example, the information submitted in this debt from another person that was transferred to US $ 3,000 for the original loan amount or the total subsection (optional) the declarant or family member), (c) options or amount of funds that can be claimed). other contracts under which the declarant or family For each right to claim debt, option, or another member has the right to claim transfer (including The subsection should first ask the declarant to contract giving rights to claim an asset, the subsection for payment) of a financial asset, and (d) insurance indicate the type of asset, as shown in table 24. should ask for the information shown in table 26. Table 26. Rights to claim debt or assets Table 24. Types of money owed to the declarant or family member, legal claims Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Who has the right/contract? Type of assets Declarant Loan given by the declarant or family Family member Choose the family A drop-down list of family members member member entered in section 2.3. Right to claim debt Date of acquisition of the rights, A pre-set date format date of options, or another contract Options or other contract giving rights to claim an asset, including by purchasing it Person who transferred the rights, issued options, or another contract Insurance contract with declarant or family member as a beneficiary An individual Block of fields “ID of Individual” For each loan given by the declarant or family A legal entity Block of fields member, the subsection should then ask the declarant “ID of Legal Entity” for the information shown in table 25. 50 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 51 Table 26. (continued) period or time in office. The disclosure of gifts, similar may be called something different from “Income” (for to income, can advance both objectives by revealing example, “Income and other incoming financial flows”) Field / Options in a drop-down list Subfields Characteristics / Notes to the field possible interests or potentially questionable sources or clarify the term “income.” Description of the rights or assets that can be Empty field to enter data of income used to disguise undue benefits. claimed Income is typically established on the basis of three As in many other categories of information in the main components: (a) source (the legal entity or Amount of debt or other assets that can be Empty field to enter data form, details are vital when designing the income individual from whom the declarant or family member claimed fields. The specific details should be made clear received income); (b) type (salary, fees, monies from Currency of debt or other assets A drop-down list of currencies to the filer, such as whether to include the gross selling movable/nonmovable assets, royalties, monies (if applicable) or net value of income, what currency to indicate from economic and commercial activities, dividends, End date to claim the debt or other assets A pre-set date format (domestic, foreign, or both), and how to calculate winnings from gambling, inheritance, and so forth); the corresponding exchange rate if the currency and (c) value. Comments/explanation An empty field for the declarant to indicated is foreign. The income declared should provide an explanation regarding preferably be net income (after taxes if they were The section should cover income of the declarant and the information submitted in this already paid by the declarant or levied at the source all family members. subsection (optional) of income) to show the value that the declarant actually received and could then use to fund To better organize the information in this section, we The subsection should include the information shown expenses. If the reporting period ends before taxes suggest that it could be divided into two parts, one in table 27 for each insurance contract in which the are paid or if taxes are not withheld by the payor, covering income and the other covering gifts. declarant or family member is a beneficiary. then filers may be required to report gross income. Table 27. Insurance contracts It is especially important for the form designers to 4.1. Income other than gifts consider all of these details if the data are cross- Field / Options in a drop-down list Subfields Characteristics / Notes to the field checked with other agencies such as the tax The subsection should capture all possible types of Beneficiary administration. For example, consulting the country’s income other than gifts by providing a list of the most breakdown of income types in the tax declaration common types of income from which the filer can Declarant form before designing the income fields can help choose in order to simplify submission and avoid to facilitate the verification process. At the same mistakes. The proposed types of income should be Family member Choose the family A drop-down list of family members time, the definition of income for the purposes of detailed enough to (a) convey to an outside reader member entered in section 2.3. asset and interest disclosure will differ from the one how the income was received and (b) be useful for Date of contract A pre-set date format used for tax or accounting purposes. For example, the possible automated analysis of electronic forms. loans received in the reporting period may be treated Income not covered in the list of most common income Insurance company Block of fields as “income” for the financial disclosure form even categories should be declared as “Other income” in an “ID of Legal Entity” though they are not considered income under open field made available to the filer to describe such Insured person if different from Block of fields accounting or taxation norms. Tax declarations are income. the beneficiary “ID of Individual” intended to establish taxable income, while asset and interest declarations are intended to reflect Income should be reported as a value in the national Total amount of insurance payment Empty field to enter data incoming and outgoing financial flows and conflicts currency. If income was received in a foreign currency, of interest. Therefore, the form should also capture the amount should be reported in the currency in Comments/explanation An empty field for the declarant to nontaxable income to calculate wealth. What which it was received. If the verification agency needs provide an explanation regarding matters is the incoming financial flow that increases to establish the equivalent in the domestic currency, it the information submitted in this the declarant’s financial means, which can be used will do so by using the exchange rate valid on the date subsection (optional) later for expenditures. when the income was received. To reflect the broader nature of income captured in the The subsection should include the types of income Section 4. Income, gifts, and other incoming financial flows asset and interest disclosure form, the subsection shown in table 28. Income is one of the most widespread categories of interest and to monitor unjustified variations in of information required in disclosures regardless of wealth. A snapshot of all the amounts and sources the objective of the system. The income amount and of income helps to identify fluctuations in wealth source are key elements in achieving both goals of over time when combined with information on total the system: to identify, prevent, and manage conflicts savings and assets acquired during the reporting 52 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 53 Table 28. Types of income Table 29. Income recipient, amount, and source Field / Options in a drop-down list Subfields Field / Options in a drop-down list Subfields Characteristics / Notes to the field Type of income Who received income? Employment income at the main place of work (salary, wages) Declarant Employment income at the secondary place of work Family member Choose the family A drop-down list of family members entered Bonuses, incentives in addition to employment income (if paid not as a part of the main member in section 2.3. employment income) Amount of income in the currency Total sum for one type of income received from Income from self-employed business (sole proprietorship) in which it was received one source during the reporting period. Income received from sole proprietorship or Income from professional activity (income from practicing as) Currency A drop-down list professional activity can be aggregated and of currencies shown as a total sum instead of details on each Attorney Amount An empty field transaction, which would be too cumbersome. Notary Appraiser Source of income “Source of income” field should not be required if “Sole proprietorship” or “Professional activity” Bankruptcy manager were chosen as “Type of income.” Private executor/bailiff An individual Block of fields Other Specify which one “ID of Individual” Income from the sale of assets A legal entity Block of fields Real estate “ID of Legal Entity” Vehicles Comments/explanation An empty field for the declarant to provide an explanation regarding the information submitted Shares in company in this subsection (optional) Securities Other assets Specify which one Income from investments and businesses (dividends) 4.2. Gifts Gifts in the form of assets other than cash or in-kind Income from rent/lease of real estate or another asset Unrestricted gifts undermine the integrity of public benefits should be reported in the relevant sub-section Income from interest paid on deposits in financial institutions service and create conflicts of interest. Article 8 of under section 3, “Assets” (for example, an apartment Income from interest paid on private loans the United Nations Convention against Corruption given as a gift to the declarant should be shown in mentions “substantial gifts or benefits from which the subsection on real estate, with the legal ground Income from securities a conflict of interest may result with respect to for acquisition stated as “gift”). There is no need to Royalties their functions as public officials” among the duplicate this information in the subsection on gifts Insurance payment items to be included in the declarations of public because the subsection on the relevant type of asset Pension, state allowance officials.10 The regulation of gifts received by will show “gift” as the mode of acquisition. There can public officials is often addressed in a holistic way also be a mismatch between the two value thresholds; Tax refund through national anti-corruption restrictions and that is, certain assets received as gifts may not be Cashback requirements. Disclosure of gifts should be a part reported in the relevant subsection on assets if they Scholarship of the gift regulations. are below the reporting threshold, while they must be Inheritance reported in the subsection on gifts, which has a lower To be able to identify possible interests affecting value threshold for disclosure (see the next paragraph). Lottery and gambling win public officials because of gifts or undue benefits Monetary prize disguised as gifts, the subsection should require We recommend establishing a monetary threshold Damages (compensation for a loss or an injury) information on all gifts, including those received as for reporting gifts to avoid the disclosure of small- Income/distribution from a trust or assets held in trust cash or as in-kind benefits. The latter (for example, value gifts and hospitality. Such a threshold should Other income Specify which one sponsored travel) are gifts that have a known be set for one-time gifts and gifts received from one monetary value but are not received directly source during the reporting period to prevent filers as cash or as an object. from artificially splitting a gift into several installments After the type of income is selected, the subsection should ask for the details on each item, as shown in 10 United Nations, Technical Guide to the United Nations Convention against Corruption (New York: United Nations, 2009), 12, table 29. https://www.unodc.org/unodc/en/treaties/CAC/technical-guide.html 54 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 55 to avoid reporting. Thresholds for cash and noncash should prevail, and any gift that has the potential to Table 31. (continued) gifts can also be different, with a lower threshold influence the impartial judgment of public officials for cash gifts because they represent a higher risk should be disclosed in the form. Field / Options in a drop-down list Subfields Characteristics / Notes to the field (for example, US $ 50 for cash gifts and US $ 200 Date received A pre-set date format for noncash gifts). The subsection should first ask for information on the Comments/explanation An empty field for the declarant to provide type of gift and the recipient, as shown in table 30. an explanation regarding the information The exact amount of the gift threshold should reflect submitted in this subsection (optional) the national context, including the average income For cash gifts (donations, financial assistance), the level and the country’s anti-corruption regulations on subsection should cover cash or the cash equivalent For other gifts (noncash), the subsection should or providing an opportunity to use certain assets, such gifts. However, the main consideration in deciding (for example, vouchers and pre-paid gift cards), cover material benefits received free of charge in a as a vehicle, for free); written-off debt; and discounts on the gift threshold should not be filer convenience donations, and financial assistance received by form other than cash. Such benefits can be a payment for goods or services that are not generally available. or the prevailing tradition. Giving gifts to public the official or family members that does not have by another person for services for the benefit of the The subsection should ask for the information officials may be a well-established tradition in the to be repaid. Financial assistance that must be declarant or family member (for example, paying for shown in table 32 for each noncash gift above the country, but this does not eliminate the risks of a repaid is considered a financial obligation and their education, travel, medical services, or utilities, value threshold. conflict of interest or bribes disguised as gifts and should be reported in the relevant section of the should not mean that the disclosure form should form. The subsection should ask for the information Table 32. Noncash gifts set a high threshold to exclude the reporting of shown in table 31 for each cash gift above the most of the gifts. The anti-corruption considerations value threshold. Field / Options in a drop-down list Subfields Characteristics / Notes to the field Type of noncash gift Table 30. Type of gift and recipient Object Field / Options in a drop-down list Subfields Characteristics / Notes to the field Hospitality or entertainment Type of gift Payment for travel Cash gift (donation, financial assistance) Gift in a form other than cash Payment for education Recipient Payment of medical expenses Declarant Payment for accommodation Family member Choose the family A drop-down list of family members entered member in section 2.3. Written-off debt Discount for goods/services Table 31. Cash gifts or their use for free Field / Options in a drop-down list Subfields Characteristics / Notes to the field Other Specify which one Empty field to enter data Type of cash gift Gift description Empty field to enter description Gift Value of noncash gift received Empty field to enter data Donation (in the currency in which it was paid for) Financial assistance Voucher Currency A drop-down list of currencies Pre-paid card Source of gift Other cash equivalent Specify which one Empty field to enter data An individual Block of fields Amount Empty field to enter data “ID of Individual” (in the currency in which gift was received) A legal entity Block of fields Currency A drop-down list of currencies “ID of Legal Entity” Source of cash gift Date received A pre-set date format An individual Block of fields “ID of Individual” Comments/explanation An empty field for the declarant to provide an explanation regarding A legal entity Block of fields the information submitted in this “ID of Legal Entity” subsection (optional) 56 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 57 Section 5. Financial liabilities Table 33. (continued) The debts, obligations, loans, mortgages, and other Similar to section 4, “Income,” and other sections Field / Options in a drop-down list Subfields Characteristics / Notes to the field financial liabilities incurred by the public official and of the form, the financial liabilities of a declarant or Date issued A pre-set date format family members are essential to completing the a family member as a sole proprietor or in another Original liability amount Empty field to enter data wealth variation analysis. These liabilities are also similar status should be reported in this section indicators of possible interests affecting the official. as well. The liabilities of legal entities in which the Currency of liability A drop-down list of currencies It is important to note that this section requires the declarant or family member have shares or other Annual interest rate A pre-set date format disclosure of information related only to what the interests should not be reported. public official owes to someone else because what No-interest liability A checkbox is owed to the official has already been declared in The section on financial liabilities should cover Amount outstanding Empty field to enter data section 3, “Assets.” This distinction should be included information on the declarant and all family members. (as of the end of the reporting period) in the form to clarify the disclosing obligations. Amount paid toward the liability Empty field to enter data The section should include the details shown in table during the reporting period To avoid the disclosure of small-amount liabilities, 33 for each obligation. the law should set a threshold (for example, Amount paid toward the interest Empty field to enter data US $ 3,000 for the original liability amount). during the reporting period Liability maturity date A pre-set date format Table 33. Financial liabilities Guarantor Field / Options in a drop-down list Subfields Characteristics / Notes to the field (if liability includes a guarantee) Type of financial obligation An individual Block of fields “ID of Individual” Bank loan A legal entity Block of fields “ID of Legal Entity” Loan from nonbanking financial institution Collateral (if liability includes a collateral) Overdraft/credit card debt Yes Type of asset A drop-down list of assets (real estate, Mortgage vehicle, securities, and so forth) Consumer credit Location of asset Leasing/hire purchase - Block of fields “Address” Tax debt Owner of asset Life insurance Declarant Other type of insurance Family member Choose the family member Private loan Another individual - Block of fields Financial obligation in which the “ID of Individual” declarant or family member is a A legal entity guarantor - Block of fields Other Specify which one Empty field to enter data “ID of Legal Entity” Borrower No Declarant Comments/explanation An empty field for the declarant to provide an explanation regarding Family member Choose the family member A drop-down list of family members the information submitted in this entered in section 2.3. section (optional) Creditor An individual Block of fields “ID of Individual” If life insurance was chosen as the type of financial obligation, the form should also ask for the A legal entity Block of fields “ID of Legal Entity” information shown in table 34. 58 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 59 Table 34. Life insurance Table 35. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Premium amount Empty field to enter data Original liability amount Empty field to enter data Payout (policy proceeds) amount Empty field to enter data Currency of liability A drop-down list of currencies Beneficiary Amount outstanding (as of the end of the Empty field to enter data reporting period if known to the declarant) Declarant Liability maturity date (if known to the A pre-set date format Family member Choose the family A drop-down list of family members declarant) member entered in section 2.3. Comments/explanation An empty field for the declarant to An individual (nonfamily member) Block of fields provide an explanation regarding “ID of Individual” the information submitted in this A legal entity Block of fields subsection (optional) “ID of Legal Entity” Insurer An individual Block of fields “ID of Individual” Section 6. Expenditures and other transactions A legal entity Block of fields The disclosure of expenditures and other in the section on expenditures and other “ID of Legal Entity” transactions is important to getting the full transactions. picture of the declarant’s financial situation, to The section may also cover financial obligations type of financial obligation (“financial obligation tracking variations in wealth, and to managing To avoid the reporting of minor transactions, in which the declarant or family member is a in which the declarant or family member is a conflicts of interest. The section on assets there should be a threshold for expenditures and guarantor because this is a potential obligation guarantor”); if this obligation is included in the form captures only expenditures resulting in the other transactions (for example, US $ 3,000 per and can show an important interest. This and chosen by the declarant, then the declarant acquisition of assets and loans given. expenditure or cumulatively for several expenditures information could be presented as a separate must provide the details shown in table 35. Expenditures, as a separate category, cover if made separately to acquire the same asset or payments for services (travel, medical, education, service; alternatively, the threshold may be linked Table 35. Financial obligations in which the declarant or family member is a guarantor and so forth) and works (construction and to the declarant’s salary, such as the monthly salary so forth), gifts or donations provided by the rate). The exact amount of the threshold should Field / Options in a drop-down list Subfields Characteristics / Notes to the field declarant or family member, and other transactions be based on the country context, including average Guarantor not covered in other parts of the form. These income level. transactions include the exchange of assets — Declarant that is, the acquisition and disposal of the same The section on expenditures and other transactions Family member Choose the family A drop-down list of family members asset during the reporting period. To avoid should cover information on the declarant and all member entered in section 2.3. duplication, the form should clarify that if the family members. declarant has already reported the transaction Borrower The same person cannot be the in other sections (for example, acquisition The section should include the details shown in table borrower and the guarantor of assets in the section on the relevant type 36 for each expense or transaction above the value Declarant of asset), it should not be reported again threshold. Family member Choose the family A drop-down list of family members member entered in section 2.3. Creditor An individual Block of fields “ID of Individual” A legal entity Block of fields “ID of Legal Entity” Date issued A pre-set date format 60 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 61 Table 36. Expenses and other transactions Table 36. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Field / Options in a drop-down list Subfields Characteristics / Notes to the field Type of expense or transaction Date of expenditure or other transaction A pre-set date format Acquisition of an asset if disposed of by Type of acquisition If the asset was acquired Country of expenditure or other transaction A drop-down list of countries the end of the reporting period during the reporting period Purchase Counterparty to the transaction An individual or legal entity that and was kept (that is, the asset received the payment from the Inheritance was not disposed of in any way) declarant or family member until the end of the reporting Gift period, it should be reported An individual Block of fields Exchange under the relevant subsection “ID of Individual” on assets and should not be Other reported here. A legal entity Block of fields “ID of Legal Entity” Disposal of an asset if acquired during the Type of disposal reporting period Comments/explanation An empty field for the declarant to Sale provide an explanation regarding the information submitted in this Gift subsection (optional) Exchange Depletion (if the asset was of a nature that could be used up) Section 7. Activities outside of public service and other interests Loss To act as an effective conflict-of-interest prevention conflicts of interest that may arise in the performance Other and management system, the form should require of the official’s duties. In some countries, concurrent Payment for services declarants to provide detailed data on their interests. employment is allowed if it does not occur during The sections of the form covering assets, income, the working hours of the public official and does Rent expenditures, and liabilities may also indicate relevant not conflict with the duties of the position. In other Mortgage payment interests (for example, a relationship with a person countries, only research, educational, creative, and who lent money to the declarant or a legal entity that other activities (such as being a sports referee or Insurance payment paid fees to the declarant’s family member). This engaging in medical practice) are allowed while the Expenses for construction (renovation) section focuses on other types of interests that are official is in public office. When a position generates not linked to assets and are not relevant to the wealth income, it is also reported in the section on income, Tax payment analysis of the declarant. To better organize the so the subsection on employment and activities Charity or other donations information on interests, we recommend requesting it may include some duplicate information. This Gift through the following subsections. subsection also covers positions and membership in management, supervisory, control, and other bodies Investment 7.1. Concurrent employment and activities of commercial and noncommercial organizations Other Specify which one Empty field to enter data of the declarant (paid or unpaid) (such as executive or supervisory boards and audit commissions). This subsection concerns only the Who made the expenditure or other Legislation often prohibits or restricts public officials declarant. transaction? from having additional employment or engaging Declarant in activities outside of public office. Even if the The subsection should include the fields shown Family member Choose the family member A drop-down list of family employment or activity is not prohibited, it is still in table 37 to properly identify each concurrent members entered in section 2.3. useful to have this information for managing possible employment or activity. Description of subject of expenditure or Empty field to enter data other transaction Amount of expenditure or other transaction, Empty field to enter data or value of property subject to transaction Currency of expenditure, other transaction, A drop-down list of currencies or value of property 62 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 63 Table 37. Concurrent employment or activity 7.2. Previous employment of the declarant In addition, this subsection could be made mandatory only in the declarations of candidates/applicants Field / Options in a drop-down list Subfields Characteristics / Notes to the field Data on previous employment can facilitate the for public office or for their entry declarations filed Name of the organization in which the Empty field to enter data evaluation of a potential conflict of interest. It shortly after taking public office. As a result, the official has concurrent employment, holds is essential to define the time frame covered by official would not need to repeatedly disclose the a position, or is otherwise engaged this subsection. To prevent it from becoming a same information in regular declarations while in Type of organization burdensome requirement for the declarant, it could office. This subsection concerns only the declarant limit the scope of time to the previous three years or because requiring such information on family Commercial entity A drop-down list of different the last three positions, whichever option covers a members would be excessive. forms of commercial entities longer period. If the declarant held several positions Charity in the same organization, only the last position held The subsection should include the fields shown in Civic association would be reported. table 38 for each of the employment positions held. Professional association Table 38. Previous employment Academic institution Field / Options in a drop-down list Subfields Characteristics / Notes to the field Higher education institution Was it a public sector position? Other Specify which one Empty field to enter data Yes Organizational/structural unit within the Empty field to enter data organization (if applicable) No Organization’s official address Block of fields “Address” Name of the organization Empty field to enter data Title of the position held concurrently (if applicable) Organizational/structural unit within Empty field to enter data the organization Director Organization’s official address Block of fields “Address” Member of the executive board Organization’s head office address Block of fields “Address” Member of the supervisory board (if different from the official address) Member of the control/audit committee Other Specify which one Empty field to enter data Title of the position Empty field to enter data Type of activity in which the declarant is Appointment date A pre-set date format engaged (if applicable) Date of termination of employment A pre-set date format Teaching Research Comments/explanation An empty field for the declarant to provide an explanation regarding Medical practice the information submitted in this Sports referee subsection (optional) Creative activity Specify which one Empty field to enter data Other Specify which one Empty field to enter data 7.3. Rights of representation (agency) information on the powers of attorney or other rights Appointment date for the concurrent A pre-set date format for the declarant of representation (agency) that the public official issued to other persons or the powers of attorney or employment or position When the public official acts as an agent for another other rights of representation (agency) in which the Paid or unpaid individual or entity (whether public or private), it official is named as an agent of another person or Paid creates interests, which may conflict with the official’s entity. This subsection concerns only the official. public duties. A similar situation arises when the Unpaid public official authorizes another person or entity to This subsection should include the information shown Comments/explanation An empty field for the declarant to represent her. This subsection of the form captures in table 39. provide an explanation regarding the information submitted in this subsection (optional) 64 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 65 Table 39. Rights of representation (agency) of public funding. The subsection could also between the declarant or family members and the capture contracts in which one party is a public public law entity. Field / Options in a drop-down list Subfields Characteristics / Notes to the field law entity and in which the declarant, a family Document certifying rights of representation member, or a company controlled by them The legislation may establish a value threshold to (for example, a power of attorney) is issued by is a subcontractor. avoid disclosure of low-value contracts (a value threshold for one contract and a cumulative Declarant To go even further, the subsection can extend value threshold for contracts concluded with one Another individual or legal entity in the name to government contracts concluded by any legal government agency during the reporting period). of the declarant entity in which the declarant or family member The subsection could ask for information about holds a management position (director or another qualifying contracts that were valid at any time Identification details of the person who issued the top executive, member of a management or during the reporting period for the respective document certifying rights of representation or whom supervisory board). The disclosure of such declaration. the declarant authorized to represent him or her contracts should be required only to the extent An individual Block of fields that the declarant is aware of them. The This subsection should include the information shown “ID of Individual” subsection excludes employment contracts in table 40 for each contract. A legal entity Block of fields Table 40. Government contracts “ID of Legal Entity” Field / Options in a drop-down list Subfields Characteristics / Notes to the field Date on which the document certifying rights of A pre-set date format representation was issued Start date of the contract A pre-set date format Country in which the document certifying rights of A drop-down list of countries End date of the contract A pre-set date format representation was issued Subject matter Duration of validity of the document certifying rights Start date A pre-set date format of representation Procurement of goods A drop-down list of types End date A pre-set date format of procurement Was the document notarized? Procurement of services A drop-down list of types Yes Name of the notary Empty field to enter data of procurement Block of fields Procurement of works A drop-down list of types “ID of Individual” of procurement No Lease of real estate or other public assets A drop-down list of types of assets Comments/explanation An empty field for the declarant to provide an explanation regarding Other Specify which one Empty field to enter data the information submitted in this subsection (optional) Name of the public law entity Empty field to enter data (public authority, local self-government agency, public company) that is a party to the contract 7.4. Government contracts The subsection should capture any type of contract (consulting, legal, other services, public procurement, Declarant’s relationship with the public law entity Information on contracts entered into by the lease of real estate, and so forth) in which one official, family members, or associated legal party is a public law entity (state authority, local Declarant works in the entity or exercises entities with public sector entities can expose self- self-government authority, or public company) and control or supervision over the entity at the dealing and is important for managing conflicts of another party is the declarant, a family member, time of disclosure submission interest. For example, if the company owned by the or a company controlled by one of them (through declarant’s spouse receives major procurement holding a majority stake in the company or other Declarant worked in the entity or exercised control or supervision over the entity contracts from the public agency in which the types of control). Another situation that could during the past three years declarant works, the information on the form to this involve a conflict of interest is a contract that is effect could reveal a real conflict of interest or even funded by public funds, public grants, international None an abuse of office. assistance provided to the country, or other sources 66 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure: A Technical Guide to an Effective Form 67 Table 40. (continued) Field / Options in a drop-down list Subfields Characteristics / Notes to the field Total value of the contract Empty field to enter data Amount paid under the contract as of the Empty field to enter data last day of the reporting period for the declaration Recipient of funds under the contract Declarant Family member Choose the family member A drop-down list of family members entered in section 2.3. Legal entity associated with the declarant Block of fields “ID of Legal or family member Entity” Explain association with the legal entity Holding a majority stake in the share capital Beneficial ownership or control (as defined in section 3.8.) Other association (specify Empty field to enter data which one) Comments/explanation An empty field for the declarant to provide an explanation regarding the information submitted in this subsection (optional) 68 Asset and Interest Disclosure: A Technical Guide to an Effective Form Appendix. Previous publications on asset and interest disclosure systems y Rossi, Ivana M., Laura Pop, and Tammar Berger. Getting the Full Picture on Public Officials: A How-To Guide for Effective Financial Disclosure. Stolen Asset Recovery (StAR) Series. Washington, DC: World Bank, 2017. https://star.worldbank.org/sites/star/files/getting-the-full-picture-on-public-officials-how-to-guide.pdf y Kotlyar, Dmytro, and Laura Pop. E-filing Asset Declarations: Benefits and Challenges. Stolen Asset Recovery (StAR) Series. Washington, DC: World Bank, 2019. https://star.worldbank.org/publications/e-filing-asset-declarations-benefits-and-challenges y World Bank. Enhancing Government Effectiveness and Transparency: The Fight Against Corruption. Washington, DC: World Bank, 2020, 224–48. www.worldbank.org/en/topic/governance/publication/enhancing-government-effectiveness-and- transparency-the-fight-against-corruption y Kotlyar, Dmytro, and Laura Pop. Automated Risk Analysis of Asset and Interest Declarations of Public Officials: A Technical Guide. Stolen Asset Recovery Initiative (StAR) Series. World Bank, Washington, DC, 2021. https://star.worldbank.org/resources/automated-risk-analysis-asset-and-interest-declarations-public-officials y Kotlyar, Dmytro, and Laura Pop. Asset Declarations: A Threat to Privacy or a Powerful Anti-Corruption Tool? World Bank, Washington, DC, 2016. www.worldbank.org/en/news/opinion/2016/09/26/asset-declarations-a-threat-to-privacy-or-a-powerful-anti- corruption-tool y World Bank, Organization for Cooperation and Development, and United Nations Office on Drugs and Crime. Good Practices Guide, Preventing and Managing Conflicts of Interest in the Public Sector. World Bank, Washington, DC, 2020. https://documents.worldbank.org/en/publication/documents-reports/ documentdetail/950091599837673013/preventing-and-managing-conflicts-of-interest-in-the-public-sector- good-practices-guide 70 Asset and Interest Disclosure: A Technical Guide to an Effective Form Asset and Interest Disclosure. A Technical Guide to an Effective Form Asset and interest disclosure of public officials is a well-established tool to prevent corruption and to help strengthen integrity in public administration. Countries use it to identify unexplained wealth, prevent conflicts of interest, and promote accountability and integrity of public officials. Asset and interest disclosure is a mechanism by which public officials must submit information about income, assets, liabilities, expenditures, and other interests of the officials and their family members. This mechanism includes many elements, including the disclosure form, the scope of declarants (filing population), methods of submission (paper or electronic), procedures of submitting the form, validation and verification of the forms, publication of information, institutional set-up to deal with the disclosure system, sanctions, and others. This technical guide focuses on the disclosure form. How and what data are requested in the form represents the disclosure system's main and most important input. It also defines declarations' role in the anti-corruption value chain. This guide builds on the previous extensive work of the World Bank and StAR on the topic of asset and interest disclosure of public officials. It reflects an analysis of the legal framework of more than 150 jurisdictions, combined with the experience gained working directly with countries throughout the different stages of their disclosure system reforms. Finally, the recommendations reflect the changing nature of corruption typologies and the diverse uses that financial disclosure can have. This guide is intended for policymakers and asset declaration practitioners who create a new disclosure form or redesign an existing one to make it more robust. The anti-corruption agencies and other institutions in charge of the asset and interest disclosure system can use this guide when developing or upgrading an electronic, and to a certain extent, the content requirements of a paper form. International organizations and civil society organizations can use this guide as a benchmark to assess the relevance and effectiveness of the national asset and interest declaration forms and promote their reform.