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For the Period 2017/2018
March, 2019
Assets Declarat ion/ Ver i f icat ion Repor t
Assets Declaration Verification Report
January 2015 to March 2019
1 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
TABLE OF CONTENTS
LIST OF ACRONYMS ................................................................................................... 2
EXECUTIVE SUMMARY .............................................................................................. 3
BACKGROUND / INTRODUCTION.............................................................................. 5
OBJECTIVES OF THE ASSET VERIFICATION EXERCISE ....................................... 5
METHODOLOGY .......................................................................................................... 6
Subjects Selection Risk Criteria .................................................................................... 7
The 2017 Cycle - Asset Declaration .............................................................................. 9
The 2017 Cycle - Asset Verification .............................................................................. 9
The 2018 Cycle - Asset Declaration ............................................................................ 10
The 2018 Cycle Asset Verification .............................................................................. 10
FINDINGS ................................................................................................................... 11
CONCLUSIONS .......................................................................................................... 13
ACKNOWLEDGEMENTS ........................................................................................... 13
Assets Declaration Verification Report
January 2015 to March 2019
2 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
LIST OF ACRONYMS
ABBREVIATION MEANING
ADB African Development Bank
CBL Central Bank of Liberia
CNDRA Center for National Documents and Archives
EPA Environment Protection Agency
EU European Union
FDA Forestry Development Authority
GAC General Auditing Commission
GSA General Services Agency
IAA Internal Audit Agency
JFK John F. Kennedy
LACC Liberia Anti-Corruption Commission
LACE Liberia Agency for Community Empowerment
LCAA Liberia Civil Aviation Authority
LIPA Liberia Institute of Public Administration
LIS Liberia Immigration Service
LMA Liberia Maritime Authority
LPRC Liberia Petroleum Refinery Company
LRA Liberia Revenue Authority
MCC Monrovia City Corporation
MFDP Ministry of Finance and Development Planning
MIA Ministry of Internal Affairs
MICAT Ministry of Information
MLME Ministry of Land, Mines & Energy
MOA-CARI Ministry of Agriculture-Central Agriculture Research Institute
MOD Ministry of Defense
MOE Ministry of Education
MOGSP Ministry of Gender and Social Protection
MOH Ministry of Health
MOL Ministry of Labor
MOS Ministry of State
MPW Ministry of Public Works
NASSCORP National Social Security Cooperation
NOCAL National Oil Company of Liberia
NPA National Port Authority
NPHI National Public Health Institute
NTA National Transit Authority
RIA Robert International Airport
SIDA Swedish Agency for International Development
UNDP United Nations Development Program
USAID United States Agency for International Development
WB World Bank
Assets Declaration Verification Report
January 2015 to March 2019
3 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
EXECUTIVE SUMMARY
On 16th September 2005, Liberia officially joined the global fight against corruption by
ratifying the United Nations Convention Against Corruption, the only legally binding
universal anti-corruption instrument. The Convention covers five main areas: preventive
measures, criminalization and law enforcement, international cooperation, asset
recovery, and technical assistance and information exchange.
Nationally, the Liberia Anti-Corruption Commission was established in 2008 by an Act
of Legislature to investigate, prosecute and prevent acts of corruption of public officials
in Liberia. With the National Code of Conduct mandating the declaration of assets by all
public officials, and the LACC being the major repository and compliance enforcement
institution of such declarations, the Body of Commissioners of the LACC, resolved to
conduct periodic asset declaration verification of all public officials. Therefore, in
February 2013, the Body of Commissioners commissioned the first asset verification
regime.
In compliance with the February 2013 Body of Commissioners’ directive, the LACC
initiated the third Asset Declaration Verification exercise in September 2018, covering
the 2017 and 2018 cycles of declarations. The third Asset Declaration Verification
exercise is ongoing and Team VERITAS, the consortium of anti-graft institutions and
relevant third-party information source entities partnering with the LACC to undertake
this task, has concluded the off-site verification phase of the exercise.
The 2017 Cycle of declarations covered the period January 2015 to December 2017.
There was a total of 573 declarations, comprising 126 females and 447 male public
officials across 69 contributing ministries, agencies, corporations / commissions and
state-owned enterprises. On the other hand, the 2018 Cycle covered the period January
2018 to March 2019 and recorded a total of 344 declarations with 79 female and 265
male declarants.
Based upon pre-established risk criteria, subjects were selected from the pool of 2017
and 2018 declarants for the third asset declaration verification exercise. A total of 70
subjects were drawn from the 2017 cycle, constituting 12.22% of the overall 2017 cycle
declarations as opposed to 52 from the 2018 cycle which constitutes 15.12% of total
declaration over the period. The 2017 asset declaration verification subjects comprised
Assets Declaration Verification Report
January 2015 to March 2019
4 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
a 19:81 female to male ratio out of 30 entities, represented, while the 2018 cycle pool
contains a 33:67 female to male ratio across 26 resulting entities.
Findings from the compliance checks and thorough desk reviews of the subjects’
declarations reveal frequent instances of fixed assets declared not being registered with
relevant national agencies through which values and ownerships of said assets can be
established and cross-checked. Similarly, there were valuation inconsistencies with
some declared and otherwise documented landed properties.
The instances mentioned above are inimical to transparency, especially considering
that real properties are a major avenue for corruption and channeling of illicit wealth. To
this end, the LACC, in continuation of its asset verification engagement, shall advance
to on-site verifications and interview of subjects of such concerns.
Assets Declaration Verification Report
January 2015 to March 2019
5 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
BACKGROUND / INTRODUCTION
In fulfillment of the Article 90(c) mandate of the 1986 Constitution of the Republic of
Liberia, the June 20, 2014, “ACT OF LEGISLATURE PRESCRIBING A NATIONAL
CODE OF CONDUCT FOR ALL PUBLIC OFFICIALS AND EMPLOYEES OF THE
GOVERNMENT OF THE REPUBLIC OF LIBERIA” was enacted. The National Code of
Conduct, in Part 10, provides for the Declaration and Registration of Personal Interests,
Assets and Performance/Financial Bonds by all public officials and employees of
government. The NCoC specifically states under 10.2 Repository and Contents of
Declaration, inter alia, “…All such declarations shall be accessible to both the public
employer and the general public upon a court order; as well as to the Liberia Anti-
Corruption Commission (LACC) for investigative purposes. …”. Hence, the ongoing
Asset Declaration and Verification exercises initiated by the LACC are in fulfillment of
her constitutional duties to ensure accountability and transparency in public
governance.
Asset declaration by public officials and employees of government form the basis for
engaging with declarants. Whereas the verification process is not an investigation;
however, preponderance of discrepancies and cloudiness of declarations may warrant
administrative punishment or gravitate to full-scale investigation and subsequent
prosecution, as the case may be, pursuant to Part 10.3 Sanctions for False Declaration
of the NCoC and PART IV – POWERS OF THE COMMISSION of the LACC Act.
OBJECTIVES OF THE ASSET VERIFICATION EXERCISE
The major objectives of the verification exercise are to establish the truthfulness of asset
declarations and also to ascertain the existence, ownership, possession (in case of
assets) and completeness (in case of liabilities) and valuation of items declared to the
LACC.
The asset declaration verification exercise is also intended to ensure that public officials
are not engaging in illegal wealth acquisition and that their official actions are in
compliance with provisions of the National Code of Conduct and relevant laws regarding
transparency and accountability.
Assets Declaration Verification Report
January 2015 to March 2019
6 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
METHODOLOGY
Team Composition
The Asset Declaration Verification (ADV) Team, code named Team VERITAS, is an
inter-agency collaborative team comprised primarily of the LACC with technical inputs
from major anti-graft institutions and relevant, public and private, third party data and
information source entities.
Team VERITAS adopted an off-site verification approach emphasizing thorough desk
reviews of declarations selected for the periods under review. The process began with
tallying declarations and assets mapping for the purpose of determining the
concentration of fixed assets across the counties. Additionally, it also disaggregated the
distribution of declarants along lines of gender, agencies and filing dates. The risk
criteria were then established to guide the process of selecting subjects.
Mixed methods were used in the verification process. Due to the limited time available
to the team for the exercise, the scope was narrowed to assessing financials reported
and real estate listed by the declarants.
The depth of the exercise equally matched the scope due to the same time constraint.
Hence, the team used prima facie to check the veracity of the information provided by
the declarants. A basis check was used to ascertain whether the statements appear
properly completed or if there are obvious incorrect entries, or missing information.
Additionally, the team used simple verification to determine whether the declared assets
appear sufficiently accounted for by declared/legal sources of income or whether
declared data appear to indicate suspicious activities.
Partial audit also formed part of the verification methods. In this case, third party data
was used to compare the stated data provided by the declarants.
Preliminary processing considered the following: material mistakes; incorrect
completion; mistaken responses; arithmetic and logical checking; accuracy of the
evaluation of the assets declared; accuracy of the financial sources declared;
sufficiency of the coverage of assets with the declared sources, and to some extent, the
verification of the accuracy of the data included in the declaration form.
Assets Declaration Verification Report
January 2015 to March 2019
7 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
Declarations were cross-checked for compliance and completeness as well as clarity of
declared liabilities. All assets, as much as possible, were cross-checked with available
relevant third-party data sources. Banking information were also cross-checked against
relevant third party data sources. Non-compliances were then catalogued for further
consideration.
Subjects Selection Risk Criteria
Following are the risk criteria used in the selection of subjects for the 2017 Cycle
valuation exercise:
1. High-spending ministries, agencies and state-owned enterprises. The key points
of reference are the national budgets (FY 2015 – 2018). Selection was made
based on volume of allotments to entities over the period under consideration.
2. High revenue- and income-generating entities.
3. A component 15% random selection based on public opinion and frequent
discussion of subjects along lines of accountability and transparency over the
period under consideration
4. An additional component of 5% based on open-source information and
5. Gender sensitivity over the entire sample space of the respective cycles.
Institutions Actual 2015/16 Actual 2016/17 Actual 2017/18
National Public Health Institute 196,883.00 65,316.00 3,396,925.00
Monrovia City Corporation 2,564,945.00 3,548,036.00 750,000.00
Central Bank of Liberia 2,876,905.00 3,290,654.00
Environment Protection Agency 1,702,194.00 2,669,885.00 1,597,245.00
Robert International Airport 4,443,653.00 11,360,436.00
Liberia Civil Aviation Authority 10,786,619.00
Ministry of State 17,737,047.00 20,417,291.00 8,573,657.00
Ministry of Labor 1,858,067.00 1,597,821.00 1,401,291.00
Forestry Development Authority 4,291,898.00 5,769,058.00 4,841,645.00
General Services Agency 1,890,697.00 2,502,052.00 194,317.00
Ministry of Internal Affairs 9,885,349.00 12,973,116.00 10,638,268.00
Liberia Immigration Service 4,056,562.00 5,608,674.00 5,529,722.00
Ministry of Information 3,546,914.00 3,189,753.00 2,703,135.00
National Archives (CNDKA) 896,154.00 824,586.00 738,366.00
Ministry of Defense 12,738,531.00 14,419,263.00 16,042,785.00
NASSCORP 32,006,589.00 12,403,153.00 19,854,231.00
Assets Declaration Verification Report
January 2015 to March 2019
8 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
Institutions Actual 2015/16 Actual 2016/17 Actual 2017/18
LACE 493,238.00 605,116.00 1,498,380.00
National Transit Authority 2,662,169.00 2,089,496.00 1,867,324.00
Ministry of Education 78,918,570.00 40,141,722.00 40,180,316.00
Ministry of Health 64,454,376.00 40,669,008.00 44,306,339.00
Ministry of Agriculture-CARI 3,794,735.00 3,049,755.00 1,884,187.00
Ministry of Gender 2,922,575.00 3,831,147.00 2,580,120.00
Liberia Revenue Authority 18,747,242.00 17,954,280.00 16,566,501.00
Ministry of Finance and
Development Planning 54,392,260.00 44,363,246.00 29,206,688.00
LPRC 44,952,334.00 7,497,590.00 16,858,679.00
National Port Authority 23,040,369.00 23,317,160.00 16,980,985.00
Ministry of Land, Mines & Energy 2,828,398.00 2,702,230.00 2,214,396.00
Ministry of Public Works 41,461,742.00 25,082,556.00 7,218,033.00
Liberia Maritime Authority 11,820,823.00 7,851,581.00 7,252,690.00
LIPA 1,156,946.00 164,544.00 1,017,470.00
LACC 2,584,287.00 2,386,116.00 2,119,315.00
General Auditing Commission 5,674,562.00 5,297,394.00 4,978,784.00
Internal Audit Agency 3,676,536.00 4,820,434.00 3,882,387.00
NOCAL 5,936,236.00 4,157,660.00 2,686,438.00
JFK 5,895,357.00 5,066,941.00 5,592,960.00
Total 473,228,238.00 341,273,321.00 299,230,852.00
-
20,000,000.00
40,000,000.00
60,000,000.00
80,000,000.00
Sum of Actual 2015/16 Sum of Actual 2016/17 Sum of Actual 2017/18
Assets Declaration Verification Report
January 2015 to March 2019
9 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
The 2017 Cycle - Asset Declaration
The 2017 Asset Declaration Cycle, abridged as 2017 Cycle, span January 2015 to
October 2017. It comprises a total of 573 declarations with a 78:22 male to female
declarants ratio across 68 contributing entities of the Executive Branch of Government
and a noteworthy individual political aspirant. It must be pointed out that there were
fewer than 3 instances where a sitting public official was assigned to a different or higher
office, thus prompting a fresh declaration given the circumstance. Such declarations are
treated here as independent and not a duplication.
Of the total declarations, the Ministry of Internal Affairs contributed 15.01%, followed by
the Liberia Revenue Authority with 8.2%, the Ministry of Foreign Affairs with 5.58%,
NASSCORP with 3.49% and the Ministry of Public Works with 3.14%. The Central Bank
of Liberia is ahead of the remaining list of 63 other contributing entities along with an
individual private citizen.
The 2017 Cycle - Asset Verification
Upon the risks criteria set for selection of subjects for verification in the 2017 Cycle, the
process proceeded. A total of 70 declarations were selected for verification out of the
pool of 573, constituting 12.22%. Drawn from a total of 30 entities, the 2017 Cycle
verification pool comprise 18.57% females and 81.43% males. The LRA and MPW each
account for 10% of total declarations verified. LACC, MFDP, MOH and NASSCORP
follow with 5.71% each of total declarations verified. The Ministries of Lands, Mines and
Energy, Agriculture, Commerce and Industry and the Public Procurement and
Concessions Commission share the third highest frequency with 4.29% each. The
remaining 20 contributing entities constitute a combined 40% of total declarations
verified in the 2017 Cycle.
Assets Declaration Verification Report
January 2015 to March 2019
10 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
The 2018 Cycle - Asset Declaration
The 2018 Cycle span March 2018 to March 2019 and recorded a total of 344
declarations. Of this amount, total female declarations constitute 23% compared to 77%
male. There were submissions from a total of 80 entities of the Executive Branch of
Government, including the Presidency. The Ministry of Internal Affairs contributed the
most declaration with 9.3%, followed by the Ministry of Foreign Affairs with 4.65% and
the Ministries of Education, Justice, State for Presidential Affairs, Public Works and the
National Fisheries and Aquaculture Authority each contributing in the range of 3%. The
remaining 73 contributing entities formed a combined 69.77% of total declarations.
The 2018 Cycle Asset Verification
A total of 52 declarations were selected out of a pool of 344 for verification in the 2018
Cycle. This constitutes 15.12% of total declarations. The 2018 Asset Verification Cycle
of subjects comprise 32.69% women and 67.31% men across 26 contributing entities
with the Center for National Documentation and Records and the Ministry of Public
Works each accounting for 8.82% of total verifications. The Forestry Development
Authority, Ministry of Foreign Affairs, Ministry of Commerce and Industry and the
Ministry of Labor jointly contribute an even spread of 24% of total verifications. The
remaining 20 contributing entities account for a cumulative 58.82%.
0.00%
2.00%
4.00%
6.00%
8.00%
10.00%
12.00%
0
1
2
3
4
5
6
7
8
LRA
MP
W
LAC
C
MFD
P
MO
H
NA
SSC
OR
P
MLM
E
MO
A
MO
CI
PP
CC
FDA
LAA
LNP
LPR
C
LTA
MIC
AT
MO
D
MO
E
CB
L
LBR
LBS
LISG
IS
LMA
MFA
MO
GC
SP
MO
T
MSP
A
NA
C
NIC
NSA
VERIFICATION DISTRIBUTION - 2017 CYCLE
FREQUENCY % COMPOSITION
Assets Declaration Verification Report
January 2015 to March 2019
11 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
FINDINGS
1.0 Complete banking information not disclosed.
There was a single instance where a declarant declared only one account. Considering
that all public officials receive salaries (Liberian Dollar and US Dollars components)
through banks, all declarants must have two bank accounts. Therefore, a declarant who
only provided one account is suspected to have at least one undisclosed alternative
account.
1.1 Suspicious bank loans and repayment plans.
Team VERITAS found 1 instance where bank loan was advanced to a declarant with
repayment scheduled for a 12-month period. Further examination of the loan in
comparison to the declarant’s income, as indicated in the asset declarations, reflects
that even the declarant’s sworn, combined gross salary and allowance would not be
sufficient to absorb or liquidate the amount borrowed by the declarant within the agreed
repayment period. The suspicion surrounding the amount borrowed and the repayment
period vis-a-vis the declarant’s sworn income could provide a basis for illicit fund flows
as well as money laundering.
0.00%
1.00%
2.00%
3.00%
4.00%
5.00%
6.00%
7.00%
8.00%
9.00%
10.00%
0
0.5
1
1.5
2
2.5
3
3.5
VERIFICATION DISTRIBUTION - 2018 CYCLE
FREQUENCY % COMPOSITION
Assets Declaration Verification Report
January 2015 to March 2019
12 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
1.2 Acquisition/appreciation of real property under “unexplained circumstance”.
About 2 properties declared do not commensurate with the income of the declarants.
Consequently, the value of properties accumulated over said period far outweighs the
cumulative salaries and allowances generated during the same period. This creates
more questions as to how the properties were financed, if the salaries and allowances
were the only sources of income for declarants in this category. It is important to note
that real property accumulation is one method by which illicit or ill-gotten wealth is
hidden.
1.3 Real properties declared not registered with the Liberia Revenue Authority.
Thirty percent (30%) of properties declared by subjects were discovered not to be
registered with the Liberia Revenue Authority real estate registry. Indication is that these
properties are not tax compliant and this is a grave transgression of 4.1 Responsibility
to the State and the Public Service of the National Code of Conduct which provides
that “All public officials and employees of government have constitutional and civic
responsibilities …over and above the good conduct and ethical issues… He or she
therefore shall uphold the Constitution and abide by laws, statutes, rules and regulations
of the Republic of Liberia….” And real property tax compliance is both a civic and
constitutional responsibility.
1.4 Conflicting property valuation.
There are 28% of instances of notarized property valuations declared by subjects with
the LACC that do not commensurate with values declared with the LRA.
Assets Declaration Verification Report
January 2015 to March 2019
13 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
CONCLUSIONS
The methods applied led to the identification of some manifest discrepancies between
the declarations and third party sources. After the examination of subject’s declarations,
it became evident that 40% of real estate declared presented one or more discrepancies
ranging from conflicting valuation to non-registration and tax non-compliance.
The “unexplained” financial trends of real property acquisition or appreciation observed
over the periods under review were reflected in 5% of subjects’ declarations.
In order to address the discrepancies and material misrepresentations, the LACC will
further investigate the declarants suspected of the various transgressions listed in the
findings. Based on further findings, appropriate sanctions will be recommended in
keeping with the National Code of Conduct for Public Officials and other related penal
laws.
ACKNOWLEDGEMENTS
The Body of Commissioners of the LACC extends sincere thanks and appreciation to
the Government of the Republic of Liberia, especially the President, His Excellency, Dr.
George Manneh Weah, for the continuous support to the work and operation of the
Commission in its fight against corruption.
We also seize the opportunity to thank our many international partners for the sustained
support – financial and capacity building – in equipping us to fight corruption and foster
the cultures of accountability and transparency. We especially thank the European
Union, through her National Authorizing Office, the United States Agency for
International Development (USAID), the United Nations Development Program (UNDP),
the World Bank, the Swedish Agency for International Development (SIDA), the African
Development Bank, etc. for your unwavering partnership and support.
Our deep appreciation goes to all collaborating agencies that partnered with us to make
this undertaking a success – the Liberia Revenue Authority (LRA), The General Auditing
Commission (GAC), and the Internal Audit Agency (IAA). Finally, our sincere thanks
goes to Team VERITAS for the commitment and dedication you demonstrated in
Assets Declaration Verification Report
January 2015 to March 2019
14 | L i b e r i a A n t i - C o r r u p t i o n C o m m i s s i o n
making this task an awesome reality. Your service to country and your resolute
professionalism are commendable.