Tag Archives: asset declaration

IMF Report on Ukraine Asset Declaration System: Wasting enormous resources on low value tasks, spending little on those that matter

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No, that is not what the new IMF report on Ukrainian’s asset declaration system says. International organizations are never that blunt. 

But reading the careful, thorough assessment of Ukraine’s most important anticorruption program it is clear that is what the authors were thinking given what they found. And what they did say comes awfully close:

  • “The effectiveness of Ukraine’s [Asset Declaration System] is undermined by an overly expansive and highly formalistic framework that overburdens the [National Agency on Corruption Prevention], weakens prioritization, and limits the system’s capacity to support meaningful detection and recovery of illicit assets.”
  • “[Its] expansive scope, which is unmatched by other European nations, strains the NACP by forcing it to manage one of the world’s largest database of public officials’ assets with highly limited resources.”
  • “The conversion of NACP findings into final judicial sanctions remains limited. In 2025, the NACP transmitted 369 reasoned conclusions to law enforcement for criminal prosecution. These resulted in 12 guilty verdicts, a marked improvement from zero verdicts in 2021, but a conversion rate that remains low relative to the volume of referrals and reflects the broader systemic delays in the judicial pipeline for high-level corruption cases.”

More lifestyle audits

Comparing what officials declare they own to their house they live in, the car they drive, the vacations they take, and other properties they own and expenses they incur is the most effective way to spot if they are corrupt (here). The NACP has a unit dedicated to conducting such audits, but as the IMF report found, not only does the Lifestyle Management (LSM) group have a small staff, but the audits do not focus on priority areas such as 

“. . . war-related procurement and expenditure, where the convergence of significant public resources and reduced oversight creates acute corruption vulnerabilities.”  

The recommendation to audit the lifestyle of those involved in procuring military supplies and equipment comes at a critical time. Confidential reviews by the State Audit Service and an internal Ministry of Defense auditing department show war profiteering has reached unconscionable levels. Front-line troops are being supplied with worthless ammunition while military contractors are reaping huge profits (here).

Lifestyle audits are the surest, fastest way to weed out those officials corrupting the military procurement process. NACP staff now conducting routine checks of the accuracy of low-level officials’ declarations should be reassigned to the LSM unit and ordered to scrutinize the lifestyle of every single individual involved in military procurement.

Ukraine’s supporters in the international community have long recognized that an asset declaration program is crucial to curbing corruption and made its establishment a condition of continued financial assistance. The IMF report provides a roadmap for making the program effective. The international community should insist the government follow that map with haste.

Guest Post: Watching Watch Wearers: More on Thailand’s Watchgate Case

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GAB welcome back Craig R. Arndt, an American lawyer now living in Bangkok. Craig has advised a variety of clients on corruption-related matters and represented corruption victims in damage actions. Below he offers a coda to Government Leaders Should Watch Who Watches Them Wearing Their Pricey Watches

In 2018 the Thai public was mesmerized by a photo showing retired General and then Deputy Prime Minister Prawit Wongsuwan wearing a luxury watch. Activists soon found other photos of him sporting a variety of watches together worth $1.5 million. General Prawit was widely mocked for his explanation that they had been loaned to him by a wealthy now deceased friend and that he was not required to report them on his asset declaration form (here and here).

Thailand’s National Anticorruption Commission (NACC) did investigate the non-disclosure claim, it found nothing wrong. Prawit continued his political career, unfazed and unaffected by what had been short-lived damage to his reputation (here). He was the candidate for Prime Minister for the current ruling party in the recent election. Although that party split, his party still gained 40 seats in the face of a resounding defeat of the generals and their allies (here).

Although the NACC concluded that Prawit failure to report the watch collection did violated the asset disclosure law lot violated the law requriwas willing The agency, however, offered no justification for letting Prawit off the hook (here). Thailand’s increasingly assertive civil society was not ready to let the matter drop.

Political Activist Veera Somkwamkid asked the Administrative Court to order NACC to disclose its findings in the Prawit case. The first level administrative court agreed, and April 2023 the Supreme Administrative Court (SAC) upheld the decision and ordered full disclosure of the NACC Prawit files (here).

The SAC’s decision in the Prawit case does not set a precedent under Thai law. The NACC can thus refuse to disclose its reasoning in future cases, meaning those seeking their disclosure will have to tread the path Veera took in Prawit’s. It may a be a slow and treacherous one, but the NACC and Thai officials are on notice it’s a path determined civil society activists are willing to take.

Prawit may still find it easy to find the time of day given his glitzy watch collection, but in Thailand time may be running short on politicians of his ilk

Should Officials’ Asset Declarations Be Public? Why I Changed My Mind About Sierra Leone

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Many countries have some form of asset declaration requirement for public officials, but there is substantial country-by-country variance as to the actual design of the process. There is especially wide variation with respect to the public accessibility of the disclosed information. In Sierra Leone, under current law, government officers’ asset declarations are kept confidential. Before I was appointed head of Sierra Leone’s Anti-Corruption Agency (ACA), I was part of a civil society consortium that called for making all of these declarations public. A few months after my appointment, I was asked if I would support changing the law to make asset declarations public, in line with what I had advocated as a member of civil society. In reflecting on this question, I found that I had changed my mind.

Part of the reason I did not advocate changing the law to make asset declarations public was simply that there was no way our Parliament would pass such an amendment in the short-to-medium term. It did not seem sensible to waste political capital on such a controversial proposal—especially since doing so might provoke a backlash and jeopardize other important reforms. But the reasons for my change of view were not merely pragmatic political calculations. I have also come to believe that, at Sierra Leone’s current stage of development, making asset declarations public could do more harm than good. Continue reading →